Chichester Local Plan Review update: 22 June 2021

We recognise that planning can sometimes seem incredibly complex and confusing. In this newsletter, we want to answer some of the most common questions people are asking about the Local Plan Review process and to correct some of the myths and misinformation surrounding this.

Q. Has the council challenged the housing targets set by the Government for the plan area?

A. Yes. Since our Local Plan was adopted in July 2015, the Government has changed the way it calculates future housing needs and this means that we are now expected to take more housing within our area.

Over the past couple of years, we have sent letters and been involved in meetings with Government officials to explain the complex issues we face in our area. In fact, only very recently our Council Leader and Chief Executive, along with Gillian Keegan MP, met with the Minister for Housing to discuss these issues and to request that we are treated as an exceptional case. Unfortunately, our request was not agreed. It was also made clear by the Minister that if we believe that the evidence we collect shows we cannot meet our full housing needs, then the Local Plan may be submitted for examination on that basis. However, the Inspector assessing our plan must have evidence that demonstrates, in planning terms, what can and cannot be achieved. This also needs to demonstrate that all available options have been considered.

This is what we are currently doing through the Local Plan Review. Our officers have been working hard to investigate how the targets might be achieved and to gather evidence - if our evidence shows that certain things are not possible, the Inspector will take this into consideration when reviewing the targets that we have been set by Government.

Q. Is the Government allocating our Local Plan area more than its fair share of housing?

A. When the Government calculates housing requirements for each area, affordability is considered as an important factor. Average pay and average house prices are compared, and each area is then given a ratio. Our area has one of the highest ratios outside of London, which explains why the housing allocation seems high.

As we mention above, the role of the Local Plan Review is to explore whether this allocation can be met, and if the evidence shows that this isn't possible, the Planning Inspector will consider this when reviewing our Local Plan and the Government's housing requirement may be reviewed.

Q. Is the Local Plan dependent on Highways England delivering their scheme on the A27?

A. No. In 2016, Highways England identified potential improvement works designed to improve traffic conditions on the A27 but the scheme was cancelled due to a lack of local support. Although we are working with Highways England and West Sussex County Council and the MP for Chichester to make the case for an A27 Chichester major scheme, it is not currently included in the Government's programme and cannot be relied upon. Therefore, we have been working with transport specialists and our partners, such as Highways England and West Sussex County Council, to carry out detailed assessments as to what smaller scale improvements could be made to meet the additional need from future housing growth.

This work has identified a series of improvements to the junctions on the A27 Chichester bypass and other improvements including a link road from the Fishbourne roundabout to the Manhood Peninsula. Our partners have agreed that the evidence points to this approach being needed in the absence of a Government funded major scheme. Further technical work is needed on these improvements to demonstrate that they are deliverable by understanding the costs and impacts - for example, on traffic and the environment. More information on this can be found in one of our previous newsletters, which you can read here: Chichester Local Plan Review update: 26 February 2021.

Q. What about waste water? Are the right facilities in place to accommodate additional housing?

A. In order to meet the Government's housing targets, we need to make sure that the right facilities are in place. Waste water has long been a problem in the South of the district and we have been lobbying Southern Water to explain to us what improvements are required for some time. Following an official complaint to the Water Services Regulation Authority, Ofwat, we have been holding constructive meetings with Southern Water and the Environment Agency, and Southern Water has agreed to work with us jointly on identifying improvements that need to be made.

Over the coming months, we will be working with them to ensure that their commitment to effective progress and engagement in waste water issues is achieved and that the required evidence work on waste water disposal is prepared.

Q. Is waste water the main source of nitrate pollution affecting Chichester Harbour?

A. No, this is not the case. Research has shown that waste water from treatment plants is responsible for only 10% of nitrogen entering Chichester Harbour. A much larger proportion (40%) runs off surrounding farmland as a result of agricultural production.

To help tackle this issue, Southern Water organised a water summit, involving representatives from the council and other local authorities, along with relevant agencies such as Natural England, the Environment Agency, Chichester Harbour Conservancy, Langstone Harbour Board and Sussex Wildlife Trust. The first meeting has taken place and was a positive step towards working together to help improve the harbour for future years to come.

Within the Local Plan Review, we are already committing to water efficiency standards and to achieving nitrogen neutrality in new homes. We are also participating in and supporting the Chichester Harbour Water Quality Group and Chichester Harbour Protection & Recovery of Nature group. The organisations participating in the summit all have a role to play and by working together we can make a difference over the long term.

Q. With no approved Local Plan, can developers build where and what they like?

A. We have robust measures in place to protect the plan area from inappropriate speculative development until the Local Plan Review is adopted.

Every planning application is considered carefully by the council. As part of this process, we consult with relevant organisations such as Southern Water, West Sussex County Council, the Environment Agency, Natural England and Highways England. If any of these organisations highlight significant problems which cannot be overcome, then an application would be refused.

