2.39. Question for Regulation 18 consultation:
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no
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It is appropriate to identify the opportunities and constraints as they affect the broad location for development for the three growth scenario options. The assessment framework should also identify the impact and significance of each constraint on each scenario and the degree to which they potentially impact delivering of the allocation. Responses to opportunities and constraints are set out below: Constraints Power Lines - It is appropriate to identify the power lines as a potential constraint and appropriate buffer distances will need to be applied. The impact of the pylons will be confirmed at the Reg 19 Stage of the DPD when a preferred growth scenario is confirmed. Depending on the preferred option and location of development mitigation options will need to be considered including buffer zones or realignment. Gas Pipeline - The pipeline consultation area needs to be shown on the constraints map. Appropriate consultation will need to be undertaken by the Council with statutory consultees regarding the impact of the pipeline consultation area on site access and developable area. Heritage Assets - A heritage statement has been prepared in relation to the Land at Cooks Lane to assess the impact on the setting of Thatchways and Loveders Farmhouse which can be shared with the Council. The statement concludes that the impact of development on Land at Cooks Lane on these heritage assets results in less than substantial harm in accordance with the NPPF and can be mitigated through appropriate masterplanning. Loss of Agricultural Land - This is identified as a constraint for all 3 growth scenarios and is therefore not a deciding factor in determining a preferred option. The Chichester Submission Local Plan SA report states that there is no reasonable alternative strategy to deliver 535dpa including the designation of the BLD at Southbourne through Policy AL13 involving the loss of agricultural land. The DPD should identify that this not an overriding constraint that will affect bringing forward the DPD and determining a preferred growth scenario. Landscape - The impact on views to Chichester Harbour National Landscape and the South Downs National Park is a key consideration. A Landscape and Visual Impact Assessment is being prepared for Land at Cooks Lane which can be shared with the Council. Strategic Wildlife Corridors - These are proposed adjacent to the BLD so not a constraint on the delivery of the allocation for the three scenario options identified at this Regulation 18 stage. Brent Geese Support Area - This is a key constraint to identify in relation to Scenario 1 'Land to the West' which may impact on its deliverability. TPOs & Ancient Woodland - These are key planning considerations but appropriate buffers to Ancient Woodland on the edge of the BLD are easily achieved and the extent of TPOS within developable areas is not a significant constraint to the delivery of the allocation. It is important to set this context in terms of the impact of this constraint on the growth scenarios. Flood Risk - The areas within flood zones 2 and 3 on the eastern boundary to the BLD effect a relatively small area of land and through a sequential approach would not affect the delivery of the c800 within this scenario. There are some limited areas of surface water flooding to the north of the railway on the east and west of Southbourne which need to be considered but do not affect delivery of the allocation overall. Landscape Gap / Coalescence - This is a constraint but primarily affects Scenario 1 'Land to the West' as Scenarios 2 and 3 do not compromise the integrity of the local gap or result in coalescence. This context needs to be set out in the appraisal of the scenarios. Dispersed Location of Amenities - We do not consider this to be a constraint but a consideration for the allocation master planning and provision / location of new amenities and facilities. 'Unsafe and Uncontrolled' Rail Crossings and Western PROW - This is a matter to address with statutory consultees / providers including Network Rail and the highways authority. Limited crossing points and highway capacity restrictions to existing level crossing at Stein Road - The Council will need to undertake consultation with Network Rail and statutory providers / consultees alongside undertaking appropriate transport modelling to determine impact and appropriate mitigation measures. Noise and Air Quality - Air quality is a consideration, but the BLD is not within an air quality management area so unlikely to be a significant constraint. Appropriate noise buffers need to be applied to development near the railway line in accordance with national guidance and noise and vibration assessments. A noise and vibration assessment has been undertaken for Land at Cooks Lane identifying appropriate buffers which can be shared with the Council. Walking and Cycling Connections - Consider that this is more of an opportunity for enhancement of existing connections including delivery of the Green Ring. Landownerships - All of the scenarios include multiple land ownerships. There is an opportunity to establish a co-ordinated approach in accordance with an overall masterplan and plan for infrastructure delivery secured through the IDP, proportionate financial contributions and CIL. Opportunities Improved Highways Infrastructure - We agree there is an opportunity to deliver improved highways infrastructure and