6.1. Question for Regulation 18 consultation

Question 15 Do you have any comments on the site assessment scoring set out above? (Tables contained within Chapter 6) Assessment Framework Summary Integrated community – barrier effect /Mixed option – should be poor not “reasonable” as does not tackle traffic congestion and delay experienced and perceived by community. Connectivity as a whole/West option – educational land need not be a barrier as further work negotiating with WSCC could alleviate this. Should be “reasonable“ not “poor” Housing for all Site capacity/Mixed option – there will be increased pressure on Inlands Road especially in the absence of a road bridge – should be “poor” rating Environment Wildlife/West option – capable of mitigation in view of land ownership north of A27 (same landowner). Change from “very poor” to “poor” Character Growth/ West and East options– the new road links proposed in both cases would create a new spines and change perception of the form of the village, Change both from “poor” to “reasonable” Deliverability Land/East and Mixed – change both options to “very poor” due to potential lack of co-operation between multiple land owners

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There are no weighting considerations to the scoring of each option against the 33 performance criteria. However based on an equal weighting of the performance criteria, I note the west option scores 24 positives for the very strong, strong and reasonable categories and 9 negatives for the poor and very poor; the east option also scores 24 against the same positives and 9 negatives against the poor and very poor; whilst the combined option scores 26 positives and 7 negatives. The combined option also scores 8 very strong whereas the west and east options only score 5 and 6 very strong respectively. The east option scores poor or very poor against deliverability tests ruling the option out in principle. The west option is marginally better with a reasonable and very poor score. The combined option scores poor against the landownership deliverability but a reasonable against viability deliverability. Since viability will be central to determining whether an option is capable of deliverability in principle, and based on an equal weighting of the listed performance criteria, it would appear the combined option is the only option able to meet the principal purpose of the Southbourne Allocations DPD which is to ensure the option delivers the overarching policy objectives of the Local Plan in particular policy A13 (paragraph 3.5 4th bullet of the Site Allocations DPD).

