The Chichester Society and the Local Plan This leaflet has been produced by officers of the Chichester Society to help its members understand the issues contained in the District Council’s Draft Local Plan. The Society will be submitting its response to the Plan and therefore wants to obtain its members’ opinions to help inform the response. On the back page you will see a series of questions to which we would welcome your answers. Please reply by 24 April. Accompanying this leaflet is an illustrated booklet. The purpose of the booklet is twofold. Firstly to celebrate the 40th anniversary of the Society and secondly to celebrate what makes Chichester so special and worth protecting. We hope you will enjoy the booklet and appreciate its content in the context of any comments you may have on the Draft Local Plan. Richard Childs, Chairman
A BRIEFING FOR MEMBERS ON THE LOCAL PLAN Your Executive Committee would like your feedback on issues raised by the Draft Local Plan, now published for consultation. This can guide the Society’s responses to the current consultation, so please let us know what you think by 24 April. The Draft Plan runs to some 216 pages. This summary of three pages is probably as much as most people will want to read, but inevitably the amount of compression will lead to some oversimplification. To read the original plan, go to http://www.chichester.gov.uk/newlocalplan . This site also contains details of how you can express your views to the Council, in their case by May 3rd. If the CDC consultation does not let you express yourself fully, you may also write to your local councillor or MP. For members who prefer paper, the full Local Plan can be viewed at the CDC offices at East Pallant House or at local libraries. (CDC also have copies for sale at £15.)
What happens if we just tell the Government to go away? There is now case law on this subject, from Tewkesbury. There the council had no local plan (not even, as in the case of Chichester, a stopgap document stating what is currently appropriate – see ‘FAD’ in the June 2012 Newsletter) and refused permission for a development of 1,000 homes. The developers appealed, and won both the first appeal, to the Planning Inspectorate, and then a second one, to the High Court. It was held that Tewkesbury was at fault for having neither an up-to-date plan, nor any way of showing that housing needs for the next five years could be met. Tewkesbury will now get 1,000 homes in a site chosen by developers, not local people. Chichester is in a similar position, and if it were not for lack of sewage disposal facilities, would probably also be involved in similar legal challenges. Doesn’t ‘localism’ let us choose the number of houses to be built?
Why bother with a Local Plan? Basically, because the Government requires every Local Authority to produce such a plan, covering development in their area to 2029, i.e.15 years of the plan plus the two current years 2013-14. This is not simply for planning more housing, but also for employment, infrastructure, transport and other related issues. Such a plan MUST contain a five-year supply of deliverable housing.
Er – not really! The presumption in law of ‘sustainable development’ trumps any local feeling in favour of setting the number of houses to be built at zero. Councils are required to provide a five-year supply of housing and employment opportunities, and to produce evidence for whatever scale of development is decided on. Here again there is case law. Winchester decided that a development of 2,000 houses should not take
CELEBRATING THE CHICHESTER SOCIETY’S 40th BIRTHDAY 1973-2013
place to the north-west of the city, at Barton Farm, on grounds of poor infrastructure. On appeal, the Communities Secretary, Eric Pickles, intervened to approve the development on the grounds that such evidence as was available indicated that there was compelling need for more houses in the area. “The National Planning Policy Framework (NPPF) states that local planning authorities should prepare new Local Plans on the basis that objectively assessed development needs (both for housing and other types of development) should be met, unless the adverse impacts of doing so would significantly and demonstrably outweigh the benefits when assessed against the document as a whole. The starting point is that Local Plans should meet the full requirements for market and affordable housing in their housing market area” [from Planning magazine] How many new homes does the Local Plan propose for Chichester District? 395 per year for the next 17 years or 6,715 in total. These have to be fitted in to the Coastal Plain, or in the extreme north of the area, as the South Downs National Park (SDNP) is responsible for its own planning strategy. For comparison, there are 41,000 homes in the CDC area outside the SDNP, including the 10,800 close to Chichester in the area which relates to the City Council. 6,700 new homes! You must be joking! Not at all. This figure is the result of a study carried out for CDC and updated in 2012. It takes into account net migration into the area – mainly people who wish to retire here – and housing needed to meet the current trends in economic growth, which are assumed to continue. The figure of 395 per annum is considered to be the smallest that could be justified. That’s a very broad-brush approach. What about some detail on the figures? There’s obviously a lot of debate going on here, judging by the variation in estimates. The most recent study is the Strategic Housing Market Assessment (SHMA), updated 2012 by consultants GL Hearn. This is currently being further modified by a ‘Duty to co-operate’ (DTC) study mounted jointly by the various West Sussex coastal councils. The following figures are what the Government might consider to be a suitable ‘evidence base’ for the plan.