connectivity through a comprehensive master planned approach with proportionate financial contributions. Pedestrian and Cycle Footbridge - The Land at Cooks Lane provides a key opportunity to deliver a new pedestrian and cycle footbridge to achieve the Southbourne Neighbourhood Plan policy objective. Green Ring - There is an opportunity to deliver the Green Ring and ecological enhancements through all 3 scenarios. Scenario 3 provides the opportunity to deliver the entire Green Ring. Landscape and Ecology Designations - There is an opportunity to provide access to nature but consideration should also be given to impact on sensitive habitats including Ancient Woodland. Provision of new amenities / facilities - There is a significant opportunity for enhancement of existing amenities and facilities through proportionate financial contributions and CIL. [See attached document for full submission]
Constraints Ecology - The SA Report identifies the impact of Scenario 1 'Land to the West' on the Ems Water Body, which should be identified as a constraint. Highways, Access and Rail Crossings - Impact on highways is a key consideration but there is a differing level of impact between the scenarios in relation to access options and safety / capacity considerations with railway crossings which needs to be reflected in the appraisal of the growth scenarios. Opportunities Housing Delivery - Further consideration should be given to the ability to deliver c800 dwellings or above in all three scenarios. Scenarios should consider the ability to deliver more than 800 dwellings to provide sufficient flexibility and certainty that the Local Plan housing requirement will be met. This will take account of potential factors that may affect delivery to ensure that at least 800 dwellings are delivered. Balanced Development & Future Growth - Consideration should be given to the distribution of development and how this enables future growth of Southbourne proportionate to the settlement and its position in the Local Plan settlement hierarchy. Scenario 3 'Mixed' provides the best opportunity for future sustainable growth beyond the level of growth currently identified in the Submission Local Plan Policy A13. Accessibility to Amenities / Facilities - In addition to the provision of new facilities there is the opportunity to enhance accessibility by sustainable modes of transport. Renewable Energy - Further exploration should be undertaken regarding potential opportunities to deliver renewable energy infrastructure to serve the allocation and wider village of Southbourne. [See attached document for full submission]
The importance given to connectivity is underplayed. This area has poor road and active travel connectivity because of existing congestion. New routes and bridges are key to solving the existing problems before new development is commenced. For instance CHEM route needs to identified on Figure 2.9. A series of key destinations needs to identified so that routes to them can be identified eg schools, transport hubs, shops.
The safety of new and existing Active travel routes needs to identified and rectified/ provided, otherwise they will need be used.
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• Residents already have good access to nature because there are footpaths across the farmland especially to the west which allows residents to walk to Emsworth. That access to farmland will be lost.
• There is insufficient evidence that Southern Water have the sewage capacity for this number of houses and it does not appear that SW have been consulted. • Existing narrow lanes particularly to the east of the village (Cooks Lane, Inlands Road, Prior’s Lease Lane) which are going to cause traffic congestion. Some of these are only wide enough for one car and can cause dangers to cyclists and pedestrians on overtaking. Frustration caused by traffic jams will increase the likelihood of pedestrian and cyclist accidents.
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Mostly, but please see our answer to Q12.
There should be mention of the potential for contamination of railway land areas. We note that 2.32 refers to Ham Brook. Ham Brook has reaches which are designated as a main river, with other reaches designated as an ordinary watercourse. Therefore, a developer would need to obtain permits or consents from either the Lead Local Flood Authority or the Environment Agency if any works were taking place near the Ham Brook. A 50-metre undeveloped buffer is a good requirement to put in place as this provides multiple benefits for biodiversity and water quality, especially given that this a chalk stream. Detailed assessment of flood risk from all sources will be required, especially if access options in relation to the A259 may be impacted by future tidal flood risk. At the time of any planning application, the Local Planning Authority’s Strategic Flood Risk Assessment must be examined and up-to-date data obtained to inform any flood risk assessment.
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• There is insufficient evidence that Southern Water have the sewage capacity for this number of houses, and it does not appear that Southern Water have been consulted. • Existing narrow lanes particularly to the east of the village (Cooks Lane, Inlands Road, Prior’s Lease Lane) which are going to cause traffic congestion. Some of these are only wide enough for one car and can cause dangers to cyclists and pedestrians on overtaking. Frustration caused by traffic jams will increase the likelihood of pedestrian and cyclist accidents.