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Reduce the barrier effect of rail tracks Scenarios 1 and 2 include the provision of a multi modal bridge but transport evidence has not yet been prepared to confirm whether it is required to the west or east. We consider that Scenario 3 should score 'strongly' by providing pedestrian / cycle rail crossings rather than making a 'reasonable / neutral contribution'. Support delivery of improved connectivity within the village as a whole with good integration between new and existing community Scoring needs to be adjusted to take account of scenario 2 delivering a multi modal rail crossing and pedestrian footbridges which will improve connectivity. We consider scenario 2 scores higher in this respect. Utilities pipeline impact onsite capacity From the appraisal it is considered that Scenario 1 'Land to the West' performs least well in terms of pushing development to the west into the landscape gap affecting the ability to sustainably deliver c800 dwellings and this should be reflected in the scoring i.e. makes a negative contribution. Scenario 2 performs better and should make a 'reasonable 'contribution and Scenario 3 also a 'reasonable' contribution. Site capacity to meet 800 homes delivery requirement It is considered that scenario 1 'Land to the west' performs least well and may not have capacity to sustainably deliver c800 homes. This is primarily in relation to impact on landscape gap, site access, connectivity, and ecological impacts. The rating for scenario 1 should be amended to 'poor'. Scenario 2 Land to the East is currently assessed as 'poor' in relation to potential access constraints at South Lane and pressure on Inlands Road but this is uncertain and has not been demonstrated through the Council's transport evidence. This option also includes the provision of a multi modal bridge and pedestrian railway bridge so appraisal scoring should be changed to 'reasonable'. Consider that scenario 3 performs best in terms of the ability to accommodate c800 dwellings and this should be reflected in the scoring which should be a 'strong' contribution This balanced distribution also provides better opportunity for further sustainable growth in the future over and above the Local Plan allocation. Potential to deliver mix of housing types and tenures, including G&T provision We consider this criteria is not required as all options are capable of providing an appropriate mix including G&T provision. This is a policy requirement from Local Plan Policy A13, which can be reflected in the Southbourne allocation policy. Potential to meet local housing need We consider this criteria is not required as all options are capable of providing an appropriate mix, including G&T provision. This is a policy requirement from the Submission Local Plan which can be reflected in the allocation policy and master planning. Potential for a bridge crossing the railway for vehicles Scenario 2 land to the east should score 'strongly' as it includes the provision for a multi modal bridge. There are considerations for landowner collaboration, but this does not mean that this scenario scores 'poorly'. Scenario 3 does not include a multi modal bridge but the significance of this will depend on the outputs of the Councils transport evidence as the DPD progresses. Influence of vehicular bridge on traffic congestion Scenario 3 does not provide a new vehicular bridge but the impact of this is currently uncertain without transport evidence prepared by the Council. Potential to create buildings to high environmental performance and meet Future Homes Standard This criteria is not required to differentiate performance of scenario options as all options capable of meeting this policy requirement of the Submission Local Plan, which can be reflected in the Southbourne Allocation DPD policy. Preserve wildlife corridors This criteria not required to differentiate performance of scenarios as all options located outside of wildlife corridors with no impact. Protect and / or mitigate existing wildlife and biodiversity We consider that scenario 3 performs 'reasonably' rather than 'poorly' with limited impact on the Brent Geese Support Area which can be mitigated. Impacts to agricultural land 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. The Submission Local Plan has identified the priority to meet local housing need through the Southbourne Allocation BLD and the loss of agricultural land has been accepted. Development location within Flood Zones Scenario 2 'Land to the East 'should score 'reasonably' rather than 'poor' as the majority of the site is within flood zone 1 and the location for development is identified outside of the flood zone. Also, as part of a sequential approach it should be possible to locate development in areas of low risk of surface water flooding. Also, there is potential for a drainage strategy solution for delivery critical infrastructure (multi modal rail bridge). Delivery of the railway footbridge on Land South of Cooks Lane is not constrained by surface water flooding. Retention of landscape gaps between villages/settlements Scenarios 2 and 3 should score 'reasonably' rather than 'poorly' as they do not affect the integrity of the landscape gaps or result in coalescence. Scenario 1 has the greatest impact on the hermitage landscape gap and should score 'very poorly'. Sympathetically to existing heritage features Scenarios 2 and 3 should have a 'reasonable' impact and not 'poor' as the existence of heritage assets within the broader allocation does not mean there will be harm to these heritage assets. Effective master planning provides the opportunity for new development to consider the setting of these heritage assets. Deliverability Assessment Deliverability (land) Considerations Scenarios 2 and 3 include multiple landowners however, the Southbourne DPD can establish an appropriate framework to ensure a co-ordinated approach to masterplanning and the delivery of key infrastructure. An overall master plan framework can be prepared which enables separate land parcels to come forward without compromising the overall objectives of the DPD. An approach can be established which enables proportionate financial contributions to ensure the delivery of key infrastructure. Therefore, consider that scenarios 2 and 3 should score 'reasonably' for this criteria. The appraisal for scenario 1 does not reflect that there is a significant parcel of land in a key position which is owned by a different landowner. Deliverability (viability) Considerations The conclusions on viability at this stage have been drawn from high level assumptions contained in the Southbourne Allocation Development Plan Document Viability Assessment Stage 1 (2024), prepared on behalf of the Council by Dixon Searle. The viability performance of Scenario 2 'Land to the East' is identified as poor, primarily in relation to the potential cost of a multi modal railway crossing. The viability report identifies that estimates regarding the cost of this crossing vary significantly and the actual cost will need to be confirmed through further work. Therefore, at this stage viability implications for scenario 2 should be identified as 'reasonable'. Furthermore, subject to transport evidence and engagement with statutory providers there is potential for this scenario to be delivered without a multi modal rail crossing which will significantly impact the viability assessment. The Dixon Searle viability report also identifies significant improvements to viability with the delivery of c1,050 dwellings as opposed to c800 dwellings. Subject to other considerations and constraints consideration should be given to delivering over 800 dwellings in relation to viability and ensuring that policy requirements can be met, and key infrastructure required to support the allocation can be delivered. Overall, we support the preparation of the Southbourne Allocation DPD and the broad approach to identifying a preferred growth scenario to progress to the Regulation 19 stage. We welcome the opportunity to continue to work closely with the Council and other landowners in the preparation of the DPD as it progresses to Regulation 19 stage including involvement in preparation of the evidence base. [See attached document for full submission]

