Authority Monitoring Report 23-24

Introduction

1.1 The Arun District Council Local Development Scheme (LDS)^[1] was updated in January 2023 and adopted by the council on 8 November 2023. In accordance with the Planning and Compulsory Purchase Act, 2004, the LDS specifies the local development documents which are to be development plan documents as follows:

• The Arun Local Plan 2018;
• 'Made' Neighbourhood Development Plans (addressed in Chapter 3);
• The West Sussex Joint Minerals Local Plan, 2018 and the West Sussex Waste Local Plan, 2014, the preparation and update of which are the remit of West Sussex County Council (WSCC) and as such, are not the responsibility of Arun District Council; and
• The South Marine Plan^[2].

1.2 The LDS acknowledges the emerging Gypsy and Traveller Development Plan Document 2018 - 2031 (G&TDPD), confirms the lifting of the pause to the ALP update (by Full Council resolution on 19 July 2023) and sets out the plan making timetables for both. It addresses recently adopted Supplementary Planning Documents (SPDs) and the council's Infrastructure Funding Statement (IFS).  

1.3 The LDS refers to Arun's declaration of a Climate Change Emergency in January 2020, and the aspiration to become carbon neutral by 2030, with the help of other stakeholders. The aspiration included the need for the council to seek a significant uplift in the adopted plan's Development Management policies (i.e., sustainable design, carbon reduction, decentralised/green energy and efficiency, climate change mitigation and adaptation). Performance on these matters will be addressed in the AMR as plan making progresses. 

1.4 The following paragraphs summarise performance of the development plan documents that are the responsibility of Arun District Council, and progress on the preparation and update of the documents set out above and covered in the LDS. This includes the stage the documents have reached in their preparation and whether this is meeting the timetable within the LDS.

Development Plan Documents

Arun Local Plan 2018 

1.5 The AMR monitors the existing Arun Local Plan 2011 - 2031 (adopted by Full Council on 18 July 2018) and plan making performance, including that of housing land supply and delivery, and commercial land delivery. 

1.6 The assessment of housing delivery is supported and informed by the Government's Housing Delivery Test (HDT), which is an annual measurement of housing delivery. Arun has not achieved the thresholds of housing delivery performance required by the HDT published for 2018, 2019, 2020, 2021, 2022 and 2023, and does not have a 5-year housing land supply (5YHLS). This performance, together with the fact that the ALP is 5 years old (July 2023), informed the council's resolution on 19 July 2023 to lift the pause to work on the Local Plan update, and to amend the Plan period to 2023 - 2041.

Arun Local Plan Update 2023 - 2041

1.7 As part of the ALP update, a number of evidence studies have been commissioned including: 

• The Arun Active Travel Study Phase 1 (June 2021); 
• The Arun Tourism and Visitor Accommodation Study (May 2022);
• An Arun Biodiversity Net Gain Study (November 2022); 
• The Arun Housing Market Absorption Study (December 2022); 
• The Arun Housing Need Review (May 2023); and 
• A Sustainability Appraisal / Strategic Environmental Assessment (SA/SEA) (June 2023). 

In addition, work was commissioned and completed on the Arun Transport Model Phase 1 Local Model Validation Report (to upgrade the Arun A259 Transport Model to a district-wide model) with West Sussex County Council (WSCC). 

1.8 During this AMR period, work commenced on the ALP update, with a Direction of Travel Document produced as the council's method of undertaking an Issues and Options consultation under Regulation 18 (Part 1) of the Town and Country Planning (Local Planning) (England) Regulations 2012. In keeping with the timetable in the LDS, consultation on the Direction of Travel Document took place between 25 March and 13 May 2024. 

Gypsy and Traveller Development Plan Document 2018 - 2031

1.9 The ALP sets out the policy and evidence requirement for preparing a separate G&TDPD which should be in accordance with the requirements of the revised Planning Policy for Traveller Sites (PPTS) published in August 2015. The G&TDPD is a Local Plan looking only at G&T needs and provision and would form part of the statutory development plan for Arun when adopted. 

1.10 The preparation timetable of the G&TDPD is set out within the LDS. A Regulation 18 (Part 1) Issues and Options consultation took place in the summer of 2019, in line with the LDS timetable. A Regulation 18 (Part 2) Draft G&TDPD 'Preferred Options' consultation (6 weeks) was completed in the summer of 2020, 'ahead' of the winter 2020 timetable. A Regulation 19 (Publication stage) G&TDPD consultation on legal and soundness (timetabled for summer 2023) took place between 13 December 2023 and 7 February 2024.

1.11 On 19 December 2023, the Government announced a change to the definition of traveller households, to include traveller households that had ceased to travel permanently. This change significantly increased the requirement for Arun and the council accordingly sought advice from the Planning Inspectorate. Advice received on 16 April 2024 was that the level of under provision was a potentially serious shortcoming of the G&TDPD. The council's Planning Policy Committee consequently resolved to withdraw the G&TDPD on 6 June 2024.

Infrastructure Funding Statement

1.12 The ALP and the Infrastructure Capacity Study Delivery Plan 2017^[3] (IDP) identify what infrastructure is needed within Arun District over the lifetime of the ALP, when it will be provided, how much it will cost and how it will be funded (e.g., through S.106 monies from Strategic Allocations and proposed Community Infrastructure Levy (CIL) funding for other off-site infrastructure).

1.13 On 1 April 2020, Arun became a CIL Charging Authority and published a CIL Charging Schedule^[4]. In line with the Community Infrastructure Level Regulations 2010 (as amended), Arun prepares an annual Infrastructure Funding Statement (IFS) comprising:

• A CIL report relating to the previous financial year;
• A Section 106 report relating to the previous financial year; and
• An infrastructure list reporting on the infrastructure projects or types of infrastructure that the council intends to fund wholly or partly by the CIL (excluding the neighbourhood portion).

1.14 The latest IFS for Arun covers the period 1 April 2023 - 31 March 2024 (Chapter 8).

Supplementary Planning Documents

1.15 Under the Planning Act 2008, there is no requirement for SPDs or other supporting documents to be included within the LDS and assessed against the LDS plan making timetable. However, where SPD are prepared and adopted following public consultation, they are a material consideration for development management decisions and are accordingly included in the LDS. 

1.16 The LDS refers to Arun's Statement of Community Involvement (SCI) which sets out the council's process for undertaking consultation on planning policy documents and as part of the development management process. The SCI was reviewed in 2023 and at its meeting of 21 September 2023, the Planning Policy Committee approved the draft SCI for public consultation from 28 September to 26 October 2023. The SCI[1] was consequently updated and adopted by Full Council on 10 January 2024, in line with the timing stated in the LDS.

1.17 During the AMR reporting period, the Arun District Design Guide^[6] was updated to provide clarity on highways and junction design. Following consultation on the proposed updates between 4 December 2023 and 12 January 2024, the revised SPD was adopted by the council on 20 February 2024.

 
[1] Arun District Council Local Development Scheme 2023-2025
[2] South Marine Plan
[3] Arun District Council Infrastructure Capacity Study Delivery Plan 2017
[4] Arun District Council CIL Charging Schedule 2020
[5] Statement of Community Involvement 2023
[6] Arun District Design Guide Update 2024

Introduction

2.1 The Localism Act 2011 introduced a new tier of plan-making opportunities for communities, who can prepare Neighbourhood Development Plans (NDPs), Neighbourhood Development Orders and Community Right to Build Orders (CRTBOs). Within Arun, the Town and Parish Councils are the responsible bodies for producing NDPs because Arun is parished. Arun continues to be one of the lead authorities for neighbourhood planning nationally and amongst local planning authorities (LPAs) with the most 'made' NDPs and CRTBOs in the country to date.