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Yes, but the constraint ‘Impact on views to the Chichester Harbour National Landscape to the south of the A259 and views to the north towards the South Downs National Park’ requires expanding to acknowledge that it is not just views to Chichester Harbour National Landscape (NL) that are relevant, but also views from the NL northwards towards the BLD, and the overall impact on the setting of the NL, as set out in paragraph 182 of the National Planning Policy Framework, given the very close proximity of scenarios 1 and 2 to the NL. Similarly, the constraint ‘Strategic Wildlife Corridors are proposed adjacent to the BLD area to protect local species networks such as waders, bats and water voles’ should be expanded as the wildlife corridors do so much more than this, they provide ecological connectivity between Chichester Harbour and the South Downs, ‘breathing space’ for residents, flood resilience, with the Ham Brook being one of only a few rare chalk streams in the world.
Additional constraints which should be included: • Additional pressure on the Waste Water Treatment Works. • Recreational disturbance to Chichester Harbour.
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Under 'constraints', and 'potential coalescence and sprawl with neighbouring villages and maintaining a visual gap between settlements' this DPD should state that this will be guided by the landscape gaps as identified in the 'Landscape Gap Assessment' (2019), and this DPD should confirm the precise boundaries of these as they relate to Southbourne, as per the 2019 study, as required under emerging Local Plan Policy NE3, given that they are not shown or included within the Southbourne Neighbourhood Plan.
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Delivering the green ring surrounded by development undermines what I think the neighbourhood plan was trying to achieve and protect. Congestion in Stein Road is not helped due to there being no traffic management solutions in place such as on street parking allowed causing bottle necks for traffic flow. None of the options consider car usage, public buses available and also the community buses.
Capacity of sewerage treatment works is an issue which currently impacts the water quality of the harbour. Infrastructure improvements have not been achieved despite the delivery of not only the 350 houses required under the approved local plan, yet this target was exceeded as potentially the village has over 1,000 units already in the pipeline. There are no guarantees the improvement in roads or GP services will be achieved, without which no additional houses should be allowed as services are already under pressure. Road improvements required to address narrow lane constraints.
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We strongly support the recognition of the two wildlife corridors in the BLD, along with the other environmental influences listed in paragraphs 2.27 – 2.31. We also agree with the conclusion in 2.32 that a 50 meter buffer is likely to be required in relation to Ham Brook and Lumley chalk streams. We are concerned that the natural influences in the area may make the level of development proposed in the DPD difficult to achieve, particularly given the large Brent Geese Secondary Support Area. We agree that the wider landscape and ecology designations in the area should be seen as an opportunity as they provide good access to nature for future residents, along with many wider benefits and fundamental ecosystem services. Overall, the designations offer the opportunity for a nature positive development that contributes to nature’s recovery and mitigates and adapts to climate change. This should be a clear requirement of any DPD policy.
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There is insufficient evidence to confirm that Southern Water has the sewage capacity to support the proposed number of houses, and it appears they have not been consulted. Narrow lanes in the eastern part of the village (Cooks Lane, Inlands Road, Prior’s Lease Lane) are prone to traffic congestion, as some are only wide enough for a single car. These conditions pose safety risks to cyclists and pedestrians, with traffic frustrations likely increasing the potential for accidents.
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In general yes but note also that the A259 "dedicated cycle route," that was planned has not been taken forward due ho complaints by local cycling clubs who prefer to risk cycling on the road, ignoring local 'casual cyclists' without lycra who find it dangerous already
What effect an the flood risk will the construction of so much 'hard' development have on existing settlements? These already suffer issues and drain overflows when high water volumes run off the Downs. Are issues over multiple land ownership Matters actually so important when many of the smaller ones have already applied successfully for development?
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ChEm route must be identified in Fig 2.9.
Fifth bullet port add upgrade ChEM coute to improve safety and encourage greater usage.
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We agree with the list of opportunities and constraints provided on pages 19, 20 and 21 of the Assessment Framework, however we would advise that some of the identified constraints (e.g. the Strategic Wildlife Corridors) should not be viewed as barriers to development. Instead, the proposed Scenarios have the potential to deliver valuable opportunities to create and reinforce links between natural habitats, thereby increasing ecosystem resilience and connectivity.