I think, in general, the assessment has overweighted benefits of the mixed scenario. Specific points noted below. Integrated, well serviced community - #2 – Reduce the barrier effect of rail tracks • I think this should read – Strong/Very Poor/Very Poor rather than Very Strong/Very Strong/Reasonable • Scenario 1 West – a pedestrian/cycle bridge alone will help a very limited number of people. Those who live in the west of the village who wish to access the new hub. A definite commitment to a vehicular bridge would make this Very Strong as it would undoubtedly reduce the impact of traffic caused by new building. • Scenario 2 East - a pedestrian/cycle bridge alone will help a very limited number of people. Those who live in the east of the village (essentially Prior’s Orchard) who wish to access the new hub. There is very little opportunity realistically to build a vehicular beach in the east as the land is owned by multiple landowners, there is already an application pending regarding the relevant land south of the railway, the area is subject to flooding. • Scenario 3 Mixed – There is no vehicular bridge in this scenario so congestion will be appalling. The hub is to the east which is unsuitable for reasons already mentioned. Support delivery of a community hub – a ‘Heart for Southbourne’ • This should read Reasonable/Very Poor/Very Poor instead of all being Reasonable. • The same argument applies for both Scenarios 2(East) and 3 (Mixed). The location of a separate hub to the east of the village would impact the separation of the villages (Southbourne and Nutbourne West). • The proposed East hub is not closer to the existing facilities than the proposed West hub as stated and it would be better if the new hub was a genuine consolidation of all facilities, a genuine 'heart for Southbourne'. So those going to the Leisure Centre could also access all the new facilities. Making another separate hub just splits up the facilities more so that people will drive from one location to another, increasing the traffic in the village. The main route to the new hub in the east from those living to the south (except Prior’s Orchard/Harris Scrapyard development) would be along Cooks Lane into Prior’s Lease and that road does not take two way traffic. Promote access to nature and open space • I think this is overstated in all categories. The nature provided is not as good as the nature we currently enjoy. Support local employment opportunities • Overstated in all three scenarios. There has been very little evidence provided of what these employment opportunities might be. The assessing of Scenarios 2 and 3 as being stronger than 1 is based on the previous misassumption that a hub in the east is better than a hub in the west. As I have shown, that is not the case. So I would go for Reasonable/Poor/Poor Housing for all Site Capacity to meet 800 homes delivery requirement • This should read Reasonable/Very Poor/Poor as the problems relating to the construction of a vehicular bridge in the east impacts Scenarios 2 and 3. Transport and Sustainable Travel Providing active travel connectivity • All of these should be reasonable rather than strong. None of the existing routes through the existing village can be improved to make walking and cycling safer especially in relation to young people going to and from school and the railway station. People already think it is too dangerous to let their children cycle – once there are increased cars in the village, that will get worse, not better. Improvements in pedestrian/cycle access to the train station • The ranking of Scenarios 2 and 3 are only strong if people can access the train station directly from the pre-app Elivia site. If the Elivia site does not go ahead and that land is kept as fields, then access to the station remains walking along Cooks Lane and down Stein Road. This is not ‘adjacent’. Climate Change, move towards net zero carbon living Potential to create buildings to high environmental performance and meet Future Homes Standard • No current developments do this – how do CDC plan to ensure this happens? Support a mix of uses and facilities minimising the need to travel • None are strong – people in the village already drive rather than walk or cycle. Making the village larger will lead more people to drive. Provide the Green Ring for both people and wildlife • None of these are strong – they should all be poor. Building houses always has a massive effect on wildlife – ask anyone who has lived in the village for thirty years or more and they will tell you of the bats, different bird species, frogs, hedgehogs, that they used to see and see no more. Protect and/or mitigate existing wildlife and biodiversity • All should be very poor. Development location within Flood Zones • All should be very poor as all are going to have knock on effect flooding. Scenarios 2 and 3 threaten all of the east down to the sea. It is not enough just to think of the actual land that the houses will sit on, it is also important to think of the land that lies downstream. Scenarios 2 and 3 will negatively impact the Ham Brook and everything that the river runs through. All sites are impacted by the train line. The house in Stein Road just north of the line floods because it is at the bottom of the hill. The water runs down and has nowhere to go. • We have already seen the impact at Parham Place of a failure to think of land surrounding a development site and the impact rain falling on that can have. Character Impact on views to and from Chichester Harbour • All should be Poor. It is a massive change in size for the village – what currently appears as greenery will be urban. Retention of landscape gaps between villages and settlements • All should be very poor. If all the building goes ahead in Cooks Lane and Inlands Road as well as either Scenario 2 or 3, the gap is lost. It is disingenuous of CDC not to take pending and preapps into consideration. Growth of the village sympathetically to its existing form and structure. • In scenarios 1 and 2, the new road links proposed would create new spines in the village creating a new shape. This new shape would reduce congestion in the village. In scenario 3, the current structure of the village would be maintained, but would limit vehicle traffic to 1 main road creating enormous congestion. The new 2 spine shape of scenarios 1 and 2 is better suited to a larger village/town. I would go for 'slightly lop-sided with a bridge' over 'balanced but completely congested' anyday!

