Chichester Local Plan 2021-2039 - Main Modifications consultation

Merrow Wood supports the additional wording of Objective 1 in respect of locating new development in accessible locations. Merrow Wood has promoted sites through the Local Plan process at Prospect Farm, Chidham & Hambrook, and Tawny Nurseries, Birdham. Both sites are well located for facilities and services and sustainable transport links to bus and train, as well as walking and cycling. This makes it all the more imperative that the Council allocates additional sites in the Plan now which are sustainable, in order to properly meet the Inspectors' increased housing requirement.

Reference to further sites coming forward in a DPD or Local Plan Review should be deleted and replaced with further allocated sites.

Merrow Wood objects to the modification to Policy S1 which states that further housing allocations being made through either a site allocations DPD or a review of the Local Plan. The Inspectors at Examination have recommended an increase of over 1,100 homes to be delivered in this Local Plan. Such an increase will not be met solely by windfall development which, in any case, fails to provide any certainty of delivery.
The plan’s overall housing requirement of 575 dwellings per annum was significantly below the then Local Housing Needs calculated figure of 763 dwellings per annum. Whilst this has been raised by the Inspectors, it remains significantly short of the new LHN figure for Chichester of 1,305 dwellings per annum.

Even with a fair wind, any local plan review is likely to take 2-3 years, all the more so with resources still dealing with this Plan. Merrow Wood has evidenced sites in its control at Prospect Farm, Chidham and Hambrook and Tawny Nurseries, Birdham, which are available for development early in the Plan period. Both sites have been promoted through the Local Plan process but not yet taken up by the Council. There is now an opportunity to set a path towards sustainably meeting higher housing requirements. Allocating further sites now, which can if necessary be "rolled forward" into a local plan review is a practical way of addressing future housing need.

The current strategy, of adding a further 1,100 dwellings to the housing requirement with no indication at all of how these will come forward, is unsound.

Merrow Wood supports the additional text proposed in Policy NE3 which requires proper reference to landscape character in any assessment of impact upon gaps between settlements. This is welcome as it creates a more evidence based approach, founded in landscape appraisal, rather than the previously more blunt approach.

Merrow Wood supports the addition of the word "any" to the first clause of Policy NE10: The sustainability of the site is enhanced by improving or creating any opportunities to access the site by walking, cycling and public transport;.

Sites located outside existing settlement boundaries may not always benefit from the same opportunities for sustainable travel as those in larger settlements do. However where sites such as Prospect Farm, Chidham and Hambrook, can be located outside settlement boundaries but in locations offering reasonable opportunity for sustainable travel choices, this sould be seen as a positive.

Policy H1 should be revised to include further site allocations, already submitted to the Local Plan process to date, including sites at Prospect Farm, Chidham and Hambrook, and Tawny Nurseries, Birdham to create a table indicating delivery of the additional 1,134 dwellings added to the Plan in the Modifications.

Merrow Wood considers that the Modifications, as proposed are neither legally compliant nor sound. They fail to reflect national policy in that they show no consideration of HOW the additional 1,100 dwellings proposed will be delivered - for example through the Duty to Co-operate or through further allocations. The new NPPF requires plans to meet housing requirements in full, and thus to show a clear strategy for meeting such needs.

The Modifications as proposed are unsound as they leave uncertainty as to how this additional housing is to be delivered, rather stating that any shortfall will be picked up through further DPDs or a Local Plan Review.

Housing requirements in Chichester are to increase significantly based on the new Local Housing Needs calculation, from the current 675 dpa (averaged) to 1,305dpa. If the Plan cannot predict delivery of even the current Plan's requirement there can be little confidence in how significantly increased housing needs can be met, or indeed when any Plan will emerge to address the issue.

Merrow Wood has control of two sites (Prospect Farm, Chidham and Hambrook, and Tawny Nurseries, Birdham, which are capable of delivering well over 100 dwellings in sustainable locations. It has never been clear why these sites have not been taken up by the Council to date, but now is the time to properly address delivery of the additional housing required by the Inspectors, by allocating these and other sites in THIS plan rather than waiting potentially years for a subsequent plan.

This has the additional benefit of creating a pipeline of sites which can roll forrward into any new Plan as a basis for a new housing requirement.

Merrow Wood considers it unfortunate that the effective housing requirement for Chidham and Hambrook has been delivered outside the Local Plan and Neighbourhood Plan processes - planning by appeal. Merrow Wood reiterates its comments on the Plan overall that certainty of delivery for housing needs is best achieved by allocating sites in sustainable locations. Creating uncertainty over delivery will only lead to further sites coming forward at appeal.

Merrow Wood does at least welcome the Modifications to Policy A12 in Chidham and Hambrook which allow fir consideration of addtional development sites should delivery of the appeal sites fail to come forward. It is also very likely that additional housing will be required in the area to meet the sigmificantly increased housing requirements created by the new Local Housing Needs calculations.