As highlighted in our comments to the three scenarios above, we would consider the requirement to deliver mitigation for both nutrient neutrality and recreational disturbance impacts a potential constraint on the site. However, as with our comments in response to Question 11, we would also strongly recommend that mitigation options (for both nutrient impacts and recreational disturbance), should consider how they can be delivered in a way that provides multiple benefits to people and nature i.e., the provision of high quality and biodiverse open greenspace. In addition, we would like to flag that areas within the Broad Location of Development (BLD) area, but not identified within the Solent Wader and Brent Goose Strategy, still have the potential to provide functional linkage to the Chichester and Langstone Harbour SPA and Ramsar site (as well as being an identified secondary support area for Brent Geese). Further survey work would be required to determine whether the site is functionally linked and whether mitigation would be required for its loss.
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ChEm route must be identified in Fig 2.9.
Fifth bullet port add upgrade ChEM coute to improve safety and encourage greater usage.
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4.24 These representations have been prepared on behalf of Hallam Land Management Limited. 4.25 Hallam control the land north of Gosden Green and west of Alfrey Close that is identified as a potential development location in the first scenario - land to the west of the settlement. 4.26 This scenario has a great many benefits. None of the challenges represent absolute constraints to development west of Southbourne. For the most part they give rise to masterplanning considerations rather than factors that preclude development. For all of these reasons set out here and in the consultation material, scenario 1 should form the basis of the DPD. 4.27 What is also evident is that the development opportunity south of the railway is eminently suitable whichever scenario is taken forward. It is conveniently located to key services and facilities including the railway station. Development here does not give rise to significant environmental considerations other than separation with Hermitage which can readily be avoided. Nor are there physical constraints and development here does not require a new road crossing of the railway line. It provides a discrete development opportunity that can be easily assimilated with the existing settlement pattern via the recent development at Gosden Green and Alfrey Close. 4.28 In the event that, for some reason, either scenario 2 or 3 are preferred, that does not preclude the Hallam land from being a part of that strategy. The Hallam land should feature regardless. [See attached document for full submission]
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Education Appendix A: Assessment Framework: Education (Pg 23) Reference is made to the potential expansion to Bourne Community College, including its sixth form. It should be noted that there is not a sixth form at Bourne Community College, and reference should be amended. [See attached document for full submission]
I live south of the A259 in School Lane in Nutbourne. I am confident my concerns about the developments will mirror those that have been put forward by neighbours. Priority must be given to sorting out current sewerage, surface water, flooding risk issues. I have absolutley no faith in anything Southern Water says. Our Southbourne GP practice does not have the resources to provide services for the current population. It goes without saying that wildlife, nature (AONB) and impact of people on the Nutbourne and Prinsted coast will be immense. Finally, the forecast costs of the new builds are not affordable - £245,000 for a one bed flat. I understand the need for housing and look forward to further consultation.
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THANK YOU FOR SENDING A COPY OF SOUTHBOURNE ALLOCATION D.P.D." WHICH / READ WITH INTEREST AS I LIVE ON THE A259 [REDACTED] ". I DID WRITE RECENTLY EXPRESSING MY CONCERNS ABOUT THE SMALL DEVELOPMENT PROPOSED THERE WHICH I CAN NOW MULTIPLY TEN FOLD ON LEARNING OF THIS HUGE DEVELOPMENT. WHILST I APPRECIATE THE PRESSURES ON ALL LOCAL AUTHORITIES TO IMPROVE, HOUSING, ETC..., IT WOULD BE MADNESS NOT TO IMPROVE AN ALREADY CONGESTED HIGHWAY NETWORK AND AN OVERWORKED LOCAL SEWAGE SYSTEM WHAT EVER SCENARIO IS CHOSEN, TO INTRODUCE THE NUMBERS YOU ARE TALKING ABOUT WITHOUT A PERIMETER ROAD AROUND THE PROPOSED AREA LINKING THE A259 WITH THE A 27 BY-PASS WOULD BE UNTHINKABLE GIVEN THE DAILY GRINLOCK IN BOTH DIRECTIONS. WITH EXISTING BRIDGES ALREADY IN PLACE NORTH OF SOUTHROURNE OR HAMBROOK, ON/ OFF RAMPS AT EITHER LOCATION WOULD RENEUE THE CONGESTION, AS MOST OF THE TRAFFIC 14 THE AREA IS MERELY WISHINGTO JOIN THE A27 ANYWAY. I AM SURE THIS HAS BEEN THOUGHT ABOUT BEFORE BUT THANKS FOR THE OPPORTUNITY TO HAVE MY SAY.