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Yes – there is no attempt to weight the considerations in order of importance and in general, the assessment has overweighted benefits of the mixed scenario. Specific points noted below. Integrated, Well-Serviced Community - #2 -Reduce The Barrier Effect Of Rail Tracks • This should be graded as – Strong/Very Poor/Very Poor not Very Strong/Very Strong/Reasonable • Scenario 1 West – a pedestrian/cycle bridge alone will help a very limited number of people. Those who live in the west of the village who wish to access the new hub. A definite commitment to a vehicular bridge would make this Very Strong as it would undoubtedly reduce the impact of traffic caused by new building. • Scenario 2 East - a pedestrian/cycle bridge alone will help a very limited number of people. Those who live in the east of the village (essentially Prior’s Orchard) who wish to access the new hub. There is very little opportunity realistically to build a vehicular beach in the east as the land is owned by multiple landowners, there is already an application pending regarding the relevant land south of the railway, the area is subject to flooding. • Scenario 3 Mixed – There is no bridge and so not a viable option. Support delivery of a community hub – a ‘Heart for Southbourne’ • This should read Reasonable/Very Poor/Very Poor instead of all being Reasonable. • The same argument applies for both Scenarios 2(East) and 3 (Mixed). The location of a separate hub to the east of the village would impact the separation of the villages (Southbourne and Nutbourne West). • The proposed East hub is not closer to the existing facilities than the proposed West hub as stated, and it would be better if the new hub was a genuine consolidation of all facilities. So those going to the Leisure Centre could also access all the new facilities. Making another separate hub just splits up the facilities more so that people will drive from one location to another, increasing the traffic in the village. The main route to the new hub in the east from those living to the south (except Prior’s Orchard/Harris Scrapyard development) would be along Cooks Lane into Prior’s Lease and that road does not take two-way traffic. Promote access to nature and open space • It is overstated in all categories. All categories should be classed as ‘Reasonable’ as the nature provided within the green ring will be limited compared to that of open space that is currently enjoyed within the village. Access to nature and open space beyond the development must be considered. Support local employment opportunities • Overstated in all three scenarios. There has been very little evidence provided of what these employment opportunities might be. The assessing of Scenarios 2 and 3 as being stronger than 1 is based on the previous misassumption that a hub in the east is better than a hub in the west. As we have shown, that is not the case. So, we assess the grading to be Reasonable/Poor/Poor. Housing for all Site Capacity to meet 800 homes delivery requirement • This should read Reasonable/Very Poor/Poor as the problems relating to the construction of a vehicular bridge in the east impacts Scenarios 2 and 3. Transport and Sustainable Travel Providing active travel connectivity • All of these should be reasonable rather than strong. None of the existing routes through the existing village can be improved to make walking and cycling safer especially in relation to young people going to and from school and the railway station. People already think it is too dangerous to let their children cycle – once there are increased cars in the village, that will get worse, not better. TRANSPORT AND SUSTAINABLE TRAVEL • Providing active travel connectivity – All of these should be reasonable rather than strong. None of the existing routes through the existing village can be improved to make walking and cycling safer especially in relation to young people going to and from school and the railway station. People already think it is too dangerous to let their children cycle – once there are increased cars in the village, that will get worse, not better. Improvements in pedestrian/ cycle access to the train station – At the moment the only route between the pedestrian cycle bridge to the train station is via Cook’s Lane and Stein Road. This means the bridge ‘adjacent to the station’ as stated in the assessment is only reliant on the Elivia Site going ahead, so the grading of this category should be Reasonable, Reasonable, Reasonable, not Reasonable, Strong, Strong. Climate Change, move towards net zero carbon living Potential to create buildings to high environmental performance and meet Future Homes Standard • No current developments do this – how do CDC plan to ensure this happens? Green ring for people and wildlife • The provision for the green ring for people and wildlife is a major point of our neighbourhood plan. Of the scenarios, there is no set outline of where the green ring goes, it is not a circle around the village. It must access open green space as well as connect all parts of the village with safe cycle and pedestrian routes. Scenario 3’s weighting of ‘Very Strong’ is wrong as the green ring is more than just a footpath around the village and for scenario 2 and 3, the development site is mostly in Nutbourne and therefore not part of the green ring’s area. With the Cook’s Lane development, the east end of the green ring is already being constructed now. Protect and/or mitigate existing wildlife and biodiversity • All should be very poor due to the loss of land and habitat. Development location within Flood Zones • All should be very poor as all are going to have knock on effect on flooding as per NPPF Dec 2023 para 165, 166. Scenarios 2 and 3 threaten all of the east down to the sea. It is not enough just to think of the actual land that the houses will sit on, it is also important to think of the land that lies downstream. Scenarios 2 and 3 will negatively impact the Ham Brook and everything that the river runs through. Character Impact on views to and from Chichester Harbour • All should be Poor. It is a massive change in size for the village – what currently appears as greenery will be urban. Retention of landscape gaps between villages and settlements • All should be very poor. If all the building goes ahead in Cooks Lane and Inlands Road as well as either Scenario 2 or 3, the gap is lost. It is disingenuous of this Consultation not to take pending and pre-apps into consideration. Growth of the village sympathetically to its existing form and structure – We would alter the ranking of this category to Reasonable, Reasonable, Poor. In scenarios 1 and 2, the new road links proposed would create new spines in the village creating a new shape. This new shape would reduce congestion in the village. In scenario 3, the current structure of the village would be maintained, but would limit vehicle traffic to 1 main road creating enormous congestion. The new 2 spine shape of scenarios 1 and 2 is better suited to a larger village/town. In section 6, the deliverability (viability) considerations do not match the score given in Section 5. In section 5, the scores are Poor, Poor, Poor and in section 6, they are given as Very Poor, Very Poor, Reasonable. This should not be the case and must be rectified. Section – Deliverability (viability) Considerations We consider Scenarios 2 and 3 should be ranked Very Poor due to the potential lack of communication between multiple landowners.