Proposed numbers of dwellings per year needed in Chichester District, excluding the SDNP: More than 600 515 (upper limit) 450 (upper limit) 422 400 (lower limit) 375 (lower limit) 363 350 292
Experian study 2012 DTC 2013 provisional A study for CDC 2011 SHMA (5 yr growth basis) A study for CDC 2011 DTC 2013 provisional SHMA (10 yr growth basis) Average 10 yr completions SHMA (no growth)
The ‘5/10 yr growth basis’ assumes that local economic growth continues at the same rate as it has for the last 5/10 years. It is also estimated that 270 affordable homes are needed each year. At the proposed CDC target of 30% affordable housing in major developments, meeting this target would need 900 new homes per year, more than any of the above. Wouldn’t it be better to go for the actual housing completion rate, rather than some consultant guesswork? Or even, taking a pessimistic view, zero employment growth? There might be something in that. 292 rather than 395 homes per year is 1,751 homes less over 17 years, rather more than the number proposed on either of the big two sites (Whitehouse Farm and Tangmere, see below). Certainly there’s a case for releasing land in stages, rather than despoiling a whole area which might never be needed. But if the target is set too low, the whole plan stands in danger of getting rejected when submitted to the Government for approval – and all recent Governments have wanted to promote prosperity by means of economic growth. Where are all these homes going? Existing planning permissions account for nearly 2,000 homes (much of this at Graylingwell and Roussillon Barracks), and a further 1,400 expected on small sites both in Chichester and surrounding villages. Even though the latter are not all established, the total comfortably exceeds the number needed in the next five years, which is the earliest that major developments could start, owing to other constraints (below).
CELEBRATING THE CHICHESTER SOCIETY’S 40th BIRTHDAY 1973-2013
Don’t be coy! It’s Whitehouse Farm! No, it’s not only there. ‘Suitable’ major sites for development have to be planned for and settled now. The following are the major strategic sites listed, in alphabetical order:. Oldplace Farm: (‘Westhampnett’ in the draft plan) 500 homes from Barnfield up towards Fordwater and the western edge of Goodwood airfield Shopwyke Lakes: 500 homes on the derelict industrial site formerly occupied by Tarmac, just across the A27 at Portfield. Your Executive Committee thinks this is a good use of brownfield land, provided that suitable means of crossing the A27 are installed Southbourne: 300 homes Tangmere: 1,000 homes to the west of the existing village, with access to the A27 at the junction of the Petworth Road, A285. Very little of this development, if any, is planned for the brownfield area of the old aerodrome, and apart from access to the A27, the reason for this needs to be made clear. Whitehouse Farm: (‘West of Chichester’ in the draft plan) 1,000 homes (but with a hint that this could become 1,600 after the end of the current plan in 2029), west of Centurion Way, and from Clay Lane north to Old Broyle Road and then towards Brandy Hole Copse. This is a total of 3,300 homes, which with the 3,400 referred to on the previous page comes to the 6,700 suggested as a 17-year total. The few hundred homes planned for the Manhood area are not included above and there seems to be little reason to go ahead there unless Manhood infrastructure is much improved. I’d heard there was a problem about getting rid of sewage? Yes, and other constraints too. The lack of wastewater treatment capacity (to give it a dignified name) is what has stopped Chichester going the way of Tewkesbury and Winchester. Your committee would expect the Local Plan to specify the necessity for firm and costed measures to deal with the following problems to be in place before development starts. Current legislation can require developers to mitigate problems created by development, but not to remedy existing ones.