In addition to this, we have introduced an Interim Housing Policy Statement. This is part of our rule book for planning applications and this considers other factors, such as the protection of strategic wildlife corridors and Environment Agency advice on flooding.

Q. Can't you also impose a moratorium on all new large housing developments?

A. Even if we wished to delay investment in homes and jobs, under law, developers have the right to submit planning applications which must be determined within agreed timescales. If not, they have a right of appeal to Planning Inspectors and we may even be found to have acted unreasonably, with applicants appeal costs awarded against us.

We're keen to reassure people that until the Local Plan Review can be adopted, the measures we've mentioned in the previous Q&A give us the best possible position to manage planning applications.

Q. Will you help ensure local people can buy and stay in the area?

A. There's a high demand for housing and we know that young people are finding it difficult to get on the property ladder as first time buyers or renters. We want those who grow up here to have the option to stay here - and so we need to make sure that there are homes of the right prices and type that will enable us to do this.

It's important to point out that there is limited Government funding available for affordable housing. This is why the Local Plan is so important, because it requires developers to deliver a proportion of affordable homes that are suitable for local families and young people who have a local connection. This means that our children and families can continue to live locally and that we can attract people to work here, in our hospitals, schools and other essential services.

The Government currently gives the council a financial bonus when new homes are built. As part of the council's New Homes Bonus (Parish Allocations) Scheme, the first £250,000 of this money is offered to Parish Councils to apply for funding to deliver local projects. This could include improvements to local facilities, such as community buildings or play areas.

In addition to this, Local Plan policies and the community infrastructure levy means that developers have to pay a financial contribution, or provide infrastructure, for every property they build. This money is already being invested in villages and towns that are taking new developments, with new schools, community facilities and roads planned as part of large schemes.

Q. What about the impact of house building on the environment?

A. We are incredibly lucky to live and work in such a beautiful and biodiverse area, and we want to keep it that way. The Local Plan has a crucial role to play in this and looks to identify areas that need to be protected, such as valued countryside, wildlife corridors, and open spaces.

We have also brought forward a policy to protect wildlife corridors, which is a new initiative for the Chichester Local Plan area. The plan also takes into account the impacts of climate change, including the importance of mitigating flood risk associated with new development. The National Planning Policy Framework puts a requirement on developers to consider the impacts of existing and future flood risk, from all sources including sea and rivers, for the lifetime of a development.

Q. Is the Local Plan all about housing?

A. Not at all. Planning affects where we live, work and relax; where new shops and community facilities are built; and it protects our historic buildings and the natural environment. The Local Plan addresses all of these issues and more, helping to make Chichester more resilient and create a fairer, healthier, safer and greener area. This is more important than ever in light of the Covid-19 pandemic and gives us the opportunity to create a better future for our residents and businesses.

Because the Local Plan covers such a wide variety of topics, we have created themes to help people better understand the work that the plan covers. These include: Health & Wellbeing; Local Community; Climate Change & Environment; Services & Facilities; Arts, Culture & Heritage; Getting around & Transport; Housing & Economy; and Education & Learning. In our last newsletter, we explained each of the themes and why these are important - if you missed it, you can read this here: Chichester Local Plan Review update: 20 May 2021.

Q. Does your Local Plan cover the whole of the Chichester District?

A. No — our plan only covers those areas in the district that do not fall within the South Downs National Park. There is a separate plan for the whole of the National Park and this is produced by the South Downs National Park Authority.

Q. Could you be doing more to complete the Local Plan Review quicker?

A. We want to reassure people that the Local Plan continues to be a top priority for the council and we are working incredibly hard to progress this as thoroughly and quickly as we possibly can. It's important to appreciate the huge challenge to assemble all of the evidence needed. To date, this adds up to 41 policy documents, including reports by Statutory Consultees on subjects as diverse as wastewater, flood risk, environmental issues, transport and climate change.

At a Full Council meeting in March of this year, councillors approved our revised timetable. They also agreed a motion that expressed their regret at the delay to the plan and asked residents to understand that this is due to the impossible timeline set by central Government and the complex challenges, constraints and delays we face as key parts of the process are largely within the control of other agencies, such as Southern Water, the Environment Agency, Natural England and Highways England.

Having an agreed timetable helps our local communities and partners to keep up-to-date on the process. It also provides timings to indicate when different pieces of work will be completed and when the findings will be published as documents on our website. You can find the timetable here: Timetable - Local Development Scheme and we will continue to keep you updated on the progress that is being made in future newsletters.

Find out more about the Local Plan Review

Don't forget that you can keep up to date on all of the work that's being done around the Local Plan Review, and view all of the evidence that has been prepared so far, by visiting:

Our previous newsletters have covered a range of topics, including: why we need a Local Plan; how long will the process take; the progress being made on key challenges such as waste water and the transport network; how to get involved in future consultations and have your say; and the wide range of topics the Local Plan covers. You can read all of our newsletters here: Sign up to the Local Plan Review email newsletter.

You can also follow us on our social media channels, where we will be publishing quick videos to explain more about the plan and the work that's being done:

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