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Under ‘Mitigate impact on the Chichester Harbour SPA from recreational disturbance by creating accessible natural greenspace’ all 3 scenarios are scored the same as ‘Strong’. We disagree. Scenarios 1 and 2 should be scored as ‘reasonable’ or ‘poor’ given their proximity to Chichester Harbour. Scenario 3 would have less impact in this regard and should stay as ‘strong’ to reflect and acknowledge the difference from being sited further from the Harbour and north of the railway line, and therefore likely to cause less recreational disturbance to the Harbour shoreline. Under ‘Preserve Wildlife Corridors’ all 3 scenarios are scored as ‘strong’. We disagree. Scenario 3 would be the furthest removed from the Strategic Wildlife Corridors and is therefore less likely to have a negative impact in this regard than scenarios 1 and 2, in particular scenario 2. Scenario 1 should be scored as ‘Reasonable’ and scenario 2 should be scored as ‘Poor’. Again, under ‘Protect and/or mitigate existing wildlife and biodiversity’ scenario 2 is shown as ‘reasonable’ with scenario 1 as ‘very poor’ and scenario 3 as ‘poor’. We disagree. Scenario 2, due to its proximity to the Strategic Wildlife Corridor (the Ham Brook) should score badly under this objective and should therefore be ‘very poor’ as well as scenario 1. Scenario 3 would have the least impact on this objective, with a much smaller area of Secondary Support Area for Brent Geese being affected than scenario 1, and overall being much further removed from the Strategic Wildlife Corridors and the Harbour, and therefore should have the highest rating, as ‘reasonable’. Under ‘Impacts to agricultural land’, all 3 of the scenarios would be located on Grade 1 and 2 Agricultural land, and score as ‘poor’ within the Assessment Framework as a result; although scenario 3 would appear to have the ‘least bad’ impact in this regard, as the proposed housing area includes less Grade 1 and more Grade 2 land than scenarios 1 and 2. Scenarios 1 and 2 should be scored as ‘very poor’ and scenario 3 as ‘poor’ to reflect and acknowledge this difference. Under ‘Impact on views to and from Chichester Harbour National Landscape (CHNL) and South Downs National Park (SDNP)’ all 3 scenarios are scored as ‘reasonable’. We disagree. Scenarios 1 and 2 should score as ‘very poor’ and ‘poor’ respectively, given the open nature of the land within the NL to the south and the views obtainable looking northwards towards the site for scenario 1 and given that scenario 2 directly adjoins the NL boundary at the last remaining field along this part of the A259 / NL boundary. Under ‘Retention of landscape gaps between villages/settlements’ scenario 1 is scored as ‘very poor’ and scenarios 2 and 3 are both scored as ‘poor’. Whilst we agree with the ratings for scenarios 1 and 2, we disagree with the rating for scenario 3, as this would clearly have by far the least impact in terms of coalescence and infilling landscape gaps, and should therefore score as ‘reasonable’, to reflect the difference between this scenario and scenarios 1 and 2.