NDP Update and Progress

2.2 The level of interest in neighbourhood planning in Arun remains solid. There are currently 17 'made' (adopted) plans - all of which are led by a Parish/Town Council or a sub group of the Parish/Town Council - for the following areas:

Area Designation Approved

1. Aldingbourne*
2. Angmering*
3. Arundel*
4. Barnham & Eastergate
5. Bersted
6. Bognor Regis
7. Climping
8. East Preston
9. Felpham
10. Ferring
11. Ford
12. Kingston
13. Littlehampton
14. Lyminster and Crossbush*
15. Rustington
16. Walberton*
17. Yapton

*Parts of these parishes fall within the SDNP, but Arun District Council is the Local Planning Authority for the purposes of NDPs.

2.3 There are also 3 CRTBOs made in Ferring. The CRTBO is a particular type of neighbourhood development order, which allows people to propose development in their local area and obtain permission for it, without having to go through a lengthy planning process. A proposal can be developed as part of a full neighbourhood planning process, or on its own. The statutory process is similar to a NDP and therefore has a referendum after the examination

2.4 There are currently 17 'made' NDPs and 3 'made' CRTBOs in Arun. The following list shows the current status of each NDP: 

Made Plans 

1. Aldingbourne (2nd Plan) ('made' on 14 July 2021) 
2. Angmering ('made' on 11 March 2015) 
3. Arundel (2nd Plan) ('made' on 15 January 2020) 
4. Barnham & Eastergate (2nd Plan) ('made' on 9 March 2022) 
5. Bersted ('made' on 5 November 2014) 
6. Bognor Regis ('made' on 11 November 2015) 
7. Climping ('made' on 13 January 2016) 
8. East Preston ('made' on 11 March 2015) 
9. Felpham (2nd Plan) ('made' on 17 March 2021) 
10. Ferring ('made' on 14 January 2015) 
11. Ford ('made' on 9 January 2019)
12. Kingston ('made' on 11 March 2015) 
13. Littlehampton ('made' on 5 November 2014) 
14. Lyminster & Crossbush ('made' on 9 November 2022)
15. Rustington ('made' on 11 March 2015) 
16. Walberton (2nd Plan) ('made' on 14 July 2021)
17. Yapton (2nd Plan) ('made' on 8 November 2023) 

Community Right To Build Orders (CRTBO)

1. Ferring CRTBO1 ('made' on 14 January 2015)
2. Ferring CRTBO2 ('made' on 14 January 2015)
3. Ferring CRTBO3 ('made' on 14 January 2015)

2.5 Under Regulation 7 of the Neighbourhood Planning (General) Regulations 2012, Middleton-on-Sea was designated as a 'neighbourhood area' for the purpose of preparing an NDP on 28 July 2023. The parish council published a pre-submission Draft Plan for consultation (Regulation 14) between 21 October and 4 December 2024.  

2.6 Pagham parish withdrew their NDP (Regulation 14) on 25 February 2021 and have not proceeded further since then. 2 further parishes, Aldwick and Poling, currently have no program in place for preparing NDPs.

2.7 It is critical that NDPs are prepared and updated in order to contribute towards housing delivery and the housing land supply performance of the authority, ensuring polices are up to date. The majority of the plans were 'made' prior to the ALP being adopted so the next phase is for each parish to consider monitoring and reviewing their 'made' plan. The council is actively encouraging the parishes to review their plans in order to fully meet the identified housing need and housing target set out in the ALP, and the roll out of modified plans has already started. 

2.8 The ALP includes a policy commitment to deliver at least 1,250 homes (as part of the overall housing target of 20,000 dwellings over the Plan period) either through preparing a Non-Strategic Site Allocation DPD (NSSDPD) and/or through contributions from reviewed/made NDPs. With the update to the ALP, the NSSDPD was abandoned. 

2.9 Nevertheless, the preparation and review of NDPs are expected to test the ALP housing figure and distribution agreed with the council. The Housing Target in the ALP remains the starting point for NDP preparation or reviews until the ALP is updated.

Update

2.10 Arun District Council's website has documents relating to all the 'made' plans including e.g. basic condition statements, consultation statements and examiner's reports where these have been published^[1]. 

Conclusion

2.11 As set out in the LDS, 'made' NDPs form part of the Development Plan for Arun and sit alongside the ALP. NDPs will accordingly be used by the council to help make decisions on planning applications received for the area covered. 
 
[1] Arun Neighbourhood Planning

3.1 The Localism Act 2011 (March 2012) requires public bodies to carry out the duty to cooperate (DtC) on planning issues that cross administrative boundaries. Local authorities are expected to demonstrate evidence of having cooperated with a range of bodies prescribed by the regulations where it is appropriate to do so, in order to enable the delivery of sustainable development. Furthermore, local authorities are expected to document the outcome of such cooperation and to identify any unresolved issues. 

3.2 The Government's National Planning Policy Framework (NPPF, December 2024) (paras. 24 to 28) sets out the specific requirement for authorities and prescribed bodies to cooperate on strategic matters that cross administrative boundaries, including how any unmet needs may be met elsewhere. The NPPF (paras. 36 to 38) also sets out 'soundness' tests for plan making and how this is to be achieved by preparing positive, justified, and effective plans and strategies with supporting infrastructure evidenced via effective, ongoing joint working demonstrated through published Statements of Common Ground (SoCG). These should be published and accessible online at the earliest stages to inform Regulation 18 draft plan making.

3.3 The Coastal West Sussex and Greater Brighton (CWS&GB) Strategic Planning Board provides a framework for undertaking the DtC via the Local Strategic Statement (LSS). This body includes Chichester, Arun, Worthing, Adur, Brighton & Hove, Lewes, Mid Sussex, Horsham, SDNPA, WSCC and East Sussex County Council. The purpose of the Board is to:

1. Identify and manage spatial planning issues that impact on more than one local planning area within the CWS&GB area; and
2. Support better integration and alignment of strategic spatial and investment priorities in CWS&GB, ensuring that there is a clear and defined route through the statutory local planning process, where necessary.

3.4 The CWS&GB Strategic Planning Board have prepared two successive LSSs. The current version, LSS2 (2016), focuses on the strategic issues that are shared across CWS&GB, or that will impact on the long-term sustainability of the area, providing an overlay for local plans and the business priorities of key stakeholders. Work was initiated by the CWS&GB authorities on the preparation of LSS3 and a SoCG in 2019 and in 2021/22 however, this has been delayed.

3.5 The council has continued to work collaboratively with CWS&GB and other bodies to ensure the delivery of strategic priorities across local boundaries in a coordinated way and that shared goals are reflected in the ALP (e.g. the ALP makes a contribution towards unmet housing needs - mainly Chichester and Worthing who share a local Housing Market Area).

3.6 During the monitoring year and up to the end of 2024, the council held numerous meetings and corresponded with local authorities and other bodies within the Housing Market Area (HMA) to discuss progress of the Local Plan, evidence base work and cross boundary issues. The following activities have taken place:

Adur & Worthing District Council (A&WDC)

• A&WDC undertook a public consultation with ADC on the Draft Worthing Affordable Housing Supplementary Planning Document (August 2024). 
• Comments submitted by ADC on the Sustainability Appraisal Scoping Report for the Adur Local Plan Update (November 2024).

Chichester District Council (CDC)

• DtC meetings and correspondence on CDC's emerging Regulation 19 Publication Plan (October 2023 - June 2024) with focus on housing need, G&T site provision, and highways matters.
• The Chichester Local Plan 2021 - 2039 was submitted on 3 May 2024. 
• A SoCG between ADC and CDC was entered into in July 2024 in relation to the Plan. 
• ADC was initially consulted on CDC's A27 Chichester Bypass Mitigation SPD in September 2023 and sent a response in October 2023. A further consultation on the SPD took place in May 2024 but ADC did not send a formal response as it was considered the key matters were already covered in the SoCG for the Local Plan.
• A transport update meeting between ADC, CDC and Stantec (CDC's transport consultants) and WSCC regarding improvements on the A27 Junctions that impact ADC was held in January 2024.

