3.12. Question for Regulation 18 consultation
Question 13 Do you have any comments on the infrastructure requirements set out above (para 3.1 – 3.11), including how they could /should be most effectively delivered? Paras 3.4 and 3. Definitely needs enforceable phasing and Implementation Plan PIP Paras 3.6 and 3.11. Fully support the refusal of piecemeal development which, if permitted, would seriously undermine the whole project. Para 3.9 Education – does the Bourne Community College have a 6th form? Healthcare – urgently needed due to new development (both recently built and now proposed) and ageing population New community hall – urgently needed Library is a hub for many community activities, needs support and expansion Age Concern Building – needs replacing. New dev could justify extension to bus routes which are currently not viable Wastewater – stormwater discharges must stop, Chichester Harbour water quality already in decline and further housing must not exacerbate this.
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It is understood that infrastructure requirements have been identified through the Submission Local Plan, Policy A13 and the Infrastructure Delivery Plan 2021 - 2039 (IDP) and Infrastructure Business Plan 2024 - 2029 (IBP). A response to the infrastructure requirements and delivery mechanism is set out below. Transport A27 Mitigation Contributions - It is appropriate that mitigation for the A27 is identified, and contributions should be proportionate to the impact of sites within the wider allocation and in accordance with the adopted SPD. Multi Modal Crossings - The potential requirement for new road level crossings will need to be determined through engagement with statutory providers and transport modelling undertaken by the Council. It is currently not clear what the impact of the allocation is without new multi-modal crossings. Any potential financial contributions must be proportionate and in accordance with the CIL tests. The alternative option of road level crossing improvements should also be assessed through the DPD involving engagement with statutory providers / consultees. Bus Service Improvements - The provision of bus service improvements is a commercial decision by the bus operators and cannot be delivered by developers. Engagement with bus operators should be undertaken by the Council through preparation of the DPD to determine the potential for bus service improvements / bus routes. Pedestrian Rail Crossings - A pedestrian rail crossing is deliverable on safeguarded land located to the east of Southbourne (within scenarios 2 and 3) on Land at Cooks Lane. Elivia Homes has undertaken engagement with Network Rail regarding delivery of the railway footbridge. As a result of these discussions, a railway footbridge is considered deliverable on land at Cooks Lane within the next 4 years. Furthermore, the costs of delivering the footbridge have been broadly agreed with Network Rail which will refine the costs provisionally identified in the emerging Southbourne Allocation DPD. Education - Education infrastructure requirements have been identified through the Local Plan IDP in relation to wider population growth and the impact of growth associated through the Local Plan including the Southbourne Local Plan allocation Policy A13. The delivery of education infrastructure through the Southbourne DPD could identify proportionate financial contributions related to the impact of individual sites / land parcels within the wider allocation in accordance with the CIL tests. Health - Health infrastructure requirements have been identified through the Local Plan IDP in relation to wider population growth and the impact of growth associated through the Local Plan including the Southbourne Local Plan allocation Policy A13. The delivery of health infrastructure through the Southbourne DPD will need to identify proportionate financial contributions related to the impact of individual sites / land parcels within the wider allocation in accordance with the CIL tests. Sports Facilities - More details required on sports facilities requirements and playing pitch provision. Social / Community - The identified requirements for a new community hall and library expansion will relate to the needs of Southbourne as a whole. The IDP will need to determine the impact of the allocation and to determine proportionate contributions related to the impact of individual sites / land parcels within the wider allocation in accordance with the CIL tests. Thornham WWTW Capacity - Further clarity needed in the IDP regarding delivering sufficient capacity over the plan period to accommodate the allocation. Natural Environment - In relation to nutrient neutrality a strategic approach should be identified through the Southbourne DPD whereby a mitigation strategy is identified which specifies a suitable scheme capable of delivering appropriate mitigation as part of a co- ordinated approach. Green Infrastructure - In consultation with Southbourne Parish Council and in accordance with the Southbourne Neighbourhood Plan further work needs to be undertaken to clarify the detailed form of the Green Ring SO this can be incorporated into master planning work. Gypsy and Traveller Pitches - Submission Local Plan Policy A13 Southbourne Broad Location for Development' identifies that the Southbourne BLD will provide 12 gypsy and traveller pitches in accordance with Policy H11 and a serviced site(s) to deliver 12 plots for travelling showpeople. The Southbourne DPD needs to establish a preferred location(s) for the provision of gypsy and traveller pitches and travelling showpeople plots that meets the needs of these groups in accordance with the local plan criteria policy and as part of a co-ordinated engagement exercise involving landowners within the BLD. Infrastructure Delivery Informed by ongoing refinement of the IDP, the Southbourne Allocation DPD needs to establish a planning obligations framework which enables proportionate contributions to be made from individual sites / land parcels within the wider allocation. The role of CIL to contribute to infrastructure priorities in the BLD also needs to be clarified which also reflects how the Southbourne Parish CIL proportion is spent. The role of statutory providers in delivering key infrastructure also needs to be identified including the role of Network Rail, Southern Water and the Highways Authority / National Highways. In terms of the impact of overall growth in the area statutory providers will need to be planning for the delivery of key infrastructure related to the impact of cumulative growth in the wider area. [See attached document for full submission]
