The papers relevant to this item which will be considered by the Cabinet on Tuesday 6 March 2018 immediately prior to this meeting are the Cabinet agenda report and its appendix (pages 27 to 32).
It is anticipated that the following recommendation will be made by the Cabinet to the Council:
RECOMMENDATION TO THE COUNCIL
That, subject to the completion of the ongoing evidence-based work and the assessment of sites to meet the identified housing needs associated with the Local Plan Review, Chichester District Council will assess the ability to meet some or all of the unmet housing needs of approximately 44 dwellings per annum arising from the part of the South Downs National Park within Chichester District via the Chichester Local Plan Review.
Minutes:
The Council considered the recommendation made to it by the Cabinet at its meeting earlier in the day on Tuesday 6 March 2018, as set out in the Cabinet report and its appendix (pages 27 to 32 of the Cabinet agenda).
Mrs Taylor (Cabinet Member for Planning Services) formally moved the Cabinet’s recommendation and this was seconded by Mrs Lintill (Deputy Leader of the Council and Cabinet Member for Community Services).
Mrs Taylor presented the Cabinet’s recommendation. It was a pre-requisite for CDC’s Local Plan Review (LPR) to be found sound that the duty to co-operate (DTC) obligations had been fulfilled and a statement of common ground (SCG) agreed with its neighbouring authorities. The South Downs National Park Authority (SDNPA), which would shortly be submitting its local plan for examination, had now asked CDC whether it could take some or all of its unmet housing need within Chichester District. Whereas the Chichester Local Plan (CLP) had to be development -led, the SDNPA’s local plan was landscape-led and this meant that the SDNPA did not have to meet its full housing need within the South Downs National Park (SDNP) and under the DTC it could request adjacent authorities to provide for the unmet need. When CDC’s CLP was being examined, it was anticipated that the supply of new housing within the Chichester District part of the SDNP would be approximately 70 dpa. However, under the SDNPA’s draft local plan the proposed supply was 81 dpa which gave rise to an objectively assessed need (OAN) housing shortfall in the Chichester part of the SDNP of approximately 44 dpa. The appended SDNPA letter set out why the SDNP could not meet its full OAN given the landscape protection accompanying national park status. The SDNPA’s request was considered by CDC’s Development Plan and Infrastructure Panel (DPIP) on Thursday 1 March 2018 and concerns were raised that (a) whilst the SDNPA had previously made CDC aware that it would not be able to meet its shortfall, it had only made a formal request to CDC to meet its unmet need after the end of the consultation period and (b) in not meeting its OAN within the SDNP, this could result in sustainability issues in the SDNP villages within Chichester District. As to (b), although CDC was not the local planning authority for the SDNP area within Chichester District, it was nevertheless responsible for supplying other services within the SDNP such as housing and insufficient new housing in the villages could make them unsustainable as well as having an unbalanced demographic. Accordingly, the DPIP had recommended a revision of the recommendation which was before it (and this was set out in the Cabinet report), namely that any decision regarding the SDNPA’s request should be subject to the evidence-based work associated with the Chichester LPR and the assessment of sites to meet the identified housing needs. The DPIP was cognisant of the DTC to make the LPR sound but that recognition should be balanced with the need to ensure that the SDNP villages in the Chichester District area should remain viable.
With regard to the South Downs National Park Authority’s (SDNPA) request that CDC consider assessing its ability to meet some or all of the SDNPA’s unmet housing need, Mr Frost referred members (who had previously been e-mailed in this regard) to the Consultation on South Downs Local Plan Pre-Submission report which had been considered by the Cabinet on Tuesday 7 November 2017 and in particular paras 6.8 and 6.9 and appendix 2. That report had identified a shortfall in the SDNPA’s housing provision against the objectively assessed housing need for the Chichester District part of the SDNP but at that time the SDNPA had not requested CDC to consider meeting its unmet need and had only done so at a very late stage in its local plan process. It should be borne in mind that the SDNP faced different constraints from those affecting the CLP area. The DTC required CDC for the sake of its own LPR to consider carefully how to respond now to the SDNPA’s request.
Mrs Taylor and Mr Dignum said that the issue of the unmet need and the points made by members during the debate would be addressed in a forthcoming meeting between the SDNPA’s and CDC’s respective chief executives and leaders. This had to be resolved in order that CDC could sign in due course a SCG. Members were asked to e-mail Mr Dignum the points they wished him to raise at that meeting.