Crawley Borough Council (CBC)

• Email from CBC seeking confirmation ADC's role in assisting in meeting unmet development needs under DtC provisions.
• Correspondence with CBC (April 2023) in relation to the Submission draft Local Plan 2024 - 2040: DtC. ADC responded in June 2023 noting that CBC sits within the North-West Sussex HMA with Horsham and Mid Sussex councils and the priority must be to try to resolve unmet need within that HMA.

Horsham District Council (HDC) 

• Meetings and correspondence with HDC in September and November 2023 and February 2024, regarding their request for ADC to help with unmet G&T needs and impacts from water neutrality. 
• A SoCG between HDC and ADC was signed in June 2024 concerning the Horsham Local Plan 2023 - 2040, confirming Arun's position that we are not able to contribute to meeting Horsham's unmet housing or G&T needs. 
• The Horsham District Local Plan 2023 - 2040 was formally submitted to the Planning Inspectorate on Friday 26 July 2024.

Lewes District Council (LDC)

• LDC requested ADC help with meeting its unmet housing needs (April 2024). ADC responded saying that it is too early in our own Local Plan update to confirm whether any unmet need arising from any neighbouring or remote local authorities can be accommodated in Arun.

Mid-Sussex District Council (MSDC)

• The Mid Sussex District Plan 2021 - 2039 was submitted for examination on 10 July 2024.

South Downs National Park (SDNP)

• SDNPA consulted ADC on the South Downs Local Plan Review in September 2024, sharing the Project Initiation Document, LDS and SCI. 
• A preview of site allocations and Land Availability Assessment in relation to the draft Regulation 18 Local Plan was shared with ADC and Angmering & Findon Ward Members in October 2024.

West Sussex County Council (WSCC)

• Various liaison meetings and correspondence on Arun Transport Model during 2023 and 2024. 
• ADC responded to the A259 Bognor Regis to Littlehampton Improvement Consultation in April 2023. 
• ADC responded to the Stage 2 consultation on the A259 Chichester to Bognor Regis improvement scheme in October 2024.

Planning Policy Officers Group (PPOG)

• ADC attendance at various meetings of PPOG, which comprises representatives of local authorities from across West Sussex - including a dedicated session on the consultation on reforms to the NPPF and wider planning system (July 2024).
• Email from ADC (October 2023) advising of review of Local Plan and sharing scoping consultation document for the SA/SEA.

Utilities

• Southern Water (SW) - DtC meeting with ADC on water related matters held in April 2023 and discussions commenced on a SoCG to help inform the ALP update. ADC formally responded to the consultation on SW's revised draft Water Resources Management Plan in November 2024.

Statutory Bodies

• National Highways (NH) - June to August 2023 correspondence between ADC and NH regarding approach of Chichester Local Plan Consultation and improvements on A27 Junctions that affect or are affected by ADC developments and future plan making. Correspondence and meetings with NH (April 2024) concerning the Chichester Local Plan Regulation 19 Publication Plan Consultation - A27 Monitor Manage.
• Transport for the South-East - Consulted with ADC on Regional Active Travel Strategy and Action Plan in November 2024.

Engagement with other Stakeholder Bodies

• Rampion 2 Wind Farm - ADC consultation responses on this Nationally Significant Infrastructure Project for offshore wind generation off Littlehampton coast. A SoCG was agreed between ADC and the applicant in July 2024 and was followed by the submission of a document setting out the Principal Areas of Disagreement between the parties in August 2024. 
• Sussex Local Nature Partnership - Ongoing engagement and meetings involved with the development of a Local Nature Recovery Strategy for West Sussex took place during 2023 and 2024. Presentation on Arun's Biodiversity Net Gain study evidence base to LNP webinar (January 2024).
• Three Harbours Partnership - ADC was consulted on the Draft Three Harbours Strategy, which includes initiatives relating to Pagham Harbour. The Council agreed to become a partner organisation in September 2024.
• Traffic & Infrastructure Management Group (TIMG) - A multi-agency officer-level group comprising representatives from NH, WSCC, Hampshire County Council, CDC and ADC held a number of meetings since April 2024 to advise and recommend on the long-term monitoring and review of the local planning transport mitigation strategy, predominantly as it relates to CDC and cross boundary highway issues.

Arun District Council 5-year Housing Land Supply 2024/25 - 2029/30

4.1 This Chapter sets out the council's assessment of Housing Land Supply (HLS) for the Arun Local Planning Authority Area (i.e. excluding areas of Arun District which fall within the SDNP). The 5YHLS looks forward for the period 2024/25 - 2029/30. The methodology for assessing the 5YHLS is in accordance with the provisions of the NPPF, and relevant Planning Practice Guidance (PPG). In accordance with the AMR reporting period, the completions and commitments monitoring baseline period is from 1 April 2023 - 31 March 2024.

National Planning Policy Framework

4.2 In July 2024, the Government consulted on proposed changes to the NPPF, with a revised NPPF published on 12 December 2024. The NPPF sets out a revised standard method and requires a 5YHLS to be demonstrated at all times. This should include a 5% buffer, or 20% where there has been significant under delivery of housing over the previous 3 years (para. 78a & b). Further policy consequences apply where delivery has fallen below housing requirement over the previous 3 years (para. 79). Local Housing Need (LHN) calculations generated by the new standard method were published with the revised NPPF; these increase the annual requirement for Arun from 1,342 to 1,476. 

4.3 A key objective of the Government's policy set out in the NPPF is to significantly boost the supply of homes (para. 61). This includes a requirement that LPAs should identify and update annually a supply of specific deliverable sites to provide 5 years' worth of housing against their housing requirement.

4.4 The NPPF sets out how authorities measure their previous 3 years housing delivery performance against the housing policy requirement or local housing need; and looking forward, how to calculate a 5YHLS: 

• The Government's revised 'standard method' (SM) is used to calculate a minimum annual local housing need and comprises two main steps:
  • Setting the baseline using the value of existing housing stock for the area of the local authority^[1], where the baseline is 0.8% of the existing housing stock for the area. The most recent data published at the time should be used. 
  • An adjustment to take account of affordability, using the median workplace-based affordability ratios published by the Office for National Statistics (ONS) at a local authority level^[2]. The mean average affordability over the 5 most recent years for which data is available should be used.
• The Housing Delivery Test (HDT) measures performance over the previous 3 years and is expressed as a percentage of the Local Plan housing target (or housing requirement), divided by the number of housing completions. 
• Where plans are more than 5 years old and housing polices have not been updated, then the SM local housing need figure must be used (para. 78).
• The HDT is the basis for calculating an authority's 'buffer' for calculating a 5YHLS (para. 78b).
• Calculating a 5YHLS places emphasis on clearly evidenced 'specific deliverable sites' that are available in the right locations now, that can be developed within 5 years (para. 78).

4.5 The NPPF states that LPAs may make an allowance for windfall sites as part of the anticipated supply, if they have compelling evidence that such sites will provide a reliable source of supply (para. 75). This should not include residential gardens.

4.6 The NPPF contains further guidance to assess the deliverability and developability status of sites (Annex 2). To be considered deliverable, sites for housing should be available now, offer a suitable location for development now, and be achievable with a realistic prospect that housing will be delivered on the site within 5 years. In particular:

a)  Sites which do not involve major development and have planning permission, and all sites with detailed planning permission, should be considered deliverable until permission expires, unless there is clear evidence that homes will not be delivered within 5 years (for example because they are no longer viable, there is no longer a demand for the type of units or sites have long term phasing plans).

b) Where a site has outline planning permission for major development, has been allocated in a development plan, has a grant of permission in principle, or is identified on a brownfield register, it should only be considered deliverable where there is clear evidence that housing completions will begin on site within 5 years.

4.7 To be considered developable, sites should be in a suitable location for housing development, with a reasonable prospect that they will be available and could be viably developed at the point envisaged.

Planning Practice Guidance (PPG)

4.8 The Government's streamlined planning guidance was launched on 6 March 2014 and is continually updated. It includes guidance on issues such as the starting point for the HLS, deliverability, developability and dealing with past under- and over- supply. 