Transport • A vehicular bridge should be a sine qua non not ‘Road level crossing improvements OR replacement with road bridge’. This should read ‘road level crossing improvements AND a new vehicular bridge.’ Health • Community healthcare facilities: phases for improvement and expansion needed – this improvement and expansion needs to predate the development. It is already extremely hard to get a doctor’s appointment and the developments going on and likely to go ahead in Cooks Lane are going to exacerbate this. Infrastructure must be in place before new residents move in. Social • New shops, pharmacy, café, take away, etc as part of the hub so residents go to one area to do many things. Utilities • Wastewater treatment reinforcement needed. This is such an UNDERSTATEMENT! Sewage has been an issue in this village for at least 25 years. Last year we had sewage tankers in Stein Road for 10 days trying to cope with sewage overflows. Some residents gardens were awash with raw sewage. In Farm Lane, raw sewage was flowing down the road.
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Enforceable phasing and Implementation Plan PIP is needed with the development carried out with a systematic approach. Without this, the entire project would be undermined. Transport • A vehicular bridge should be a sine qua non not ‘Road level crossing improvements or replacement with road bridge’. This should read ‘road level crossing improvements and a new vehicular bridge.’ Health • Community healthcare facilities: phases for improvement and expansion needed – this improvement and expansion needs to predate the development. It is already extremely hard to get a doctor’s appointment and the developments going out and likely to go ahead in Cooks Lane are going to exacerbate this. Infrastructure must be in place before new residents move in. Social • New shops, pharmacy, café, take away, etc as part of the hub so residents go to one area to do many things. • Support and expand the current Library. • Age Concern to be added to the community hub. Keeping a variety of shops, cafes etc within one area. Consideration/suggestion of a U3A for greater provision for the older population. Utilities Wastewater treatment ‘reinforcement needed’. This is an understatement. Expansion of Thornham for capacity increase must happen before houses are built. Consultation about wastewater treatment should predate building. There is no mention of flood prevention – this should be a major infrastructure consideration. Keeping the surface water separate from foul water. Chichester Harbour water quality is already in decline and an increase in housing will only intensify the problem
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Under 'Utilities', stating 'reinforcement needed' to wastewater treatment is an understatement, it will require additional capacity and upgrading. Under 'National Environment', for Chichester Harbour SPA, it should state the importance of providing a SANG within the development in addition to mitigation contributions and potential compensatory habitat.
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Southern Water is the statutory wastewater undertaker for the Southbourne area. In relation to the requirements for the reinforcement of Thornham Wastewater Treatment, over the next 5 yearly water industry investment period (2025-30) Southern Water will be increasing the hydraulic and process capacity of the Thornham Wastewater Treatment Works to accommodate the population growth forecast in the Local Plan. Therefore, we recommend the following new wording wording (in brackets) is set out under Utilities in Chapter 3 infrastructure requirements: 'Utilities - Wastewater treatment reinforcement needed' to (Utilities - The increase of the hydraulic and process capacity of the Thornham Wastewater Treatment Works is required to accommodate the population growth forecast in the Local Plan. This is planned for delivery over the next 5 yearly water industry investment period (2025-30).) Over the same 5 year period we will also be undertaking sewer rehabilitation and maintenance to increase the operational resilience of the Thorhnham WwTW sewer catchment, and use SuDs and storage in various locations to reduce storm overflows. You may be aware that Southern Water will assess wastewater sewer capacity in relation to the flows proposed for a development site during the planning process (when consulted), any capacity constraints will be managed through the regulatory funding mechanism for the reinforcement of our network; currently that mechanism is the Infrastructure Charge paid by developers. Whilst assessing capacity during the planning application process, should it be determined that the flows from the development will cause detriment to the operation of the sewer, we will progress the reinforcement work through our capital delivery programme. Note that the catalyst for progression is that the site receives outline planning approval. This is to ensure that there is an element of certainty that the development will progress and therefore funding is being utilised to provide reinforcement of the network in the right locations at the right time. It also ensures that there is not a misuse of funds through us delivering reinforcement work and then the development does not move forward. We have assessed capacity as part of this consultation and determined that there is sufficient capacity to serve the proposed 800 dwellings. However, developers are strongly advised to liaise with Southern Water ahead of submission of any planning application and local authorities should consult with Southern Water on the application. This is to ensure that further capacity checks are undertaken closer to construction, which will provide a more up to date assessment at that time. Therefore, we recommend the following additional wording (in brackets) to be included under Utilities in Chapter 3 infrastructure requirements (Utilities - Developers are strongly advised to liaise with Southern Water ahead of submission of any planning application and local authorities should consult with Southern Water on the application. This is to ensure that capacity checks of the sewer network are undertaken, and that any network reinforcement is delivered aligned to the occupation of the development, if required.)
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Traffic improvements: Road level crossing improvements would be unacceptable as some form of bridge crossing is required to reduce the congestion experienced due to train gates being down. Health Improvements required to GP services and pharmacy already required due to developments that have taken place (Southbourne surgery serves other parishes so growth of need not addressed yet). NHS need to deliver improvements before planning granted. Deliver before any large scale developments as current Infrastructure Plan too fluid in timescales. Social Age concern, Mens Shed and the social club are part of the existing community hubs, and certainly improvements to these facilities should be included. Utilities Both extraction / water supply plus waste water treatment needs to be in place before any development permitted, considering the current poor water quality in the harbour and the continued breaches by Southern Water of effluent. Natural Environment No detail on mitigation for brent geese. Why keep engineering solutions when the natural environment is there already? Destroying all grade 1 or 2 agricultural land is not to be taken lightly considering the impact of the lack of food security this country has. Why keep a wildlife corridor which includes grade 3 land. Green Ring The neighbourhood plan seemed to suggest the green ring surrounded the village under these proposals they become surrounded by development. So what does this now achieve? Others The original target was for 9 traveller pitches in Priors Orchard. So if there is a need why should Southbourne provide 12 for travelling show people too? Where will the support for these requirements come from? If required these numbers should be taken into account for the homes target set.
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As mentioned previously, the Sussex Wildlife Trust believes that this DPD should require a higher level of BNG delivery of at least 20%. We would also like to see this delivery primarily targeted in the wildlife corridors and their buffers. Any delivery of SANGs should be separate to both the wildlife corridors and BNG delivery.
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As mentioned previously, the Sussex Wildlife Trust believes that this DPD should require a higher level of BNG delivery of at least 20%. We would also like to see this delivery primarily targeted in the wildlife corridors and their buffers. Any delivery of SANGs should be separate to both the wildlife corridors and BNG delivery.
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Establishment of a steering committee with stakeholders (local authorities, developers, transport agencies, and community groups). Implement projects in alignment with housing delivery schedules to match demand. Utilize mixed funding models, including public funds, developer contributions, and grants. Set up performance indicators to track progress and adjust plans dynamically.
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3.3. Correct. 3.4. Will any development be allowed before adequate infrastructure in place? Poor phasing demonstrated already with existing new developments. 3.6 Too late! Piece real developments already given go ahead and causing problems highlighted in DPD. Transport - Cycle route along A259 is dangerous Simply looking at feeding More cycles onto this is short sighted. Effect of even More traffic on A259 is ignored relative to difficulties of pulling out onto what is becoming a major road through the villages. Utilities New, modern WTW are required not just short term "fixes" to existing eg. UV treatment of sewage outfalls. Travellers and Show people Given existing provision in Hambrook & Westbourne I assume this is necessary from National policy?
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Southern water must upgrade the treatment works before ANY housing is built
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Transport Road bridge over railway is essential Cycling route improvements to ChEm route The cost of the vehicular bridge over the railway should be from a "pot" with contributions from developers and local councils.
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We note that your authority has highlighted the need for natural greenspace to be provided, which we presume is to mitigate the impact of increased recreational disturbance on Chichester & Langstone Harbour SPA and Ramsar site. While Suitable Alternative Natural Greenspace (SANG) is a potentially suitable mitigation method, its effectiveness in relation to coastal designated sites is assessed on a case-by-case basis given that on-site greenspace typically only attracts around one third of would-be coastal visitors. In some other coastal locations, Natural England has advised that a SAMMS+ approach to be implemented. We recommend that you consult the Solent Recreation Mitigation Strategy (December 2017) for further information. With regard to Biodiversity Net Gain (BNG) requirements we recommend that the Biodiversity Gain Hierarchy is followed to ensure that BNG is achieved in a structured manner and that as much of the BNG requirement is delivered on site as possible. In the event that Scenario 2 or 3 is taken forward, a strategic approach to BNG could be beneficial to maximise benefits for nature across multiple application sites. It should also be noted that BNG can be delivered in combination with mitigation for nutrient impacts and SANG provision, so long as non-BNG outcomes only contribute up to a point of 'no net loss'. We are concerned that the infrastructure requirements mention the provision of compensatory habitat in relation to recreational disturbance impacts on Chichester and Langstone Harbour SPA. It is Natural England's opinion that the potential impacts of recreational disturbance arising from this development, subject to the provision of appropriate mitigation, can be mitigated and we would therefore not expect there to be a need to deliver "compensatory habitat'. Furthermore, in line with paragraph 186(a) of the NPPF, impacts should be avoided in the first instance, then adequately mitigated for and finally compensation measures provided as a last resort.
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Transport Road bridge over railway is essential. Cycling route improvements to ChEm route. The cost of the vehicular bridge over the railway should be from a "pot" with contributions from developers and local councils.
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Para 3.12 / Q13 The DPD must include a very clear mechanism concerning the delivery of any new or improved railway crossings. Reference is made regarding the road bridge to significant financial contributions. If the new/improved railway crossings are deemed essential to the proposed allocation, these must be provided by the developer to enable these to be delivered in a timely manner. The need for contributions towards this infrastructure is therefore irrelevant. Active travel aspirations should be consistent with the West Sussex Transport Plan which promote active travel strategies to improve connectivity around the Bourne area and beyond. The ChEm route active travel improvement is expected to play a significant role in achieving this; any proposed development should include connections with the ChEm route. Extension to bus services should also be agreed with relevant operators especially where this involves commercial services. The need to design road infrastructure to accommodate potentially two-way bus services is a significant element to include within any master plan. Infrastructure improvements to existing stops on the A259 could still otherwise be referenced in the DPD. This could include the provision of cycle parking alongside bus stops. The provision of cycle parking would in some way assist in overcoming any excessive walking distances from parts of the allocation to existing stops on the A259. Within ‘Cycling’, this should be broadened to include improvements to cycle routes on the A259 too. The wording included is a little unclear as to whether this is meant or not. [See attached document for full submission]
Thank you for consulting Portsmouth Water on the Southbourne Allocation Development Plan Document - Regulation 18 of the Town and Country Planning (England) Regulations 2012. Please find Portsmouth Water's response below. Our Water Resources Management Plan (WRMP) sets out how we plan to supply safe, reliable drinking water for the next 50 years (2025-2075). We have developed it with and for our customers, but also to play our part in delivering the best-value plan for the wider South East, which makes the most of our region's precious water resources, prepares for the future and will improve our natural environment. All water companies prepare WRMPs) which consider how much water is available today, how much we need for the future and develop options to make up the difference. These plans are reviewed every year and updated every five years, to make sure they always reflect the latest situation and especially our customers' needs. Our plan covers the period 2025 to 2075. Our WRMP is built on our previous plans, working with our neighbouring companies in the South East to ensure that we meet all the regulatory requirements. Since our WRMP19 there have been significant challenges that we have had to consider, including: Changes in behaviour around water use as a result of Covid-19. The potential need to reduce or stop altogether abstractions from sources that are environmentally sensitive. Accounting for population and housing growth. Working together with neighbouring companies to develop a regional plan (Water Resources South East (WRSE)) to meet the requirements of the National Water Resources Framework. To meet the requirements of Defra's Environmental Improvement Plan (EIP January 2023) which set demanding demand-side targets. Taking account of the risks and uncertainties inherent in planning for at least 25-years ahead Recognising that our plan needs to deliver 'best-value' to our customers and for the environment. More variable and extreme climatic conditions that affect both the water we have available to supply and the water required for the environment and customer demands. Our WRMP presents the base supply-demand balance throughout the next 50-year planning period (2025-26 to 2074-75). It demonstrates the need for the investment necessary to maintain the balance between supply and demand over that period. It shows how we derived feasible options to either reduce demand for water and/or increase the supply of water. It lays out the programme of actions we are proposing to ensure a reliable and resilient water supply for our customers, our environment and to contribute to the resilience of water resources for the wider South East of England. Over