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These representations have been prepared by Turley in respect of the current consultation on the emerging Southbourne Allocation DPD (SADPD) Regulation 18 consultation. Wates Developments have land interests in the District, including those to the east of Southbourne within the Broad Location for Development (BLD) that Chichester District Council (CDC) propose to deliver under draft Local Plan Policy A13 and which is the subject of the emerging SADPD. The emerging Local Plan has been the subject of recent Examination hearings, the outcome of which are awaited. It is anticipated that a round of consultation on proposed modifications will be required ahead of receipt of the Inspector’s Report. It will be important therefore that the emerging SADPD has due regard to any changes made to the Local Plan through this process, to ensure the two are in conformity. This includes the potential for a commitment to an early review to ensure additional growth can be planned for at an early stage. Our comments on the SADPD are provided without prejudice to the submissions we have made through the Local Plan Examination process. 1.3 Alongside the draft SADPD itself, the Council have also published an Assessment Framework, Interim Sustainability Appraisal Report and Viability Assessment. These representations consider both the SADPD and the supporting documents. Due regard has also been paid to the evidence base of the emerging Local Plan where relevant to the SADPD. 1.4 Our comments have regard to national planning policy and other material considerations. At the time of consultation, the 2023 National Planning Policy Framework (NPPF) remains the current document. It is noted however that consultation on a revised NPPF was held earlier in 2024 and it is understood that a new NPPF will be formally published by the end of the year. Based on the draft transitional arrangements in the consultation version it is therefore likely that the SADPD will fall to be examined under the new NPPF and therefore once published updates may be required to the SADPD to ensure it is consistent with this. 1.5 Our representations are structured as follows: • Section Two – Representations on the SADPD • Section Three – Representations on the Assessment Framework • Section Four - Representations on the Interim Sustainability Appraisal Report • Section Five – Representations on the Viability Assessment • Section Six – Summary and Conclusion. The representations are supported by the following documents: Appendix One – i-Transport Technical Response • Appendix Two – SLR landscape response • Appendix Three – Vision Document. 1.7 We look forward to continuing to engage with the Council and their consultant team in the development of the SADPD and would be keen to arrange a further meeting to discuss our representations following the close of the consultation. 2. Southbourne Allocation DPD Planning Policy Context 2.1 As set out in the introduction, it is important to recognise the evolving context in respect of the emerging Local Plan which is currently the subject of Examination. It will be necessary to ensure the SADPD is in conformity with the Local Plan when adopted including any modifications which may be made to the current submission version of the Plan. 2.2 Indeed, it is noted that the Council has suggested some modifications to the proposed Southbourne Broad Location for Development (BLD) Policy when submitting the Plan. These include suggested modification CM333 which proposes to alter the requirement to provide ‘up to’ 1,050 dwellings to a requirement to provide ‘approximately’ 1,050 dwellings. Whilst it is understood that the consultation SADPD has been based on the Local Plan as submitted, the outcomes of the Examination process will need to be reflected in future consultation versions of the SADPD. It is important that the SADPD does not prejudice the opportunity to explore additional growth at Southbourne, should this be required as an outcome of the current Local Plan Examination. Furthermore an early review of the Local Plan may be required, in light of the discussions at the recent Examination hearings particularly around the need for updated transport modelling work. Importantly, the Development Plan for this area also includes the Southbourne Modified Neighbourhood Plan 2014-2019 (November 2023). The Neighbourhood Plan provides important local context and further guidance on the community’s aspirations for Southbourne and future development within it. 2.4 As well as the made Neighbourhood Plan itself, it is also important to consider the wider evidence base and consultation processes that have gone into the various iterations of the Neighbourhood Plan. In particular, it is notable that the Neighbourhood Plan process has previously assessed what it considered to be the most appropriate location for growth to be accommodated at the settlement. 