4.11. Question for Reg.18 consultation:
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While the vision itself is reasonable given the imposed necessity of increasing the housing stock it does fail to address the strategic vision necessary to ensure that future developments will unfailingly negate much of what is envisioned here. Given the current disastrous State of sewage disposal provision this is inadequately addressed in the objectives. No Mention of improved/planned access onto A259 or Fishbourne roundabout
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I cannot see where there is any mention of sewerage. The existing site is full. There is NO extra capacity to build houses without Knowing that sewage can be disposed of is irresponsible This MUST. be sorted with Southern water before ANY more development starts.
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4.3 Add "including to the proposed CHEM route" after Active travel sentence 4.7. Add "Support facilitate construction connection of road bridge over railway line to facilitate connection to A259 and CHEM route".
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The stated objectives detail a positive approach for achieving the Council's vision of growing Southbourne in a comprehensive manner that supports a vibrant and sustainable community. The objectives seek to ensure the delivery of a well-integrated and well-connected village that responds positively to the environment and climate change, and sits well within the wider landscape setting. The Commissioners agrees that development should deliver essential services, modern infrastructure, a 'Green Ring' of inclusive biodiverse open space and a range of housing to support balanced and mixed communities and healthy lives. The Commissioners is wholly supportive of the objectives, which align with its own values. It is critical to the Commissioners that development of its land to the west of Southbourne (Scenario 1) achieves the three dimensions of sustainable development - economic, social and environmental, as per the NPPF (December 2023). The Commissioners' strategic land team has a positive track record of bringing forward land for new housing developments across the country, to build and strengthen new and existing communities and help create and sustain vibrant and environmentally conscious places to live. The vision and objectives outlined in the DPD align with the Commissioners' vision for a new neighbourhood 'The Beeches' on its land to the west of Southbourne (Scenario 1). Initial technical work undertaken by the Commissioners confirms the suitability, availability and deliverability of the site. The technical work has informed a concept masterplan, which is presented within a Vision Document 'Creating a Vision for The Beeches Land West & North of Southbourne'. The Vision Document has been submitted to accompany these Representations and has previously been shared with the Council to accompany Regulation 19 Representations to the Local Plan, submitted by Lichfields. The masterplan is for the development of a nature-led new neighbourhood which forms a logical and well-integrated extension to Southbourne. Informed by ongoing technical work, the Commissioners is developing a comprehensive and coordinated development approach of phased delivery to bring the site forwards effectively, in line with the vision set out in the DPD. [See attached document for full submission]
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I am responding to this email on behalf of the British Horse Society. The BHS is the UK's largest equestrian charity with 125,000 members and represents the country's 3.2 million horse riders. One of our charitable objectives is "to promote and secure the provision, protection and preservation of rights of way and of access for ridden and driven horses over public roads, highways, footpaths, bridleways, carriageways, public paths and other land." Almost 16,000 passported horses are owned by people living in the postcodes contained within Chichester District Council area, contributing in excess of £110 million" per annum to the economy, much of which is spent locally (feed, bedding, farriers, vets, riding instructors and riding schools, etc.). Horse riders have the right to access just 22% of the public rights of way network nationally, with substantially less for carriage drivers. Many of these routes are inaccessible or disconnected as a result of increased traffic and/or development. Research undertaken by the University of Brighton and Plumpton College on behalf of The British Horse Society found that More than two thirds (68%) of respondents participated in horse riding and associated activities for 30 minutes or more at least three times a week. Sport England estimates that such a level of sporting activity will help an individual achieve or exceed the government's recommended minimum level of physical activity. A range of evidence indicates the vast majority (90% plus) of horse riders are female and more than a third (37%) of the female riders of respondents were above 45 years of age. Horse riding is especially well placed to play a valuable role in initiatives to encourage increased physical activity amongst women of all ages. Amongst the horse riders who took part in the survey, 39% had taken no other form of physical activity in the last four weeks. This highlights the importance of riding to these people, who might otherwise be sedentary. Horse riders with a long-standing illness or disability who took part in the survey are able to undertake horse riding and associated activities at the same self-reported level of frequency and physical intensity as those without such an illness or disability. Planning Policy, etc. National Planning Policy Framework 96. Planning policies and decisions should aim to achieve healthy, inclusive and safe places and beautiful buildings which: enable and support healthy lifestyles, especially where this would address identified local health and well-being needs - for example through the provision of safe and accessible green infrastructure, sports facilities, local shops, access to healthier food, allotments and layouts that encourage walking and cycling. Including provision for equestrians within the "equal opportunities for all' referred to in Objectives 4.5 would make this objective truly equal. Pedestrian / cycle bridge 5.10. Across the scenarios there are opportunities to improve pedestrian and cycle connectivity, by either introducing new crossing points or improving the existing informal crossing points. Any crossings or improvement of informal crossings must include equestrians too, especially where onward connectivity is bridleway or otherwise suitable for equestrians. Road Safety Road Safety is a particular concern to equestrians, who are among the most vulnerable road users. Data shows that 3,383 road incidents involving horses were reported to the British Horse Society (BHS) in 2023. Among these, 66 horses died, 86 horses were injured; 3 people died and 94 people were injured because of road incidents. 