During the debate members asked questions and made comments on points of detail and where appropriate received responses from Mrs Taylor, Mr Frost and Mr Dignum. Among the matters covered were: (a) the unexplained and unacceptably late request by the SDNPA that CDC meet its unmet housing need within the Chichester District area of the SDNP; (b) the SDNPA did not appear to have explored sufficiently the scope for providing additional housing within the SDNP and it should be willing to share the burden of this; (c) it was incumbent on CDC notwithstanding the DTC to assess very carefully its ability to accept all or any part of the unmet housing need; (d) CDC should not enter into discussions with the SDNPA with its hands tied as it were to any particular number of houses per year, whether it was 44 (as cited by the SDNPA in its letter) or any other figure; (e) there should be an opportunity within the SDNP for additional affordable housing (which was clearly needed for local people rather than those who were retiring from, say, London) to be provided within parishes via neighbourhood development plans and there was need for such development, together with developing employment including micro-economy options within the SDNP, to be sustainable community-led rather than landscape-led; and (f) CDC should adopt a robust and proactive approach to DTC negotiations with the SDNPA over the unmet housing need (for which there needed to be clear evidence), which should include a timeframe for a resolution.
The following question was submitted by e-mail in advance of the meeting by Mr Ransley and received an oral response by Mrs Taylor during the debate on this item:
Question
‘Can the [Cabinet Member for Planning Services] assure the Council that [(1)] the provision of 667 units made in the [South Downs National Park Authority’s] Local Plan for the SDNP area part of the Chichester District is proportional to the allocation for other districts in the SDNP? and [(2)] that by accepting the unmet SDLP housing numbers of 44 units per annum this Council is not agreeing to a higher proportion compared with the other district council areas in the SDNP?’
Response
‘The Council and all members have had the opportunity to respond to consultation on the draft South Downs Local Plan as part of the formal consultation in November 2017. This included reference to proposed housing provision across the National Park. No additional sites were put forward by this Council for development within the National Park. Officers have not carried out a detailed analysis of the provision to be made in other districts, but it is believed that a consistent approach to development within the South Downs local plan area has been adopted.
Given the landscape-led approach to the SDNPA Local Plan and the availability of suitable land within the National Park, a detailed analysis of the proportions being allocated to each district in relation to housing needs is unlikely to help inform any Chichester District Council view of the plan. For example the presence of sites such as Syngenta and Shoreham Cement Works might lead to more development within certain parts of the National Park than would otherwise be the case. The SDNPA has advised officers that for the other districts within the National Park statements of common ground are being progressed with the other councils which will address the scope for meeting the unmet needs within these areas in the same way as is being requested of this Council.’
Mr Dignum said that although it had always been obvious that the housing figure of approximately 70 dwellings per year (dpa) for the SDNPA area within Chichester District was well short of the OAN, it had never been made clear that CDC would be expected to meet the unmet need of 44 dpa ie the difference between OAN figure of 125 dpa and the 81 dpa the SDNPA would provide. CDC was also well aware that the SDNPA was not required, unlike CDC, to have a local plan target figure. Accordingly CDC had seen no reason to object to the SDNPA’s draft local plan on that basis and had looked and hoped for a parish-led approach (which was still available). He read from a written response he had received from the Planning Portfolio Holder at East Hampshire District Council (EHDC) which took issue with (a) the SDNPA’s use of the landscape-led criterion as a tool to avoid meeting its housing number allocation, (b) the assumption that adjacent local planning authorities (LPAs) would meet unmet housing need and (c) the consequence that extra unnecessary pressure was unhelpfully being put on those LPAs such as CDC.
Mrs Tull proposed an amendment to the Cabinet’s recommendation made earlier in the day whereby on the face of the agenda (a) the word ‘the’ be replaced with the word ‘its’ in the third line and (b) the words in the fourth line ‘of approximately 44 dwellings per annum’ should be deleted. Her proposal was seconded by Mr Moss.
Mr Martin said that he was minded to propose that CDC should assess its ability to meet some, if any, of the SDNPA’s unmet housing need. His proposal was seconded by Mr Budge.
In the light of Mrs Tull’s prior proposal Mr Martin withdrew his proposal.
At the end of the debate the Council voted on Mrs Tull’s proposal.
Decision
On a show of hands the members present voted in favour of Mrs Tull’s proposal to amend the Cabinet’s recommendation, with three votes against and one abstention. It was, therefore, carried.
RESOLVED
That, subject to the completion of the ongoing evidence-based work and the assessment of sites to meet the identified housing needs associated with the Local Plan Review, Chichester District Council will assess its ability to meet some or all of the unmet housing needs arising from the part of the South Downs National Park within Chichester District via the Chichester Local Plan Review.