2.5 The February 2021 submission version of the Neighbourhood Plan included a proposed allocation (draft Policy SB2) for circa 1,050 homes to the east of Southbourne. The proposed allocation of land to the east of Southbourne was supported by a 51% community preference indicated through the NP consultation process: 2.6 Whilst the Neighbourhood Plan did not ultimately allocate the site to the east of Southbourne as had been proposed in the February 2021 submission version, this was a result of the examining Inspector (Christopher Lockhart- Mummery QC) concluding the Neighbourhood Plan should be seeking conformity with the adopted Development Plan as opposed to an emerging early draft of a Local Plan, one that had potential to alter prior to adoption (Appendix One). Whilst therefore the NP removed the proposed allocation, this was purely on a technical basis rather than any suggestion of any issue with the proposed allocation itself. 2.7 The previous Neighbourhood Plan process therefore provides a clear indication of community preference in relation to the location of growth at Southbourne. Whilst the SADPD has understandably, and correctly, revisited all potential locations for growth it is important that this is also set within the context of the previous work undertaken. Supporting Material 2.8 In addition to the four main consultation documents themselves, the Council’s website advises that: “There are also evidence base documents included within the Local Plan Examination Library which are of relevance in underpinning the Southbourne Allocation DPD, which are available to view via the following link: The Local Plan examination - submission documents and evidence base - Chichester District Council. This includes a Southbourne Level Crossing Study within the Transport and Accessibility section.” 2.9 We note there were considerable discussions at the recent Local Plan Examination in respect of the highways evidence base underpinning the Local Plan in particular. The Inspector’s conclusions in respect of this, and any further work or updates required, will need to be reflected in the SADPD. In any event, it is noted that the work undertaken at the Local Plan level will have necessarily been undertaken at a higher level rather than solely focusing on Southbourne and will be somewhat time dated by the adoption of the SADPD. 2.10 The Stantec Report on Southbourne Level Crossing in particular is dated May 2021. Although there was a Paramics Model Update in March 2023, it is clear that the local context has continued to evolve since this time, including in respect of local commitments. 2.11 Similarly, we note there is no Infrastructure Delivery Plan prepared in support of the SADPD and instead it is assumed reliance is placed on the Infrastructure Delivery Plan (April 2024) prepared in support of the Local Plan. It is considered that a Southbourne specific Infrastructure Delivery Plan should be prepared to inform the SADPD. This would then help to inform the Viability Assessment, our comments on which are provided in Section Five. [See attached document for full submission]
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3.2 Chapter 2 of the Assessment Framework sets out the site context in respect of the Broad Location for Development (BLD). Whilst much of the information presented is factual and therefore on which we have no comment, we would highlight the following. 3.3 To aid clarity it is suggested that Figure 2.2 is updated to also reflect consented development which sits outside the settlement boundary and the BLD. Currently it would appear that growth to the east of the settlement would be disconnected which is not an accurate reflection of the context. 3.4 Figure 2.5 represents the different land ownerships within the BLD. Whilst this is understood to be an accurate reflection of ownership this does not necessarily depict wider agreements that are in place between landowners. Specifically, we can confirm that in addition to the orange parcel which forms the majority of the eastern part of the BDL, Wates also control the pale green and southern blue parcel in the eastern BLDAs such, whilst it is recognised that there are additional parcels outside of the control of Wates Developments, the majority of the land to the east of Southbourne is under their control. 3.5 Whilst the proposed green ring will be primarily a recreation route, it is considered that it should also be referenced in the ‘connectivity network’ section given the opportunity it presents and the community support which it has as well as its status in the Neighbourhood Plan. It is considered that the BLD boundary should be shown as a red line on Figure 3.0 Constraints Map for consistency with the other figures. It is noted that a noise buffer 60dB is annotated on the constraints plan. This is based on assessment work undertaken by Wates and supplied to the authority. It is considered this should be shown as an indicative constraint as clearly this will require further testing (including for the land outside of Wates control) as detailed proposals are developed. At this stage it is unclear whether the LPA are intending to undertake such additional work themselves in developing the next version of the SADPD. Whilst the overhead power line is shown on the constraints map, the route of the gas pipeline is not identified. We would suggest this is updated to include.Whilst the proximity considerations shown on Figure 2.2 Built Form and Heritage are consistent with the Landscape Gap Assessment (May 2019), these are then not replicated on Figure 3.0 which instead shows smaller areas for these. It is considered that the proximity considerations from Figure 2.2 must be accurately reflected on Figure 3.0. If alternative evidence has been prepared to support the revised proximity consideration areas shown on Figure 3.0, these must be published as part of the evidence base to support the current consultation. At the current time it is unclear whether the development scenarios have been informed by inaccurate information in Figure 3.0. [See attached document for full submission]
