The Local Plan - your questions answered

The following information was published in Spring 2023 to support the Regulation 19 consultation.

What is a Local Plan, why is it needed and what does it cover?

Is the Local Plan just about housing?

The Local Plan isn't only about building new homes. It has important roles to help protect the environment and support sustainable communities, creating an area that we can all be proud of and that meets local needs, now and for the future. Key objectives that the Plan addresses include:

Climate change - delivering mitigations and adaptations as part of our response to the climate emergency and our contribution to achieving net zero;
Natural environment - protecting natural resources and enhancing biodiversity;
Employment and the economy - supporting business and improving job opportunities;
Health and wellbeing - encouraging healthy lifestyles and reducing inequalities;
Design and heritage - protecting and enhancing the area's character;
Infrastructure provision - supporting sustainable transport networks and improvements to essential services and community facilities.

How do you identify what development is needed?

Housing need for the plan area is objectively assessed using standard Government methods to identify the amount of land required to deliver suitable homes. The calculation considers local population size and the affordability of homes. This assessment forms part of the evidence base from which the Local Plan is developed.

We know that new housing as well as business development depends on improvements to supporting infrastructure to ensure that the people living and working here can access essential services such as transport, health, education and utilities. We therefore work closely with partners and providers to identify key infrastructure requirements and to determine whether they can be delivered in time to support new development.

Why do we need more housing?

The plan area is an attractive place to live and work, drawing people to set up home here, plus our residents are living longer. This has led to a growing population, creating high demand for housing.

We know that young people are finding it difficult to rent or buy their first home. We want those who grow up here to have the option to stay - and so we need to make sure that there are new homes of the right type and tenure to enable them to do this.

There is limited Government funding available for affordable housing, which is why the Local Plan is so important, because it requires developers to deliver a proportion of affordable homes suitable for local families and young people. The Plan also recognises those with specific accommodation needs, such as older people, people with disabilities or those who require specialist support.

Where are you proposing to place new housing?

Our Local Plan spatial strategy is to focus new development in and around Chichester city, enhancing its role as the plan area's main centre and avoiding the most environmentally sensitive areas. Other development will be within key communities to the east and west of the city (the East-West corridor). This includes strategic development sites carried forward from the 2015 Local Plan at Tangmere, Shopwhyke, Westhampnett and West of Chichester. New strategic housing sites in this area include Highgrove Farm, Bosham (245 homes), East of Chichester (680), Maudlin Farm (265) and Southern Gateway (180).

An area for development has been identified at Southbourne for 1,050 homes. The detailed location of the development site, or sites, is not yet decided.

The plan does not include any strategic housing allocation on the Manhood Peninsula. This is in recognition of recent speculative development and the ongoing constraints that the area faces. It does allow for 50 homes at North Mundham.

Within the north of the plan area, the local plan recognises that need to conserve the rural character, high quality landscape and historic environment. As a result, a relatively small number of homes are proposed within Kirdford (50), Wisborough Green (75) and Plaistow and Ifold (25). Loxwood is the least constrained village in the north of the plan area, and benefits from the most services and facilities. It is therefore proposed that 220 homes are delivered in this location.

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

Yes. Since our Local Plan was adopted in July 2015, the Government has changed the way it calculates future housing needs, meaning that we are now expected to deliver more housing within our area. Our Government-required target is 638 homes each year from 2021 to 2039.

We have publicly stated that this target is not achievable within the plan area due to the complex issues and constraints we face. In fact, our Council Leader and Chief Executive, along with Gillian Keegan MP, have met Government officials and the Secretary of State to discuss this matter and to request that we are treated as an exceptional case. Unfortunately, our request was not agreed. The Government is, however, currently consulting on whether the standard method for assessment of local housing need should be an advisory starting point and not mandatory.

The intention of our proposed Local Plan is to demonstrate through robust evidence that a reduced number of homes of 575 delivered each year is the most that can be accommodated within the available and deliverable infrastructure, and in the context of other constraints. This evidence and justification will be submitted to the Planning Inspectorate for independent examination following the consultation.

What about the impact of development on the environment?

We are incredibly lucky to live and work in such a beautiful and biodiverse area with its multitude of special qualities, and we want to keep it that way. The Local Plan has a crucial role to play in balancing development needs with the protection of our environment, both locally and as part of the national and global climate objectives.

The Local Plan is focused on delivering sustainable development, where impacts on the environment are minimised. This includes enabling the building of energy and water efficient buildings, reducing reliance on private vehicles and achieving biodiversity net gain.

Our Plan ensures that development will be located and designed to avoid adverse impacts on protected sites (such as Chichester and Pagham Harbours, the Medmerry Compensatory Habitat and the Arun Valley), as well as introducing new initiatives to conserve and enhance strategic wildlife corridors that link the South Downs National Park to the coast. Significant impacts on important landscapes (including the Area of Outstanding Natural Beauty, the coast and the countryside) and heritage assets will be avoided or mitigated. Development will also be directed away from areas facing significant flood risk.

We know that the plan area is not unique in terms of having environmental constraints to development, but we consider that the combined presence of these environmental constraints, as well as issues of infrastructure limitations (such as the capacity of the A27), places uncommon restrictions on the amount of development that can be undertaken, which it what is evidenced within the Local Plan.

Is the Local Plan dependent on National Highways delivering their scheme for the A27?