Wastewater treatment: Apuldram has very little spare capacity, perhaps enough to accommodate existing development, and cannot be economically extended. Tangmere has some spare capacity which could accommodate Shopwyke Lakes, but no more until it is upgraded. The earliest this could be achieved is 2019, and even that requires a goahead from OFWAT in the near future. Any extension would be designed to cope with proposed developments. Waste from Whitehouse Farm would have to be piped to Tangmere works. We think that both capital and running costs of this and similar extra infrastructure should be a charge on the developer (or running costs compounded for a capital sum). Traffic: Experience at Graylingwell shows how difficult it is to get people to abandon their cars, yet the draft plan is full of hope that this will happen. We would expect good direct road links from any development to the A27, paid for by the developer, and not for any site to rely on putting more traffic down existing roads running through an already congested city. The draft plan also contains statements about significant improvements to the A27; we would expect these to be explicit in the final version and tied to the release of adjacent land for development. Firm plans are also needed for local road improvements e.g. Old Broyle Road, for Whitehouse Farm or Madgwick Lane for Oldplace Farm. Parking. The ‘do nothing’ and ‘do minimum’ options for car parking in the city, outlined in the document given at the start, are never going to cope with the additional demand, extra buses or no extra buses. See www.chichester.gov.uk/index.cfm?articleid=4 528 . Identifiable sites for a Park-and-ride service must be included in the local plan. Public Transport and cyclists. Again bus links and cycle ways are proposed but not related explicitly to development areas. Such cycle ways, to be successful, must be free of motor traffic. The idea that the major exit from Whitehouse Farm should debouch via land taken from Bishop Luffa School on to a National Cycleway, and a route to the city centre which has been ‘traffic-calmed’ must be questioned.
CELEBRATING THE CHICHESTER SOCIETY’S 40th BIRTHDAY 1973-2013
Local employment and community facilities. These are mentioned but must be enforced in detail, else there will be yet higher demand for travel into a congested City. Wildlife corridors and open spaces These are mentioned but also need underlining. There are, additionally issues with the SDNP and Chichester Harbour AONB, in terms of pollution, interference with wildlife and appearance of large new housing estates.
Education. Primary schools can and should be incorporated into new developments, but infrastructure money and land should also be forthcoming from developers for new or extended secondary schools under the Community Infrastructure Levy. We have not yet found this mentioned in the 216 pages!
YOUR RESPONSE We don’t want to be prescriptive about what you want to say, but these headings may help you to focus. 1. How many new homes do you think should be built each year across Chichester District as a whole? Why do you pick this figure? Bear in mind the national legislation on this subject. 2. Should the amount of affordable housing (for rent or purchase), which is planned to comprise 30 percent of new developments, be maintained increased to the current level of 40%, or reduced? 3. Do you think that some land should be made available for development from each site as demand builds up? Or is it better to develop just one or two sites at a time? If you favour the latter, which of the strategic sites described in this leaflet would you prioritise for development and why? 4. We identified a number of constraints in this leaflet. From local knowledge, are any of these constraints of special importance, generally or in relation to a particular site? What have we have missed? 5. Are any infrastructure improvements (besides, obviously, sewage disposal) so important that no development should take place until the improvement is complete? Should CDC press for a proportion of ongoing costs as well as capital costs (e.g. in pumping sewage all the way to Tangmere)? 6. Besides the necessary expenditure needed to overcome constraints, what facilities do you want to see provided in any or all of the strategic sites? What features of Chichester should never be sacrificed? 7. What other points would you like the Chichester Society to make in its formal response to the District Council’s consultation on the draft Local Plan?
DEADLINES The Chichester Society Committee needs your responses back in time for us to compose a formal reply to CDC. Apologies for a tight timescale, but that means by April 24th; by post to ‘ChiSoc on the Local Plan’, 11 North Walls, Chichester PO19 1DA or by email to david@northwalls.demon.co.uk headed Local Plan. If at all possible, also reply to the Council directly by May 3rd (see page 1). Only in that way will your individual views be taken into account. The Planning Inspectorate, who has to approve the Local Plan, can only take into account direct submissions. Newspaper polls are thus unfortunately excluded. You may also want to make your views on local issues known to your local councillor, who can be found by entering your postcode on www.chichester.gov.uk , or by asking at East Pallant House 785166. Points about national policy should be made to Andrew Tyrie M.P., by post to the House of Commons, London SW1A 0AA or by email to http://www.andrewtyrie.com/content/contact-us.
CELEBRATING THE CHICHESTER SOCIETY’S 40th BIRTHDAY 1973-2013