3.10 With regards to the opportunities and constraints identified, we would further highlight the following: • The eleventh bullet identifies both the Inlands Road crossing and the western PRoW crossing as being “unsafe and uncontrolled pedestrian rail crossings.” The Inlands Road (all mode) crossing has barriers which drop when a train is approaching, thereby alerting pedestrians not to cross. It is only the crossing of footpath 241 which is completely uncontrolled. The issue at Inlands Road can be addressed much more easily - with double barriers, which development at Scenario 2 could fund. Similar schemes have been implemented elsewhere in West Sussex and there is no reason why the same could not be done here. The constraint should be reworded accordingly. Further information is provided in the i-Transport response at Appendix Two. • The final bullet and constraints notes ‘multiple landowners in the east’ as a constraint but does not acknowledge the land ownership issues that could arise as a result of the multiple third-party land to the west, for example the parties involved in the delivery of a pedestrian link through the college or of the bridge to the south. This should be acknowledged and given equal weighting in the assessment process. Furthermore, our comments in relation to the land control to the east have been discussed above. • Whilst the opportunities are noted in respect of improving north-south mobility within the village, this should also recognise the opportunity to bring forward a development with multiple points of pedestrian and / or cycle access both to the village and across the railway line which is a significant parameter on which the suitability of each scenario should be assessed. Our comments on the accessibility of Scenarios 1 and 2 have been discussed in Section Two and as such are not repeated here. [See attached document for full submission]
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The land in question is to the west of Chichester, near Thorney Island, and the current consultation is geared around various site allocation options within the Broad Location of Development (BLD) under Policy A13 of Chichester’s Submission Local Plan. Accordingly, given the distances involved to the shared boundary between our authorities, we do not anticipate any significant, direct, impacts for Arun and its residents or infrastructure arising from the housing scenarios being tested under this consultation. Nevertheless, we do have concerns over the fact that the various scenarios are seeking to test an overall housing number of just 800 dwellings, which is significantly lower than the policy requirement of 1,050 new homes – this policy position already representing a reduction compared with the 1,250 dwellings stated in the Preferred Approach version of the submission Local Plan. We note that CDC’s position has been to deduct newly consented dwellings within the parish from the total figure, but given current local housing pressures we consider your council should be seeking to be more ambitious with their testing of densities for Southbourne so that as much housing within the allocation can be delivered as is reasonably achievable, while taking account of the various constraints. This is particularly important given that Chichester has recently submitted a Local Plan with a suggested annual housing figure of 575 dwellings per annum (dpa) that is well below the objectively assessed housing needs (OAHN) of the plan area of 638 dpa, plus an allowance for accommodating unmet need arising from the Chichester District part of the South Downs National Park, which would take the OAHN to around 760 dpa in total. We appreciate that the government’s final response to the recent consultation on proposed reforms to the National Planning Policy Framework and other changes to the planning system has yet to be published, however, if the revised method for calculating local housing need is taken forward as is currently proposed in the consultation, the new housing figure Chichester should plan for would rise to 1,206 dwellings per annum, which is more than double the figure the submission Local Plan is based on. In that scenario, we are concerned that CDC would be likely to look towards Arun and other neighbouring authorities to help meet unmet need in the future, when Arun already has the highest figure in the whole of West Sussex and we will struggle to meet our own needs, let alone accommodate unmet need from other districts. In conclusion, taking the above into account, we would urge Chichester District Council to be more ambitious in meeting as much of their need in the district as they can. Seeking to make the most efficient use of an area of land already identified for housing, such as the Southbourne allocation, by fully testing some higher densities that could give a greater dwelling yield that is nearer to the figure originally stated in the Preferred Approach version of the Local Plan would appear to be a sensible starting point in the circumstances.
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