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We note that all three of the scenarios are assessed as having ‘no impact on wildlife corridors. Potential to enhance wildlife corridors through BNG requirements’. This is welcomed, however it is not clear if the assessment of ‘no impact’ is purely down to there being no suggested land take/encroachment into the corridor or whether there has been an assessment of potential indirect impacts? Overall, a sufficiently wide and ecologically appropriate buffer could address most impacts, but this must be properly implemented given the vulnerability of chalk streams. As noted in previous questions, we are concerned about the ability of loss to the Brent Geese Secondary Support Area to be appropriately mitigated/compensated. The practicalities of this with Natural England should be assessed before a scenario is chosen.

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The assessment lacks prioritization of key considerations and overstates the benefits of the mixed scenario. Detailed feedback on specific aspects is outlined below: ________________________________________ Integrated, Well-Serviced Community Reduce the Barrier Effect of Rail Tracks • Grading should be revised to Strong/Very Poor/Very Poor rather than the current assessment. • Scenario 1 (West): A pedestrian/cycle bridge benefits a limited group; a vehicular bridge commitment would significantly enhance outcomes (Very Strong). • Scenario 2 (East): A pedestrian/cycle bridge offers minimal impact due to ownership issues, pending applications, and flood risk; vehicular bridge feasibility is limited. • Scenario 3 (Mixed): Absence of a bridge renders this scenario unviable. Support Delivery of a Community Hub • Grading should be Reasonable/Very Poor/Very Poor. • Scenarios 2 and 3: An eastern hub risks separating Southbourne and Nutbourne West and undermines the consolidation of facilities, increasing local traffic. • The East hub is not closer to existing facilities compared to the West hub. A consolidated hub adjacent to the leisure center would minimize traffic and support integration. ________________________________________ Promote Access to Nature and Open Space • Assessments are overstated; all scenarios should be Reasonable as the green ring offers limited nature access compared to current open spaces. • External access to nature and open spaces must also be considered. ________________________________________ Support Local Employment Opportunities • Benefits are overstated in all scenarios. Lack of evidence on job creation, combined with the inaccurate assumption that an eastern hub is preferable, necessitates revision to Reasonable/Poor/Poor. ________________________________________ Housing for All Site Capacity for 800 Homes • Grading should be Reasonable/Very Poor/Poor due to challenges with a vehicular bridge in the east affecting Scenarios 2 and 3. ________________________________________ Transport and Sustainable Travel Active Travel Connectivity • Grading should be Reasonable across all scenarios. Existing routes cannot be sufficiently improved to ensure safety for pedestrians and cyclists, especially young people. Increased traffic will exacerbate these challenges. Access to Train Station • Reassess as Reasonable across all scenarios. The stated improvements are contingent on developments like the Elivia site and do not adequately address broader connectivity challenges. ________________________________________ Climate Change and Sustainability High Environmental Performance Buildings • Current developments fail to meet high standards. Detailed plans to enforce Future Homes Standards are necessary. Green Ring for People and Wildlife • Scenarios 2 and 3 are overstated as Very Strong. The green ring must connect all areas of the village with safe pathways and access open green spaces. The east-end development is already under construction, and most proposed areas lie outside the intended green ring zone. Wildlife and Biodiversity • All scenarios should be Very Poor due to habitat loss and lack of mitigation measures. ________________________________________ Flood Risk Development in Flood Zones • All scenarios should be rated Very Poor. Flooding risks extend downstream and threaten areas beyond the immediate development zones, including the Ham Brook and nearby lands. ________________________________________ Character and Village Growth Impact on Views and Landscape Gaps • Grading should be Poor for all scenarios. Development would drastically alter views and eliminate gaps between Southbourne and neighboring settlements. Village Form and Structure • Scenario 1 and 2: New road links create a functional two-spine structure better suited for growth, earning Reasonable. • Scenario 3: Maintains the current layout but limits traffic flow to one main road, causing congestion. Grade as Poor. ________________________________________ Deliverability and Viability Grading inconsistencies must be addressed: • Section 5: Scenarios ranked Poor, Poor, Poor. • Section 6: Scenarios graded Very Poor, Very Poor, Reasonable. • Scenarios 2 and 3 should be revised to Very Poor due to complex multi-landowner dynamics. ________________________________________ This revision ensures the assessment reflects realistic benefits and challenges while aligning with the overarching goals of the community.