Housing Delivery Test (HDT)

4.9 The Housing Delivery Test Measurement Rule Book, 12 December 2024 sets out the method for calculating housing delivery as follows:

4.10 The results of the HDT for Arun for 2018, 2019, 2020, 2021, 2022 and 2023 (published by the Government) follow:

• 91% November 2018;
• 68% November 2019;
• 61% November 2020 (Published 19 January 2021);
• 65% November 2021 (Published 14 January 2022);
• 61% November 2022 (Published 19 December 2023)^[3];
• 70% 2023 (Published 12 December 2024)^[4]

4.11 For areas without a recently adopted (or reviewed) Local Plan (i.e., more than 5 years old), unless the strategic policies have been reviewed and found not to require updating, the 'minimum annual local housing need' figure (based on the SM) will be used. 

4.12 Policy H SP1 'The Housing Requirement' in the ALP sets out the 5-year annualised whole plan target. This includes an element of unmet need from neighbouring local authorities and is accordingly referred to as the 'stepped housing requirement.'

4.13 However, for the purposes of this AMR and in accordance with the NPPF (12 December 2024), the 5YHLS requirement is calculated based on the Government's new SM, using the 'local housing need' figure for Arun District. 

4.14 The NPPF sets out consequences for not meeting the HDT and the 5YHLS; failure in either case will trigger application of the 'presumption in favour of sustainable development' (para. 11d). The NPPF (footnote 8 & para. 79) specifies percentage thresholds where the housing requirement assessed against the HDT would trigger para. 11d such that applications should be granted, unless such a decision would conflict with the policies, protected assets, and designations of the NPPF or that the adverse impacts of doing so would significantly and demonstrably outweigh the benefits weighed against the NPPF as a whole, "having particular regard to key policies for directing development to sustainable locations, making effective use of land, securing well-designed placed and providing affordable homes, individually or in combination."

4.15 Following annual publication of the HDT, the NPPF specifies that if delivery has been below a LPA's housing requirement over the previous 3 years, the following policy consequences should apply (para. 79):

• Where housing delivery falls below 95% of the requirement, an 'action plan' to assess the causes of under-delivery and identify actions to increase delivery in future years should be prepared.
• Where housing delivery falls below 85% of the requirement, the LPA should include a 20% buffer to their 5 YHLS, in addition to preparing an action plan.
• Where housing delivery falls below 75% of the requirement, the 'presumption in favour of sustainable development' applies, in addition to the requirements for an action plan and a 20% buffer.

4.16 The published HDT results for Arun District (see para. 4.10 above) required that an action plan be prepared; and in 2019, an action plan was published, and a 20% buffer was triggered in order to calculate the 5YHLS. It is anticipated that this requirement will not change until the Government's thresholds (set out above) are achieved.

Housing Requirement

4.17 The NPPF advises that strategic policies in Local Plans should, as a minimum, provide for objectively assessed needs for housing (para. 11b). These policies should provide a clear strategy for bringing sufficient land forward, and at a sufficient rate, to address objectively assessed needs over the plan period, in line with the presumption in favour of sustainable development, including planning for and allocating sufficient sites (para. 23). 

4.18 Arun's housing requirement is set out in the adopted ALP. The whole plan requirement, set out in Policy H SP1 'The Housing Requirement', is 20,000 new homes over the Plan period (i.e. 1,000 per annum). This target of 1,000 dwellings per annum (dpa) comprises the objectively assessed need of 919 dpa, plus an additional 81 dpa to meet unmet housing need over the Plan period to 2031. This contributes toward unmet needs of the local Housing Market Area (HMA) around Arun, as well as that of the Coastal West Sussex HMA.

4.19 Due to the shortfall in delivery from the start of the ALP period and the lead times required to build-out strategic allocations, it was established at Examination that a 'stepped trajectory' would be justified. This means that a lower figure of 610 would apply for the first 5 years of the plan (2011 - 2015); rising to 1,120 for years 6 - 10 (2016 - 2020); 1,310 for years 11 - 15 (2021 - 2025); and dropping to 960 for years 16 - 20 (2026 - 2030).

4.20 The PPG^[5] clarifies:

"Housing requirement figures identified in adopted strategic housing policies should be used for calculating the 5-year housing land supply figure where:

• the plan was adopted in the last 5 years, or
• the strategic housing policies have been reviewed within the last 5 years and found not to need updating.

In other circumstances the 5-year housing land supply will be measured against the area's local housing need calculated using the standard method."

4.21 The ALP is more than 5 years old, and the housing policies were reviewed and need updating. In accordance with the NPPF, this means that the housing requirements within the ALP should be superseded by local housing need figure using the SM (para. 78).

Shortfall/Treatment of past under-provision

4.22 Given that the ALP is more than 5 years old, the housing requirement is now superseded by the local housing need figure. Therefore, shortfalls against the ALP requirements are no longer taken into account, as the SM for calculating local housing need factors this in. This is in line with the PPG^[6] which states:

"Step 2 of the standard method factors in past under-delivery as part of the affordability ratio, so there is no requirement to specifically address under-delivery separately when establishing the minimum annual local housing need figure."

4.25 A number of other councils have adopted this approach of not including previous shortfalls when addressing housing need requirements for their 5YHLS calculations, including the following:

• Basingstoke and Deane Borough Council^[7]
• Fareham Borough Council^[8]
• Gedling Borough Council^[9]
• North Northamptonshire Council^[10]

Five Year Period

4.26 In accordance with the PPG^[11], for decision making, a 5YHLS calculation is therefore, based on the new standard method local housing need figure of 1,476 dwellings per annum for Arun (up from 1,342 under the previous method), and is set out in this AMR for the reporting year. The methodology for calculating local housing need is set out in the PPG^[12]. Guidance on the 5YHLS calculation is also set out in the PPG^[13]. 

Buffer

4.26 Para. 78 of the NPPF 2024 addresses the need to for LPAs to identify housing land supply where their adopted local plan is more than 5 years old. It states: 

"Local planning authorities should identify and update annually a supply of specific deliverable sites sufficient to provide a minimum of 5 years' worth of housing against their housing requirement set out in adopted strategic policies, or against their local housing need where the strategic policies are more than 5 years old. The supply of specific deliverable sites should in addition include a buffer (moved forward from later in the plan period) of: 

a) 5% to ensure choice and competition in the market for land; or

b) 20% where there has been significant under delivery of housing over the previous three years, to improve the prospect of achieving the planned supply; or

c) From 1 July 2026, for the purposes of decision-making only, 20% where a local planning authority has a housing requirement adopted in the last five years examined against a previous version of this Framework, and whose annual average housing requirement is 80% or less of the most up to date local housing need figure calculated using the standard method set out in national planning practice guidance."

4.28 Given the published Housing Delivery Test figure for Arun of 70% in 2023 is below 75% (although up from 61% in the 2022 measurement, 65% in 2021 and 61% in 2020), a 20% buffer must still be added to its housing requirement figure. 

4.29 Arun's historic performance of delivering housing completions is set out in Appendix 1 - Table 1. It provides annualised net housing completions for Arun District from 2008/09 - 2023/24. Up until 2011/12, it included sites which now fall within the SDNP Planning Authority. From 2012/13 onwards, the completions in SDNP are excluded from this data. However, it should be noted that the HDT includes completions in the SDNP. 

4.30 Appendix 1 - Table 2 shows that completions averaged 751 dpa in the last 5 years, which is an improvement on the 675 dpa in 2022/23. This performance, while higher than 2022, and the highest recorded for the current reporting period, is still below the Local Plan trajectory target of 1,075 dpa over the last 10 years (based on the stepped requirement). If performance in 2023/24 is maintained over the next few years, significant progress will have been made, particularly as there has been a consistently high and increasing level of planning permissions, averaging 7,000 dwellings over the last 5 years (of which 5,494 are 'Deliverable'), which have not yet been implemented or completed.

