Planning Obligations and Affordable Housing SPD
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Planning Obligations and Affordable Housing SPD
Overview
Representation ID: 7194
Received: 20/03/2026
Respondent: Southern Planning Practice
Issues raised relate to timing of SPD in relation to timing of revised NPPF which may affect content,
and need for much greater flexibility to enable schemes to progress.
General – the NPPF is going through its own consultation process which may affect the provisions in this SPD therefore the timing of the SPD is questioned in advance of the publication of the revised NPPF.
The Council has clearly recognised, through its own Development Industry Questionnaire, that at a local level it is struggling to deliver housing at the rate and levels as required by central government. This is also a national problem, but at a local level the Council needs to be much more aware of the issues facing developers on bringing forward sites for development, including in terms of the time taken to secure permission and the effect on viability through the range of site specific as well as formulaic planning obligations imposed on all developments. The cumulative costs required by planning obligations renders many development schemes unattractive to proceed and, in some cases, unviable.
"Points noted. Concerning the NPPF consultation, we are aware this is running at the same time as the revision to the SPD, however the government has issued a deadline for SPD adoption which is not conducive to waiting to know the final outcomes of the NPPF consultation, and so we propose that these are more properly addressed through a future set of policies / guidance that will be prepared under the new plan-making system.
We remain keenly aware of the financial pressures on developments in the local area, and more widely across the country. The SPD sets out formal statutory guidance on how the infrastructure and affordable housing related policies of the Chichester Local Plan 2021-2039 will be applied. The Local Plan and consequently this document have been informed by robust viability evidence which indicates that, in general, developments should be viable. The document sets out, in accordance with national policy, mechanisms for sites with viability issues to receive a degree of clemency to ensure they are deliverable while providing appropriate mitigation against infrastructure impacts."
Object
Planning Obligations and Affordable Housing SPD
1. Introduction
Representation ID: 7195
Received: 20/03/2026
Respondent: Southern Planning Practice
1.1 Last sentence refers to the Council considering the cumulative impact of planning obligations on development when considering any planning application – this section needs to be expanded upon and the methodology for this requires to be explicit in this document. It should include reference to the recognition that there may be site specific costs identified within a proposal that may affect the extent to which the application can also contribute towards the full range of planning obligations.
1.1 Last sentence refers to the Council considering the cumulative impact of planning obligations on development when considering any planning application – this section needs to be expanded upon and the methodology for this requires to be explicit in this document. It should include reference to the recognition that there may be site specific costs identified within a proposal that may affect the extent to which the application can also contribute towards the full range of planning obligations.
Points noted, however these matters are outside the scope of the SPD, which provides guidance on the implementation of infrastructure policies in the Chichester Local Plan 2021-2039.
Comment
Planning Obligations and Affordable Housing SPD
3. Negotiating Planning Obligations in the Chichester Local Plan Area
Representation ID: 7196
Received: 20/03/2026
Respondent: Southern Planning Practice
Viability 3.6 onwards
The document refers to raising such matters at the pre-application stage, but in many instances viability issues only become clear during the application process and the text should be expanded to suggest that the issue should be discussed as soon as evident.
The text does not make clear the steps the Council will take on receiving a viability report and this should be made clear, so that the processes are clear and unambiguous.
Viability 3.6 onwards
The document refers to raising such matters at the pre-application stage, but in many instances viability issues only become clear during the application process and the text should be expanded to suggest that the issue should be discussed as soon as evident.
The text does not make clear the steps the Council will take on receiving a viability report and this should be made clear, so that the processes are clear and unambiguous.
Agree that it would be helpful to clarify that viability issues should be discussed at the time they are identified.
It is felt that the viability process falls outside the scope of this document, and that additional text to address this point would not be useful.
Object
Planning Obligations and Affordable Housing SPD
Mitigating the impact of development on the A27 Chichester Bypass
Representation ID: 7197
Received: 20/03/2026
Respondent: Southern Planning Practice
4.73 onwards
Under the 2024 SPD, certain forms of development were stated to be unlikely to attract contributions towards the A27 including care homes and extra care facilities. These have not been specified in the draft replacement SPD and replaced with a general statement that there may be cases where contributions are unlikely to be sought. These exclusions should be carried forward for the same reasons that they were excluded in the 2024 SPD and therefore they should be specifically set out in the replacement SPD; it would provide greater certainty for applicants.
4.73 onwards
Under the 2024 SPD, certain forms of development were stated to be unlikely to attract contributions towards the A27 including care homes and extra care facilities. These have not been specified in the draft replacement SPD and replaced with a general statement that there may be cases where contributions are unlikely to be sought. These exclusions should be carried forward for the same reasons that they were excluded in the 2024 SPD and therefore they should be specifically set out in the replacement SPD; it would provide greater certainty for applicants.
Agree that carrying forward the exclusions from the A27 SPD would provide useful additional clarification.
Object
Planning Obligations and Affordable Housing SPD
Education
Representation ID: 7198
Received: 20/03/2026
Respondent: Southern Planning Practice
Objection to the costs associated with providing educational facilities particularly where there is a policy requirement for an on site provision of a new educational facility under a site allocation policy.
Objection is raised to the excessive financial costs expected to be borne by developers towards the provision of education facilities, particularly where there is a policy requirement for an on site provision of a new educational facility under a site allocation policy. The requirement for land to be provided for a facility reduces the amount of land which can be developed for housing which is a major deterrent, but to require that the developer also designs and builds the facility or makes a contribution for the Council to build the facility is plainly unreasonable and needs to be reviewed. There are other available funding sources including, through planning, CIL as well as financial contributions collected from other developments in the local area.
Objection noted. The approach is a continuation and update of one taken in the 2016 SPD, and we do not expect developers to meet the full costs. The figures are provided as an indication of the likely costs of education infrastructure. Any financial contribution to be paid by a developer will be related in scale to the development that they are collected from, with care taken to ensure the development is viable.