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Yes. No weighting of importance of the different criteria meeting the objectives some of which have a significant or lesser impact, but there is no differentiation. The overall objective is just to achieve housing at the expense of everything else that is important in the village. Please see the attached re-assessment using the table format in the original document

No reference to CHEM route

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Natural England does not have any comments to make on the site assessment scoring.

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No reference to ChEm route.

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Para 6.1/Q15 With respects to the following points within the table, the following comments would be made, ‘Potential for a bridge crossing the railway for pedestrians and cyclists’: The various scenarios refer only to the potential to deliver land for a bridge; the assessment does not refer to delivery of the bridge itself. The development scenarios should be required to deliver the bridge. ‘Potential for a bridge crossing the railway for vehicles’: Similar comments would be made to those made above with references to land but not delivery of the bridge. It’s noted that two of the scenarios would potentially not allow for a vehicular bridge in any case. ‘Influence of a vehicular bridge on traffic congestion’: No detailed transport work appears to have been undertaken to demonstrate the requirement for a bridge or demonstrate what benefit this may have. In principle, a bridge may assist but this is as yet unquantified. ‘Development within 400m of a bus stop’: 400 metres is a useful guide for walking distances but it should not be viewed as an absolute upper threshold. Longer direct walking routes to bus stops may still be acceptable. Direct cycle routes to bus stops may also enable services to be accessed. ‘Deliverability (viability) considerations’: The delivery of the bridge must fall to the developer; WSCC would not accept s106 contributions and the associated risk of delivering a bridge associated with this development. This should be factored into the assessment. Para 6.10 There is concern on the reliance on the vehicular bridge with the ability to deliver which has not seemingly have been tested. Para 6.11 There would appear to be apparent issues with the ability to deliver the road bridge due to the recent planning application. There is no transport evidence to suggest whether or not a bridge is required. The is a concern in terms of connectivity if a bridge is not provided, particularly to existing bus services on the A259 and potentially to other services within the village. This in turn may force reliance on the use of the private car. Para 6.12 The concern with this option is the potential accesses onto rural lanes north of the railway and the ability for these to be improved to safely accommodate increased traffic alongside other non-vehicular road users. Similar to the other options, there is no transport evidence to demonstrate the impact on the highway network in the absence of the road bridge. Paras 6.20, 6.21, 6.22 For all options there are clear deliverability issues linked to the bridge. As noted above, there is no transport assessment having been undertaken for any of the scenarios to demonstrate the consequences for or against providing the bridge. It seems fundamental to understand whether any of the development scenarios are deliverable either with or without a bridge in place. [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). Assessment Framework 3.18 In light of the above, it is considered the conclusions of the site assessment framework require updating. Whilst this does not relate to all assessment criteria, where changes are recommended, the relevant row of the Assessment Framework table is provided below including the suggested updated text and scoring for the affected Scenario(s). This has been informed by the work of i-Transport at Appendix Two and SLR at Appendix Three. The Vision Document at Appendix Four demonstrates how Scenario 2 could be delivered. [See attached document for full submission]

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