Councillors at Chichester District Council heard that the Chichester Local Plan is unlikely to meet the full housing targets set by the Government due to a lack of external funding for infrastructure improvements, at a special meeting on Thursday 29 July.
This follows extensive work and research carried out by the council which shows that improvements to the A27 Chichester Bypass, including the Stockbridge Link Road, are required in order to attempt to meet the Government’s housing targets.
Following discussions with those who fund local infrastructure, including West Sussex County Council – as the Highway Authority, Highways England and Homes England, the council has concluded that the additional costs of the scheme after developer contributions were removed could not be met. Other funding options were also explored, including discussions with Coast 2 Capital Local Enterprise Partnership, but the funds required were not available.
“It’s important to explain that the work we have carried out so far is vital in demonstrating the complex situation we are in. We’ve always said that the roads and waste water were the biggest challenges facing the plan. However, we have to show that we have investigated all options and solutions before the Government will consider reducing our housing target. No stone can be left unturned,” says Cllr Susan Taylor, Deputy Leader and Cabinet Member for Planning at Chichester District Council.
“The most recent estimated cost for delivering improvements to the A27 Bypass, which would be required to deliver the level of housing we are expected to take, would be around £65 million. As things stand, we may be able to secure £33-£45 million of this from developer contributions, and so the remainder would have to come from external infrastructure providers. Following discussions with all partners involved, there just isn’t the money available to cover this funding gap. It’s also worth explaining that this isn’t the long-awaited national road scheme on the A27, these changes would just deal with additional traffic from the new development.
“What is difficult for people to understand is that while we may be delivering the Local Plan – many elements of it, mainly roads and waste water, are totally out of our control. This is what makes this process so challenging. The Local Plan is a bit like a jigsaw, you have to make sure that all of the pieces fit.”
Susan adds: “It’s also easy for people to say, we told you that the housing numbers couldn’t and shouldn’t be delivered, but this isn’t how the planning system works. The Planning Inspector needs to see that you have investigated every single option and that you have the evidence to back this up. Just to give you an idea – our officers have already produced 41 different policy documents. They have been working flat out to try and move this forward – and it has continued to be a top priority for us, even though we have also been responding to the pandemic. We need to go through this process and gather the evidence in order to get the best outcome for our residents and businesses and keep planning decisions locally.
“We’ve spoken to the Planning Inspector who has said that before concluding that housing needs cannot be met, we need to determine what level of housing could be achieved based on improvements to the A27; considering whether full housing needs could be met another way, which would include looking back at other parts of the local plan area; and investigating if the housing needs could be met by neighbouring authorities. While the inspector did not rule out us proceeding with a lower level of development in the emerging local plan, he did emphasise the ‘high bar’ in terms of justifying such an approach.
“Moving forward we will follow the steps that the Planning Inspector has outlined, so that we are in a strong position to make our case when the plan is submitted. Within this, we will outline that we intend to review the plan again if a national road scheme for the A27 Chichester Bypass is brought forward. We intend to keep residents and businesses fully informed throughout this process, and will let them know as soon as we are ready to consult with them.”
Over the past couple of years, the leader of the council and council officials have sent letters and been involved in meetings with Government officials to explain the complex issues affecting the Chichester plan area. Recently, the Council Leader and Chief Executive, along with Gillian Keegan MP and Andrew Griffith MP, met with the Minister for Housing to discuss these issues and to request that the area is treated as an exceptional case. Unfortunately, the request was not agreed. It was also made clear by the Minister that if the council believes that the evidence collected shows the area cannot meet its full housing needs then the Local Plan may be submitted for examination on that basis. Over this period the council has also involved the Government’s Planning Advisory Service and has been highlighting concerns to the Planning Inspectorate.
“We understand that local people are concerned and we want to reassure people that we have robust measures in place to protect the plan area from inappropriate speculative development until the Local Plan Review is adopted,” says Susan.
“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.
“In response to people calling for a moratorium - 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,” says Susan.
“The council must also be able to substantiate any grounds for refusal of permission, with consultee support where relevant at any subsequent appeal. At this stage, relevant consultees have not requested a moratorium in respect of either transport or wastewater issues and so this is not an approach that would be held reasonable or defensible.
“We want to reassure people that we have measures in place to protect the plan area until the Local Review can be adopted.”
Discussions are also ongoing with Southern Water, which is responsible for wastewater, and the Environment Agency, which is responsible for enforcing the discharges into the harbour from premises that require permits, such as the wastewater treatment plants. While an engineering solution can be found to accommodate future growth, environmental limitations are a constraint, particularly in the western part of the plan area. Both organisations have not reached an agreed position, although work on a Statement of Common Ground is being progressed. Other options are possibly available, but there is still considerable concern around this important issue. Infrastructure options are being examined by Southern Water over the next year, but these will not be confirmed until 2023. All of these discussions and work will form part of the evidence to highlight the challenges faced by the plan area.
Residents are encouraged to sign up to the council’s regular email newsletter which focuses on the Local Plan. This can be done at www.chichester.gov.uk/localplannewsletter