4.31 Appendix 2 details the actual completions recorded in the year 2023/24.

Housing Land Supply Data

4.32 The assessment of HLS draws on several sources of evidence to calculate projected completion rates. The 5YHLS for 2024/25 - 2029/30 has been prepared using the Residential Land Availability (RLA) data supplied by WSCC as at 31 March 2024 (the latest available data)^[14]. Additionally, a Call for Sites process was undertaken in August/September 2024 which, along with other data sources, were used to estimate deliverable supply looking forward 5 years from 1 April 2024. The 5-year HLS has partly been informed by the Housing and Economic Land Availability Assessment (HELAA) 2024 work undertaken by the council, which included publication of the Call for Sites over the summer to identify new opportunities, together with an assessment of previously proposed development sites within the district for deliverability and developability, and positive and proactive engagement with landowners, site promoters, developers and housebuilders. This included direct contact via email/phone to request updated delivery trajectories for strategic sites and those larger sites benefitting from planning permission. Whilst such information was not forthcoming on all sites, there was some success, which has assisted in informing the current 5YHLS position.

Projected completions on large sites with planning permission 

4.33 For the purposes of assessing the HLS, 'Large' sites are those capable of yielding 5 dwellings or more from the monitoring year 2023/24. This is in line with the most up to date guidance contained within the PPG^[15].

4.34 WSCC annually surveys all large sites with planning permission for 5 dwellings or more in West Sussex and provides a consistent assessment of the status of available sites in terms of commencement, actual completion, and projected completion. They liaise with the developers of large sites with full planning permission to gain evidence of when completions are predicted to come forward. This, therefore, provides a reliable basis for such sites being included in the assessment, in the terms of the sites being considered 'Deliverable.' 

4.35 As well as HELAA records and Call for Sites data, Arun uses planning application data, recent appeal decisions, national published data, and case officer knowledge to help calculate the 5-year deliverable supply (using a consistent methodology on lead in times and build out rates). The sites which form part of this assessment are listed in Appendix 3.

Projected completions on Strategic Allocation Sites without planning permission

4.36 The stepped trajectory (Appendix 4) shows the predicted build out rates of the strategic allocation sites. This updated build out rate has been informed by the evidence sources outlined in para. 4.32 above. The strategic allocations and the details of each site are included as Appendix 4.

Projected completions on Housing & Economic Land Availability Assessment (HELAA) sites 

4.37 A general Call for Sites for housing and employment use was undertaken for the HELAA in June/July 2021. The council undertook a new Call for Sites exercise in June/July 2023. This allowed sites for a range of uses to be submitted including residential, employment, Biodiversity Net Gain, Blue / Green Infrastructure and Leisure & Tourism uses^[16]. A further Call for Sites was undertaken in August/September 2024 and will be reported in 2025. 

4.38 The HELAA is not to be used for Development Management decisions as the HELAA confers no planning permission status to any site categorised as 'Deliverable,' 'Developable' or 'Not Currently Developable.' Sites in the HELAA may move from one category to another depending on circumstances. The HELAA remains a high-level assessment by the council. The most recent HELAA document and interactive map for the period 2021 was produced in January 2022^[17]. 

4.39 For the purpose of this assessment, sites of 5 or more dwellings identified within the HELAA as 'Deliverable' (i.e., suitable, available, and achievable) and within the current built up area, are included, once sufficient evidence of deliverability was provided by the promotors - see Appendix 5 for details of sites included. 

Projected completions on Made Neighbourhood Plan sites 

4.40 Sites allocated in Neighbourhood Plans that have either been 'made' or have passed examination (as at 31 March 2024) are included if they are considered likely to come forward within the next 5 years. All such sites have been assessed as 'Deliverable' as part of the Neighbourhood Plan process and where up to date evidence was provided - see Appendix 6 for details of sites included.

Projected completions & implementation rates on small sites 

4.41 The WSCC RLA survey includes comprehensive information on all planning permissions for residential development of all site sizes and dwelling numbers. From this data, it is possible to determine the number of dwellings permitted on all 'small' sites, i.e. sites of less than 5 dwellings, as at 31 March 2024.

4.42 These small sites are then categorised either as under construction ('In Course of Erection' - ICE), or not commenced. It is assumed that sites under construction will be fully built out within the next 5 years, so these are included in the 5YHLS. Of the sites that are not yet commenced, a non-implementation rate is applied - see Appendix 7. A list of small site commitments data is set out at Appendix 8.

Small sites windfall calculation

4.43 The NPPF (para. 75) provides for LPAs to make an allowance for windfall sites as part of the anticipated supply, if there is compelling evidence that they will provide a reliable source of supply. Any allowance should be realistic, having regard to the strategic housing land availability assessment, historic windfall delivery rates and expected future trends.

4.44 Appendix 7 uses data from the WSCC RLA on dwelling completions on small sites from 2004/5 to 2023/24, specifically excluding development on residential gardens, in accordance with NPPF para. 75. This demonstrates that completions on such sites were never lower than 19 dpa, and were as high as 147 dpa, with an overall average of 70 dpa for the last 20 years.

4.45 On this basis, it is reasonable to provide a windfall allowance for small sites at a rate of 70 dpa (the average for the period 2004/5 - 2023/24) towards the 5YHLS period. A windfall figure is only included within a year's worth of housing supply when the supply from existing permissions on small sites is less than 70. This ensures that no one year exceeds 70 dwellings as a windfall allowance. This is demonstrated in the following table, as well as Appendix 7:

Small sites windfall

	2024/25	2025/26	2026/27	2027/28	2028/29	Total
Small site dwellings projected	84	60	39	7	1	191
Windfalls allowance	0	10	31	63	69	173

Housing Land Supply assessment 

4.46 Following adoption of the ALP, delivery rates have not come forward as forecast, despite there being a healthy overall level of permissions. The reasons for this are covered in more detail in the 'Arun District Council Housing Delivery Test Action Plan 2021'^[18], which updated the first version published in June 2019, and can be summarised as follows:

• Applications on all strategic sites have not come forward as anticipated.
• The quality of some submissions for major applications has not been of sufficient quality to allow for timely approval. 
• Some applications on strategic allocations which were recommended for approval were subsequently refused at Committee.
• The rate of completions is largely dependent on developers and consequently out of the control of the council.
• Developers have not delivered on previously promoted build out rates.

4.47 There has been improvement in 2023/24 with the grant of planning permission for some strategic allocations, and through receipt of deliverability evidence from site promoters e.g., site housing trajectories. Further progress on the strategic allocations is anticipated given that Masterplans are in place for most sites.

4.48 In August/September 2023, the council commissioned an external consultant to secure residential site delivery agreements with landowners and developers on 8 sites (1 additional site was put forward by the landowners). 4 sites had outline planning permission and 5 were strategic allocations without planning permission as at 31 March 2022^[19]. The process resulted in signed delivery agreements which contained estimated projected housing trajectories to boost the requirement of delivery evidence to meet the Category b definition of a deliverable site in the NPPF Annex 2^[20].

4.49 The latest update of the Local Plan Housing Trajectory is at Appendix 9. This shows the actual and predicted dwelling numbers that make up the HLS over the whole Plan period (2011 - 2031).

4.50 The following table summarizes how the 5YHLS assessment has been calculated using the land supply data sources outlined in para. 4.32 above, against the SM, in accordance with the PPG^[21]. The new SM local housing need figure for Arun District is 1,476 dpa and includes an affordability uplift to address housing delivery performance. The Local Plan backlog/shortfall is, therefore, no longer applied, or appropriate. 

4.51 There is evidence of significant progress in bringing forward planning approvals on strategic sites, including a framework of coordinating Masterplans. The Arun Housing Market Absorption Study (December 2022)^[22] considers that this should be monitored over the period 2023/24 to assess a likely step increase in housing delivery as a result. Indeed, housing completions show a step increase in 2023/24. Arun has also prepared and published HDT Action Plans which have provided policy coordination to help tackle the shortfall, including preparing Masterplans for strategic allocations, publishing an Interim Housing Statement, and work to secure residential site delivery agreements to remove barriers (see para. 4.46 above).