No. Road congestion is a major issue affecting parts of the plan area but a previous national improvement proposal for the A27 Chichester Bypass was cancelled due to lack of consensus. More recent improvement schemes are not currently part of the Government's Road Investment Strategy and cannot, therefore, be relied upon as a future solution on which our Local Plan can depend.

In the absence of a Government-funded major scheme, we have been working with National Highways and West Sussex Country Council to identify a series of smaller scale improvements than can be implemented to support the Plan's proposals. These improvements form part of a 'monitor and manage' approach, which also includes enhancing walking and cycling routes, as well as public transport, bringing additional environmental and social benefits.

What about wastewater? Are the right facilities in place to accommodate additional housing?

In order to meet our proposed housing growth, we need to make sure there will be the necessary infrastructure to support the new development.

Water companies have a statutory duty to treat wastewater resulting from new development. We work closely with these companies, primarily Southern Water but also Portsmouth and Thames Water where relevant, to ensure new development is factored into their future plans.

Wastewater treatment capacity has long been a problem in the south of the district and timely upgrades to infrastructure are required to manage the increased wastewater from our proposed and planned development. We have been working proactively with Southern Water and the Environment Agency and have agreed a Statement of Common Ground (November 2021) which describes how all parties will work together to ensure that planned investment in and improvements to wastewater infrastructure matches need resulting from new development.

Is wastewater the main source of nitrate pollution affecting Chichester Harbour?

No, this is not the case.

Parts of Chichester Harbour, internationally-designated for its ecology and conservation importance, are assessed to be in an 'unfavourable - declining' condition as a result of a build-up of excess nutrients causing eutrophication (algal growth) harmful to wildlife. Relative to other sources of excess nutrients, such as run-off from surrounding farmland as a result of agriculture, wastewater from new development contributes a small amount of pollution.

It is important that pollution caused by wastewater, as well as other sources, is addressed to reduce harmful impacts and enable recovery of the Harbour. Policies within the proposed Local Plan seek to ensure that there is no net increase, and where possible a net reduction, in nutrients discharged to the Harbour by requiring relevant new development to be nutrient neutral. In addition, a nutrient budget has been prepared to demonstrate that there is sufficient mitigation available (for example through off-setting schemes) for the first 5 years of the plan period.

Our approach to nutrient neutrality has been developed with key partners including Southern Water, Natural England, the Environment Agency, and other authorities affected by the issue (including the Partnership for South Hampshire - PfSH).

What is meant by 'water neutrality'?

Natural England has advised us that the abstraction (removal) of water within the Sussex North Water Resource Zone is having a negative impact on the Arun Valley, an internationally protected habitat. To avoid further harm, new development within the zone (within the north of the Local Plan area) must not increase pressure on water resources.

Affected local authorities have worked closely with Natural England, the Environment Agency and Southern Water to produce a joint water neutrality study. The results of the study have informed the water neutrality policy which requires that all new development must be highly water efficient to contribute to achieving water neutrality, where total water use in the supply area after development is equal to or less than before. This may require developments to incorporate water saving fixtures, greywater recycling or rainwater harvesting measures.

Water efficiencies may not be sufficient to achieve water neutrality, so additional demand will need to be offset. A joint local authority-led offsetting scheme is being developed for this purpose.

I submitted a representation during the previous consultation. What has happened since?

In 2017, the council undertook a six-week consultation on an 'Issues and Options' document, seeking views on a series of matters to help develop the strategies and policies of the Local Plan. Sites or locations for new development were not proposed. 2,221 representations were received for our consideration.

Between 13 December 2018 and 7 February 2019 we conducted a further public consultation on our Local Plan: Preferred Approach, which included proposals to fully meet the identified housing and employment needs of the area. Just over 3,200 representations by 729 respondents were made.

Concerns were raised regarding high levels of housing development, and the impacts this would have on sensitive landscapes, wildlife corridors, traffic congestion, and the capacity of other infrastructure. In response, further technical work was undertaken to update evidence, focusing particularly on the complex constraints of transport and wastewater capacity. The Local Plan timetable was amended to enable detailed feasibility assessments and to explore alternative approaches to housing, in close consultation with key partners.

The proposed Submission Local Plan is derived from your previous representations and the technical assessments this prompted. It has also taken into account changes to national policy, bringing attention to improving the environment, mitigating and adapting to climate change, and the consideration of all sources of flooding.

If national policy changes again, will the Local Plan still matter?

A Government consultation on potential amendments to the National Planning Policy Framework (NPPF) was launched on 22 December 2022. Proposals include changes to Local Plan making requirements, assessments of housing need, and examination criteria.

In the absence of any certainty as to if and when the proposed NPPF changes will be implemented, it is important that we continue to progress our Local Plan at pace to ensure we in the best position to direct development at the appropriate scale and to the most appropriate locations, avoiding speculative development that could bring harmful impacts.

This public consultation is important as we are seeking views on whether our Local Plan is sound and legally compliant (in accordance with the current legislative and policy framework), prior to submission for examination at the earliest opportunity.

How can I find out more about the Local Plan?

We have created overview documents for the three key sections of the plan area to help provide a brief overview of the challenges facing the Local Plan, how we have addressed these, and the key points relating to each area. You can download these documents on our latest news page

For updates direct to your inbox, you can sign up to our regular Local Plan email newsletters.

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: