4.28. Question for Regulation 18 Consultation
Question 14 you have any comments on the assessment methodology Useful summary of complex issues
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An assessment framework has been prepared to appraise the 3 growth scenario options currently proposed at this Regulation 18 stage and comments are provided in relation to the proposed methodology below. A Sustainability Appraisal has been undertaken for the proposed growth scenarios in accordance with the SA Framework established for the Submission Local Plan. The Southbourne DPD assessment methodology should be amended to clearly state that the assessment framework also includes the SA. A response in relation to the proposed detailed DPD assessment criteria is set out below: 1. Integrated, Well-Serviced Community It is appropriate for this criteria to identify the opportunity within the BLD to deliver new educational and community infrastructure including a community hub in accordance with the Local Plan IDP. It is important to identify opportunities to deliver potential multi modal / pedestrian rail crossings. Land South of Cooks Lane provides the key opportunity to deliver a pedestrian footbridge to connect to the school, railway station, wider village. It is appropriate to identify criteria related to achieving improved connectivity within the village for walking, cycling and vehicles. Access to nature and open space including provision of the Green Ring is a key criteria. Land at Cooks Lane is able to deliver a key element of the eastern Green Ring including connectivity through provision of a pedestrian railway bridge. 2. Housing for All To ensure that the Local Plan housing requirement is met the assessment criteria should assess the ability for growth scenarios to deliver in excess of c800 dwellings. This will provide sufficient flexibility to ensure at least 800 dwellings are delivered during the plan period taking account of any potential factors that may affect delivery within the allocation area. The assessment should also consider the best distribution of development that supports longer term growth. For example, Scenario 3 'Mixed' approach provides a balanced approach to development that does not compromise the ability to sustainably accommodate further growth in the future above that identified in the Submission Local Plan. 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. In terms of housing mix, all scenarios are capable of delivering a policy compliant mix and therefore this criteria does not assist in informing the identification of a preferred strategic option at this stage. The allocation policy will have reference to housing mix but this does not need to be included in the assessment criteria. In relation to transport impact and ability to accommodate c800 homes, a full transport assessment will need to be undertaken by the Council in the preparation of the DPD. 3. Transport and Sustainable Travel The assessment criteria and objectives are similar to '1 Integrated, Well Serviced Community' and the framework could be updated to avoid duplication between the criteria. We support the identification of opportunities for active travel routes. The opportunity to provide land to deliver pedestrian and cycle bridges across the railway in safe and convenient locations is a key criteria. Scenario 2 and 3 both include Land at Cooks Lane which provides land to enable the delivery of the railway footbridge as part of the Green Ring and enabling connectivity to the school and railway station. The assessment criteria includes the ability to deliver multi modal rail crossings but the requirement for such crossings needs to be clarified through the Council's transport evidence and in consultation with statutory providers. The weight attached to this criteria is dependent on the need for the multi modal crossings in relation to the transport evidence. Proximity to bus stops and frequent bus services is an important consideration of achieving sustainable development. However, the main issue will be for the Council to engage with the bus operators regarding bus routes and any potential for improvement in services. Proximity and connectivity to the railway station and local facilities is a key criteria and scenarios 2 and 3 perform well in against this criteria. 4. Climate Change, Towards Net Zero Carbon Living The ability of each scenario to achieve the Future Homes Standard does not need to be within the assessment criteria to determine a preferred option at this stage. All scenarios are capable of being policy compliant and any further detail that expands upon the Submission Local Plan policy can be included in the Southbourne Allocation DPD policy at Regulation 19. The criteria related to promoting short journeys, collocating uses and providing an appropriate mix of uses will be a key allocation policy requirement but is not needed at this stage to determine a preferred scenario option as all scenarios are capable of delivering the land use requirements. 5. Environment It is appropriate to include a criteria that relates to the delivery of the Green Ring but further detail is required in relation to the form that the Green Ring will take to deliver the objectives of the Southbourne Neighbourhood Plan (in addition to the 20m corridor criteria). The criteria includes reference to preserving and enhancing the wildlife corridors identified in the Neighbourhood Plan. The wildlife corridors are an important consideration but the criteria is not needed as the location of built development in all scenarios is located outside the wildlife corridors where there is no significant impact. Significant weight should be given to the opportunity to retain existing habitats, such as the Brent Geese Support area which is significantly affected by Scenario 1 Land to the West. The assessment of flood risk impact needs to consider the ability to deliver c800 homes in flood zone 1 and within areas of low risk for surface water flooding. In scenarios 2 and 3 areas within future flood zones 2 and 3 are not required for residential development. The DPD will need to consider appropriate drainage strategies for the delivery of infrastructure in areas affected by surface water flooding. The criteria related to the loss of BMV agricultural land should be removed as all 3 scenarios involve loss of BMV land and this criteria does not assist in differentiating the appraisal performance of each scenario. Furthermore, the Submission Local Plan has identified the priority to meet local housing need through the Southbourne Allocation and the loss of agricultural land has been accepted. 