4.52 Based on the new SM and updated guidance published on 12 December 2024, the 5YHLS calculation indicates that there is a 3.41-year land supply.

5-Year Housing Land Supply Table

5YHLS based on the new Standard Method - Large sites commitments, Neighbourhood Plan allocations and HELAA sites all include a 10% slippage reduction in accordance with best practice.

Table Caption

A	Standard Method annualised figure for Arun housing need 2024/25 - 2029/30 (1,476 x 5)	7,380
B	Plus 20% Buffer (A x 0.2)	1,476
C	Total need 2024/25 - 2029/30 (A+B)	8,856
D	Large Site Commitments (as at 31 March 2024 from WSCC RLA data - Appendix 3)	4,914
E	Small Site Commitments (as at 31 March 2024 from WSCC RLA data - Appendix 8)	297
F	Windfall allowance (as at 31 March 2024 from WSCC RLA data - Appendix 7)	173
G	Made Neighbourhood Plan Allocations without planning permission as at 31 March 2024 from HELAA - Appendix 6)	87
H	Deliverable HELAA Sites within built up area - Appendix 5	145
I	Strategic Site Allocations (without PP as at 31 March 2024 or committed after 31 March 2024 - Appendix 4)	419
J	Total Supply (D+E+F+G+H+I)	6,035
K	5-Year Supply in years (J/C x 5)	3.41

Note: The SM figure for Arun includes a nominal element of need for the SDNP.

 
[1] Table 125: dwelling stock estimate by local authority district
[2] Median workplace-based affordability ratios
[3] Housing Delivery Test: 2022 measurement
[4] Housing Delivery Test: 2023 measurement
[5] Housing supply and delivery, Para: 005 Reference ID: 68-005-20190722
[6] Housing supply and delivery, Para: 031 Reference ID: 68-031-20190722
[7] Basingstoke and Deane Authority Monitoring Report 2022/23
[8] Fareham Borough Council: Five Year Housing Land Supply Position
[9] Gedling Borough Council: Five Year Housing Land Supply Assessment 2023
[10] North Northamptonshire Council Assessment of housing land supply 2023-28
[11] Housing and economic needs assessment, Para: 016 Reference ID: 2a-016-20190220
[12] Housing and economic needs assessment, Para: 004 Reference ID: 2a-004-20241212
[13] Housing supply and delivery, Para: 022 Reference ID: 68-031-20190722
[14] West Sussex commercial and residential data
[15] Housing and economic land availability assessment, Para: 009 Reference ID: 3-009-20190722
[16] Arun Call for Sites process 
[17] HELAA report 2021
[18] Arun District Council Housing Delivery Test - Action Plan
[19] Arun District Council Residential Site Delivery Agreements, October 2023
[20] NPPF, Annex 2, Deliverable site definition
[21] Housing supply and delivery
[22] Arun District Council Housing Market Absorption Study

Dwellings Completions and Delivery

5.1 The following table shows the planned housing targets with phased delivery over the Plan period 2011 - 2031, based on Policy H SP1 of the ALP:

Dwellings completions and delivery

Requirements for net additional homes	2011/12 - 2015/16	2016/17 - 2020/21	2021/22 - 2025/26	2026/27 - 2030/31	2011/12 - 2030/31
Dwellings per annum	610	1,120	1,130	960	-
Total	3,050	5,600	6,550	4,800	20,000

Dwellings completions proportion built on previously developed land

5.2 The following table sets out dwelling completions data, showing the proportion built on previously developed land (PDL).

Dwellings completions proportion built on previously developed land

Year	Dwelling Completions Gross	Dwelling Completions Net	PDL[30] Total (Included in Gross Completions
2011-12	748	722	378 (51%)
2012-13	499	475	136 (27%)
2013-14	384	359	210 (55%)
2014-15	642	601	286 (45%)
2015-16	912	890	284 (31%)
2016-17	659	616	201 (31%)
2017-18	731	704	421 (58%)
2018-19	627	603	387 (62%)
2019-20	558	515	403 (72%)
2020-21	700	673	398 (57%)
2021-22	685	653	409 (59%)
2022-23	946	931	273 (29%)
2023-24	1,013	983	203 (20%)
Total	9,104	8,725	3,989 (44%)

5.3 As is evident from a comparison between the previous tables, Arun's annual delivery for the first phase of the Plan period was close to the requirement for the period 2011/12 - 2015/16. Thereafter, annual delivery was considerably less than the requirement. Whilst delivery has improved for the current and previous AMR reporting periods, it is still less than the requirement in Policy H SP1 of the ALP.

Affordable Housing

5.4 The following table gives a breakdown of Total Dwellings delivered, with affordable dwellings shown as a net figure and a percentage of total dwellings:

Breakdown of Total Dwellings delivered, with affordable dwellings shown as a net figure and a percentage of total dwellings

Year Ended	Affordable dwellings (net)	Total dwellings (net)	% of Total dwellings
31 March 2012	280	722	39%
31 March 2013	164	475	35%
31 March 2014	30	359	8%
31 March 2015	128	601	21%
31 March 2016	166	890	19%
31 March 2017	102	616	17%
31 March 2018	104	704	15%
31 March 2019	111	603	18%
31 March 2020	65	515	13%
31 March 2021	181	673	27%
31 March 2022	99	653	15%
31 March 2023	263	931	28%
31 March 2024	262	983	27%
Total	1,955	8,724	22%

5.5 Policy AH SP2 of the ALP sets out the requirement for a minimum of 30% affordable housing for all developments of 11 or more residential units. Whilst the data presented does not allow for a direct assessment of performance against the ALP requirements, average annual delivery of 22% affordable housing over the Plan period to date is less than the specified 30% minimum.

5.6 The following table shows Affordable Dwellings Delivered (gross built and net built) per parish (from 1 April 2023 - 31 March 2024):

Affordable Dwellings Delivered (gross built and net built) per parish (from 1 April 2023 - 31 March 2024)

Parish	Gross Built	Net Built
Aldingbourne	29	29
Angmering	41	41
Barnham & Eastergate	29	29
Pagham	7	7
Walberton	55	55
Yapton	101	101
Total	262	262

5.7 The following table shows Dwellings Completions, gross built and net built per parish (from 1 April 2023 - 31 March 2024):

Table Caption

Arun District Ward / Parish	Gross Dwelling Completions	Net Dwelling Completions
Aldingbourne	113	113
Aldwick	8	8
Angmering	190	189
Arundel	7	3
Barnham	16	16
Bersted	7	6
Bognor Regis	52	48
Climping	4	4
East Preston	4	4
Eastergate	124	124
Felpham	8	2
Ferring	22	19
Ford	0	0
Kingston	2	-1
Littlehampton	23	18
Lyminster	0	0
Middleton on Sea	3	1
Pagham	34	34
Poling	0	0
Rustington	7	6
Walberton	142	142
Yapton	247	247
Grand Total	1,013	983

Self-build and Custom Housebuilding

5.6 As required by the Self-build and Custom Housebuilding Act 2015 (as amended by the Housing and Planning Act 2016), the council has maintained a Custom Self-Build Register since February 2016. This is a register of individuals or groups of individuals who are seeking to acquire serviced plots of land in Arun to build their own houses. A redacted version of the register as at October 2024 can be accessed through the council's website^[1]. 

5.7 The 2015 Act (as amended) places two duties on LPAs, namely the 'duty to grant permission'^[2] and the 'duty as regards registers'^[3].

5.8 The 'duty to grant planning permission' requires an LPA to give suitable development permission to enough suitable serviced plots of land to meet the demand for self-build and custom housebuilding in their area. The level of demand is established by reference to the number of entries added to the council's register during a base period. At the end of each base period, the council has 3 years in which to approve an equivalent number of plots of land, which are suitable for self-build and custom housebuilding, as there are entries for that base period.

5.9 The annual base period of the self-build register is from 31 October to 30 October. As this falls outside of the AMR base monitoring period, this AMR includes data up to 30 October 2024.