the planning period, we are forecasting a reduction in the water we have available to supply, primarily related to a reduction in abstraction to meet environmental protection but also due to the effects of climate change. In addition, we are forecasting an increase in demand from a growing population. The result of which is that we are forecasting significant supply deficits in the planning period. Over the planning period, the additional water we need to find rises from 54.5 MI/d in 2035, rising to 179.8 MI/d in 2075. We have reviewed a range of options to bridge this supply demand balance gap, which include new demand reduction options and new supply schemes. These options were used in the investment modelling to develop our best value plan which accounts for environmental protection, national targets, and customer preferences. Starting in 2025-2026 - implementation of demand management measures. This includes reducing leakage by 50% by 2040 and an ambitious programme to install smart water meters for all customers within 10 years. From 2025-2026 until 2040-2041 continue to allow for existing drought schemes as set out in our Drought Plan. From 2025-2026 until 2038-2039 reduce the risk of requiring Emergency Drought Order by planning for 1-in-200 Levels of Service initially and then moving to 1-in-500 by 2038-2039. From 2025-2026 continue to meet existing bulk supply obligations to Southern Water and to allow for future requirements. Some of these exports reduce overtime as our available supplies reduce as we make sustainability reductions for environmental protection. From 2039-40 receive an import from Southern Water and undertake upgrades to network boosters to unlock deployable output. From 2046-47 onwards increase the transfer and treatment capacity within our network to allow additional water to be abstracted and treated from Havant Thicket Reservoir. This option is linked to the development of strategic regional resources by other companies to allow for further capacity increases. In line with regulatory requirements, we have looked at a range of potential futures based on projections of population growth, climate change and environmental protection. Our investment the first 15 years of the planning period is very consistent, indicating that the proposed set of investments would be required in all future scenarios. We will track and monitor annually which potential future is emerging which will inform our adaptive plan. These options balance our supply demand deficit, ensuring we can continue to ensure a security of supply to our customers. Our plan also seeks to meet the demand-side targets set out in Defra's Environmental Improvement Plan (EIP ,January 2023) by 2050 and for leakage we aim to bring forward delivery of the target by 10 years (by 2040). Further details of our WRMP can be found here: https://www.portsmouthwater.co.uk/wp-content/uploads/2023/09/Portsmouth-Water- WRMP24-rdWRMP24-August-2023.pdf Given the high demand for water supply in the South East and its classification of being an area under 'serious water stress' we have the following recommendation for new build developments: Portsmouth Water encourage local planning authorities to consider higher standards of water efficiency in new developments, with all new homes being built to a minimum standard of 100 litres per person per day. Planning policy can help to ensure long-term sustainability and management of water supplies, which is likely to reduce the need to take less water from the environment to protect local streams and rivers and the wildlife which rely on them. For developments that can demonstrate meeting high standards of water efficiency of no more than 100 litres per head per day, Portsmouth water offer an incentive of a 50% discount on the Infrastructure charge. Based on a development of 200 properties with an occupancy of 3 people per property, there will be a minimum saving of 15,000 litres per day. The guide would benefit covering the importance of water efficient developments and to recommend this for all new dwellings.
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Infrastructure Requirements 3.11 Whilst we do not wish to repeat our earlier comments, we would recommend that a Southbourne specific Infrastructure Delivery Plan is prepared in support of the next consultation on the SADPD. This would provide greater certainty and reflect the current position in order to inform the viability testing. 3.12 A series of infrastructure requirements are noted in Section Three. We would highlight that these are likely to vary depending on the quantum of development to be accommodated in the BLD, which in itself is dependent on the current Local Plan Examination process. These requirements may therefore vary and will need to continue to be reviewed through the evolution of the SADPD. 3.13 It is noted that whilst the majority of the identified infrastructure requirements are consistent with the Local Plan Infrastructure Delivery Plan (LP IDP), there are some discrepancies and ongoing uncertainties. In particular we note: • The LP IDP only noted the need for provision of improved bus services and bus stops in respect of transport infrastructure. It is clear that the SADPD identifies a number of other requirements. It is important that these are justified and have been factored into the viability assessment of the options. Proposals will need to be worked up in further detail through discussions with West Sussex County Council in particular. • There remains uncertainty on the need for an expansion of Bourne Community College for both secondary and sixth form provision. • It is unclear what the need for the potential replacement of the Age Concern building is, how this is directly related to the development and how the relevant tests will be met. Further information is required on this element. • We have commented through the Local Plan Examination on the proposed requirements in respect of custom and self-build housing, and gypsy and traveller pitches and plots for travelling show people. The SADPD will need to respond to the Local Plan Inspector’s comments on these points. • We would note the role that the green ring provision will have in meeting the wider open space requirements and consider these two requirements may be more appropriately addressed as a single requirement to ensure they are considered holistically. 3.14 With regards to the delivery of these infrastructure requirements, we do not repeat our comments provided in Section Two. We comment separately on how the LP IDP has informed the viability appraisal in Section Five. [See attached document for full submission]
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