6. Character Landscape impact and views of the Chichester Harbour National Landscape and South Downs National Park as are key consideration. The draft DPD needs to clarify the approach to co- ordinating an allocation master plan and landscape strategy confirming technical work to be undertaken by the Council in the preparation of this DPD. Landscape Gap is a key criteria for appraisal of the scenarios and is recognised that Scenario 2 'Land to the East' and Scenario 3 Mixed' perform best in this respect. The criteria identifies the importance of development respecting Southbourne's settlement form, by maintaining the traditional village structure, ensuring that new development complement the scale and style of the existing properties. This is an important consideration for the allocation policy and determining the preferred high level scenario option. [See attached document for full submission]
The assessment methodology appears to be fundamentally flawed as there is no weighting of criteria. Counting ticks does not identify the best scenario. Clearly the need for Chichester District Council to allocate housing outweighs everything else!
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Yes – there is no attempt to weight the considerations in order of importance. This consultation shows the need for the provision of houses outweighs all other considerations.
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Lack of weighting to differentiate between the items to be considered its all about delivering housing numbers and nothing else is guaranteed including the likelihood of delivering the necessary infrastructure. No employment opportunities as no details. All too subjective. Aims are good but completely lacks credibility based on experiences of the planning system policies to date.
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The whole consultation process, from limited availability of display through poor labelling of documents and complicated form filling seems designed not to encourage residents participation. The whole consultation process seems like a 'box ticking exercise. ie. yes, we consulted, job done.
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Natural England does not have any comments to make on the assessment methodology.
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Chapter 5 Assessment Framework Reduce the barrier effect of rail tracks: as well as benefits consideration should be given on how to reduce any unwanted side effects such as the attraction of through traffic. Support delivery of a community hub - a ‘Heart for Southbourne: consideration should be given to the use of an accessibility tool to compare walk distances for users of the facilities resident in the development and existing village residents who would use the new facilities. Support local employment opportunities: consider the overall impact of each option on minimising distance to travel for commuting and maximising the proportion within normal walking and cycling distance. Influence of vehicular bridge on traffic congestion: consider also if there would be any changes elsewhere by some existing traffic choosing to re-route, such as that to Westbourne. [See attached document for full submission]
Assessing the Options 3.15 Chapter 4 sets out how the options have been assessed. We note that initial community engagement is stated to have already taken place. It is assumed that future consultation versions will include a summary of consultation feedback received and how this has fed into the SADPD. 3.16 With regards to establishing the Assessment Framework, it is considered greater clarity is required as to how the comparative tables of shared objectives have been created. We note, by way of example, Figure 1 currently identifies shared objectives between Local Plan objective 1: Climate Change with Neighbourhood Plan objectives 1 and 4, but not with 5 which is “adapted and prepared for climate change and zero carbon living.” As Figure 1 has then fed into Figure 2, this lack of clarity is further compounded. 3.17 Our comments on the DPD objectives have been provided in Section Two and as such are not repeated here. The objectives are however expanded on in the Assessment Framework and we make the following observations: • Whilst it is recognised that the creation of a “Heart for Southbourne” is a local community aspiration and the dispersed nature of facilities has been identified, as discussed in Section Two there are various options for how this could be addressed which do not necessarily require the co-location of uses. The connectivity between the facilities (both new and existing) will be a key consideration. • Our comments on the quantum of housing proposed are addressed elsewhere and as such are not repeated here. The assessment methodology should not only consider the location of the site in relation to existing bus stops. It should also take account of: The assessment methodology should not only consider the location of the site in relation to existing bus stops. It should also take account of: Walking distance to nearest high frequency (as a minimum, hourly) bus services.Quality of walking routes to the bus stops. (iii) Quality of bus stops. Number of vehicular access points into site and likelihood of delivering a new or extended bus service (for example by designing a suitable road network). [See attached document for full submission]
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