5.10 The Register has 54 individuals and 1 association of individuals as at 30 October 2024. There were 11 new entries of individuals added to the register and 0 new associations of individuals during this base period.

5.11 The following table gives an overview of self- and custom-build plot monitoring:

Overview of self- and custom-build plot monitoring

Base period	No. of individuals added to the register	No. of associations of individuals added to the register	Number of plots granted planning permission
4 Feb '16 - 30 Oct '16	120	0	Not known*
31 Oct '16 - 30 Oct '17	76	0	Not known*
31 Oct '17 - 30 Oct '18	22	1	Not known*
31 Oct '18 - 30 Oct '19	16	0	Not known*
31 Oct '19 - 30 Oct '20	12	0	16
31 Oct '20 - 30 Oct '21	17	0	9
31 Oct '21 - 30 Oct '22	11	0	22
31 Oct '22 - 30 Oct '23	6	0	13
31 Oct '23 - 30 Oct '24	11	0	7

*Note: 'Not known' due to unreliability of counting custom or self-build planning permissions. From 1 April 2020, Arun introduced CIL Regulations, whereby CIL Exemption monitoring could be used. Planning application forms were updated to include custom and self-build homes identification under Section 17. 

[1] Arun District Council Custom and Self-Build Register
[2] Self build and custom housebuilding, Para: 023 Reference ID: 57-023-201760728
[3] Self build and custom housebuilding, Para 014 Reference ID: 57-014-20210508 

6.1 The following tables present data on employment floorspace provision and availability, provided by West Sussex County Council as at 31 March 2024.

6.2 It should be noted that Use Class E - Commercial, Business and Service, which is in 11 parts, was included from September 1, 2020. Class E more broadly covers uses previously defined in revoked Classes A1/2/3, B1, D1(a-b) and 'indoor sport' from D2(e).

Total additional available employment floorspace 

6.3 The following table shows gross and net employment floorspace completions that are available or are currently under construction (retail, leisure, and hotel uses have not been included):

Gross and net employment floorspace completions that are available or are currently under construction (retail, leisure, and hotel uses have not been included)

Year Ended	Gross Additional Employment Floorspace (sq. metres)	Net Additional Employment Floorspace (sq. metres)
31 March 2012	3,595	3,217
31 March 2013	3,165	1,163
31 March 2014	2,350	1,490
31 March 2015	20,594	16,775
31 March 2016	25,651	17,293
31 March 2017	77,714	74,687
31 March 2018	118,641	118,558
31 March 2019	6,036	5,659
31 March 2020	5,664	5,052
31 March 2021	16,936	15,438
31 March 2022	2,804	2,495
31 March 2023	21,654	21,654
31 March 2024	10,320	10,320

6.4 In total, the gross employment floorspace developed in Arun for this AMR period was 10,320 sq. metres. This is just less than half of that recorded for the previous AMR period. 

BD1: Additional employment floorspace occupied by use class 

6.5 Employment floorspace is defined by Use Classes E(c) (i), (ii), (iii), E(g) (i), (ii), (iii) (defined as B1a, B1b and B1c prior to September 1, 2020), B2 and B8.

6.6 The following table shows gross and net floorspace completed^[1]:

Gross and net floorspace completed

Floor Space Type	Gross Additional Employment Floorspace (sq. metres)	Employment Floorspace Lost (sq. metres)	Net Additional Employment Floorspace (sq. metres)	Site area (Ha)
E (previously B1): Commercial, Business and Service	0	0	0	0
E(g)(i) (previously B1a): Offices	0	0	0	0
E(g)(ii) (previously B1b): Research and Development	0	0	0	0
E(g)(iii) (previously B1c): Industrial processes	0	0	0	0
B2: General Industry	200	0	200	1.5
B8: Storage & Distribution	1,040	0	1,040	5.8
Grand Total	1,240	0	1,240	7.3

BD2: Additional employment floorspace occupied on previously development land by use class

6.7 This counts employment floorspace from the total gross floorspace identified in BD1 (above), which is on previously developed land (PDL). This is shown in the following table:

Employment floorspace from the total gross floorspace identified in BD1

Floor Space Type	Gross Additional Employment Floorspace (sq. metres)	Employment Floorspace Lost (sq. metres)	Net Additional Employment Floorspace (sq. metres)	Site area (Ha)
E (previously B1): Commercial, Business and Service	0	0	0	0
E(g)(i) (previously B1a): Offices	0	0	0	0
E(g)(ii) (previously B1b): Research and Development	0	0	0	0
E(g)(iii) (previously B1c): Industrial processes	0	0	0	0
B2: General Industry	0	0	0	0
B8: Storage & Distribution	800	0	800	0.8
Grand Total	800	0	800	0.8

BD3: Employment land available by use class

6.8 Employment floorspace is defined by Use Classes E(c) (i), (ii), (iii), E(g) (i), (ii), (iii) (defined as B1a, B1b and B1c prior to September 1, 2020), B2 and B8. This includes available sites, sites with planning permission and sites under construction. This is shown in the following table:

Employment floorspace is defined by Use Classes E(c) (i), (ii), (iii), E(g) (i), (ii), (iii) (defined as B1a, B1b and B1c prior to September 1, 2020), B2 and B8. This includes available sites, sites with planning permission and sites under construction.

Floor Space Type	Gross Floorspace (sq. metres)	Floorspace Lost (sq. metres)	Net Floorspace (sq. metres)	Site area (Ha)
E (previously B1): Commercial, Business and Service	9,000	0	9,000	86.63
E(g)(i) (or previously B1a): Offices	120	0	120	5
E(g)(ii) (or previously B1b): Research and Development	0	0	0	0
E(g)(iii) (or previously B1c): Industrial processes	0	0	0	0
B2: General Industry	1,200	0	1,200	9.9
B8: Storage & Distribution	0	0	00	0
Grand Total	10,320	0	10,320	101.53

6.9       The floorspace available for Use Class E relates to a grant of outline planning permission at the Ford Strategic Allocation (SD8). 

BD4: Additional completed and occupied floorspace by Town Centre^[2] and Leisure uses 

6.10    This includes additional completed and occupied floorspace in Use Classes E(a) Retailing (previously A1), E(c) (i), (ii), (iii) (previously A2), E(g) (i) (previously B1a) and E(d) (previously D2), and is shown in the following table: 

Includes additional completed and occupied floorspace in Use Classes E(a) Retailing (previously A1), E(c) (i), (ii), (iii) (previously A2), E(g) (i) (previously B1a) and E(d) (previously D2)

Floor Space Type	Gross Floorspace (sq. metres)	Floorspace Lost (sq. metres)	Net Floorspace (sq. metres)	Site area (Ha)
E(a) (previously A1): Retailing	0	0	0	0
E(c)(i)(ii)(iii) (previously A2): Financial and Professional services	0	0	0	0
E(g)(i) (previously B1a): Offices	0	0	0	0
E(d) (previously D2): Indoor sport, recreation, or fitness	0	0	0	0
Grand Total	0	0	0	0

6.11 The above figures suggest that the emphasis on supporting the regeneration of Arun's main towns centres of Bognor Regis and Littlehampton in Policy EMP SP1 of the ALP is not being achieved.

[1] Floor space is completed when occupied, completed and available for use.

[2] Town Centre is classed as Bognor Regis and Littlehampton town centres in accordance with the Arun Local Plan 2018  

Gypsy and Traveller and Travelling Showpeople

7.1 The Planning Policy for Traveller Sites (PPTS)^[1] requires that LPAs set pitch targets for gypsies and travellers (G&T), and plot targets for travelling showpeople, which address the likely permanent and transit site accommodation needs of travellers in their area, working collaboratively with neighbouring LPAs. Using the target figures, the PPTS requires that LPAs identify and update annually a supply of specific deliverable sites sufficient to provide 5 years' worth of sites. A supply of specific developable sites or broad locations for growth should be identified for years 6 - 10 and where possible, for years 11 - 15.

7.2 The Gypsy and Traveller and Travelling Showpeople Accommodation Assessment (GTAA), October 2018^[2], was jointly commissioned with the Coastal West Sussex Authorities and sets out the objectively assessed need for gypsy & traveller and traveller showpeople families over the period 2018 - 2036.

7.3 Annex 1 of the PPTS defines 'gypsies and travellers' and 'travelling showpeople'. Revisions to the PPTS published on 19 December 2023 expanded the definition of 'gypsies and travellers', the implications of which for Arun are addressed in para. 7.8 below.

Pitch Needs - Gypsies and Travellers that meet the planning definition

7.4 At the time of production, based on the previous definition of G&T, the GTAA demonstrated a need for 9 additional pitches in Arun over the GTAA period for G&T households that meet the planning definition; a need for up to 3 additional pitches for unknown G&T households that may meet the planning definition. For information, the GTAA identified 13 G&T households which do not meet the planning definition. This data will be used to inform the ALP update and the approach to meeting the special and cultural needs of the population.

Plot Needs - Travelling Showpeople 

7.5 There was also a need for 14 additional plots in Arun over the GTAA period for travelling showpeople households, and a need for up to 1 additional plot for unknown travelling showpeople households that may meet the planning definition.

Gypsy and Traveller Development Plan Document Update

7.6 To meet identified needs, Arun commissioned a Gypsy and Traveller and Travelling Showpeople Sites Identification Study to inform preparation of a G&T Development Plan Document (G&TDPD). The study was published in April 2019 and included a process of identifying and assessing sites against criteria and in response to consultation etc. The G&TDPD preparation was additionally subjected to Sustainability Appraisal (February 2019).

7.7 A Regulation 18 (Part 1) Issues and Options consultation took place in the summer of 2019. A Regulation 18 (Part 2) Draft G&TDPD 'Preferred Options' consultation was completed in the summer of 2020. A Regulation 19 (Publication stage) G&TDPD consultation on legal and soundness took place between 13 December 2023 and 7 February 2024.

7.8 On 19 December 2023, the Government published revisions to the PPTS which expanded the definition of 'gypsies and travellers' to include such persons who on grounds only of their own or their family's or dependents' educational or health needs or old age have cased to travel temporarily or permanently . This significantly increases the need for provision in Arun and the council accordingly sought, and received, advice from the Planning Inspectorate on 16 April 2024 that the level of under provision was a potentially serious shortcoming of the G&TDPD. The council's Planning Policy Committee consequently took the decision to withdraw the G&TDPD on 6 June 2024.

7.9 Subject to any necessary updates, the council will make use of the considerable amount of work that has already gone into producing a G&TDPD to inform the review of the ALP. In the interim, the council is committed to ensuring that adequate provision is made for the travelling community in the short term through the development management process. The council considers that Policy H SP5 of the ALP, which includes criteria for determining planning applications, provides a sound basis for planning decisions and allowing further pitch provision.

[1] Planning policy for traveller sites
[2] Coastal West Sussex Gypsy and Traveller Accommodation Assessment (GTAA) October 2018

Arun District Council's Infrastructure Funding Statement 2023/24

8.1 Arun District Council has published its fifth Infrastructure Funding Statement (IFS 2023/24). The Town and Country Planning (Local Planning) (England) Regulations 2012 Regulation 34 requires the IFS to be reported as part of the AMR - and this chapter, therefore, includes links direct to the published IFS 2023/24 and Appendices to form part of this AMR.

8.2 In accordance with the CIL Regulations 2010 (as amended), the council has prepared an Infrastructure Funding Statement (IFS). The IFS 2023/24 reports the council's S.106 income and expenditure and provides an update on the council's Community Infrastructure Levy income for the period 2023/24.

8.3 On 9 March 2022, Arun's Infrastructure Investment Plan 2022-2024 (IIP) was approved at Full Council. The IIP sets out the shortlist of the council's priority projects for funding together with a CIL apportionment across each of the 3 years. It also includes a baseline (long list) of projects which may secure funding in future years. These lists will be updated in year 3 (i.e. 2024).

Summary Headlines of IFS 2023/24 (figures are rounded):

• £3.432m was received in total in Arun from S106 and CIL Developer Contributions combined in the year 2023/24; of which 
  • £1.252m was received from S.106 developer contributions; 
  • £2.180m was received from CIL liable applications;
• £0 was spent on infrastructure projects identified in the IIP; 
• £538K was spent by Arun or transferred (passed to third parties to spend) towards infrastructure projects through S.106 receipts;
• £1.2m total CIL relief granted; 
• £272k was transferred to Town or Parish Councils (details of any expenditure will be detailed in their own IFS)

S.106 Income 

• £12.128m is due to be received by the council once triggers are reached, after entering into S.106 agreements as part of the approval of planning applications on development sites, including the Ford strategic allocation planning permission.
• £9.376m was the total amount of money, under any planning obligation which was received before 1 April 2023 and has not been formally allocated or spent. 
• £4.057m was allocated but not spent in in 2023/24.
• 607 new affordable housing units on site and 6 new open spaces and play areas are due to be delivered once triggers are reached, as a result of the council entering into planning agreements for non-monetary obligations.
• 237 new affordable homes were noted as completed and transferred to an affordable housing provider on sites in 2023/24 and 4 new open space/play areas were noted as provided.

S.106 Expenditure

• £538k was spent in 2023/24 or transferred to be spent on infrastructure projects

8.4 The Infrastructure Funding Statement 2023/24 was agreed at Planning Policy Committee on 26 September 2024 and can be found on the council's website^[1].  

[1] Arun District Council Infrastructure Funding Statement 2023/24

Chapter 9 - Biodiversity and Biodiversity Annual Monitoring Report 

9.1 Arun District Council will record and monitor the 10% Biodiversity Net Gain (BNG) metric, which is mandatory for major developments under the Environment Act 2021 and published regulations. An annual register of BNG will record location, amount, habitat type and whether it is onsite or offsite. 

9.2 The Sussex Biodiversity Record Centre provides a Biodiversity Annual Monitoring Report to Arun on a yearly basis - Appendix 10. It is a retrospective look at the potential impacts on biodiversity of approved planning applications for the financial year 2023 - 2024.

9.2 It provides statistics on approved planning applications impacts on designated sites and priority habitats, as well as a condition assessment of Sites of Special Scientific Interest (SSSI). Compared with the data in the previous AMR report, there has been an increase in Arun's SSSI units in unfavourable condition from 3 to 12.

9.4 The report includes the Sussex Notable Bird List that consists of species that are particularly scarce or vulnerable to development and concludes with a list of invasive non-native species found in Sussex.

10.1 The council undertook a new 'Call For Sites' process from 25 July to 5 September 2024.

10.2 The call for sites has identified land promoted for the purposes of Housing and Economic Land Availability Assessment (HELAA), residential and employment uses, BNG, custom and self-build housing, leisure & tourism uses, renewable energy and blue/green infrastructure. These will be reviewed and assessed as part of the Local Plan update.

Appendix 1 - Historic Completions and Commitments 2024 [pdf] 22KB

Appendix 2 - Completions recorded 2023-24 (As at 31 March 2024) [pdf] 171KB

Appendix 3 - Large Site Commitments - with planning permission as at 31 March 2024 [pdf] 384KB

Appendix 4 - Strategic Sites without planning permission at base date from HELAA [pdf] 74KB

Appendix 5 - HELAA Sites included in Trajectory and 5 year HLSv3 [pdf] 68KB

Appendix 6 - Made Neighbourhood Plan Allocations Without PP as at 31.03.24 [pdf] 65KB

Appendix 7 - Small site completions, losses and windfall calculations [pdf] 38KB

Appendix 8 - Small Site Commitments as at 31 March 2024 [pdf] 288KB

Appendix 9 - Housing Trajectory (Updated December 2024)v4 [pdf] 61KB

Appendix 10 - Biodiversity AMR Arun 2024 [pdf] 944KB