85% of incidents occurred because a vehicle passed by too closely or too quickly. Research indicates however that only 1 in 10 incidents are being reported to the BHS. In 2021 alone, 3,288 horse riders and carriage drivers in England and Wales were admitted to hospital after being injured in transport accidents. (NHS Hospital Episodes Statistics). These figures demonstrate how important it is that planning authorities, developers, Highways and Strategic Transport understand the requirement for safe access for equestrians both on the roads and the links to the Public Rights of Way (PROW) Network. Safe crossings for all vulnerable road users over and connectivity beyond the A27 and A259 through Southbourne should be a priority for any non motorised user projects. Pedestrian/cycle routes can best be provided via a public bridleway which provides better value for the tax payer with more users accommodated and keeps more users safe. Sustrans Paths for Everyone "We want to see a UK-wide network of traffic-free paths for everyone, connecting cities, towns and countryside, loved by the communities they serve." The BHS is working with Sustrans to remove barriers to equestrian access wherever possible. Highway Code Rule 215 Along with information on how to pass horse riders and carriage drivers safely, the Code reminds road users that, "Horse riders are often children, SO take extra care and remember riders may ride in double file when escorting a young or inexperienced horse or rider." At the present time in too many areas we have the situation where a young child on their pony is afforded less protection than an older child or adult on their bike. West Sussex County Council Right of Way Management Plan (2018-2028) (extracts) "Ensuring visitors and local people alike have the opportunity to enjoy the beauty and tranquility of large parts of the West Sussex countryside is important. The rights of way network is a much valuable resource. It contributes to people being able to lead a healthy lifestyle whether enjoying the fresh air, appreciating wildlife and the landscape, improving fitness and well-being, exploring on foot, by bike or by horse, or simply to walk the dog." "The Council's Vision for PROW in West Sussex is: To enable people to enjoy the countryside on foot, by horse and by bicycle, for health, recreation and to access services, while recognising the need to balance this with the interests of those who live and work in the countryside and the management of special landscapes." "Horse riders - use local rides (bridleways, byways and quiet roads) where they exist for daily recreation and horse exercising. Whilst some horse riders box their horse to areas further afield, the majority of riders have no access to horse transport" "While bridleways and restricted byways on the chalk ridge of the South Downs provide good access for these users, the coastal plain has virtually no suitable access for horses." "In the north east of West Sussex, the limited bridleway network often lacks connectivity or is severed by the road network." "A starting point for new schemes will be to consider who could benefit from a new route, such as walkers, cyclists, horse-riders and the disabled, and be as inclusive as possible, often the aim will be to achieve at least bridleway status" It can be seen from the above that West Sussex County Council believes that equestrians are a user group for which provision is lacking in some areas and that the assumption for new provision is that bridleway status should be the minimum status. Equality Act 2010 The arguments for inclusivity of walkers and cyclists can be extended to equestrians using the mechanism of the Equality Duty. This is a form of discrimination, and the Equality Act 2010 created a Public Sector Equality Duty for organisations to provide equal opportunities for all, which means that an organisation needs a cogent reason for excluding equestrians. The majority of off-road routes can and should accommodate all non-motorised vulnerable road users - pedestrians, cyclists, equestrians and mobility buggy users. None of these users should be excluded and forced onto carriageways with the increased danger that entails. This would then mean they would be truly (non-mechanically propelled) multi-user routes (Multi-user has no legal definition and is often confused in its meaning but generally means all users, not only pedestrians.) The BHS considers it to mean all non-motorised users. Conclusion We ask, not that equestrians should receive special treatment, but that, for all the reasons stated above, they are not excluded from provision for other vulnerable road users. Housing development encompassing or connected to public rights of way should be required to upgrade footpaths to bridleways (or restricted byways) and routes ordinarily identified as walking/cycling routes on plans should be created as public bridleways and added to the definitive map, thereby giving clear identification of the protected status and the maintenance responsibilities. Road crossings and railway crossings need to be fully "multi modal" with connectivity for all to both sides. Highways improvements making provision for walkers and cyclists should also include equestrians unless there are cogent, irresolvable reasons for not doing SO. We acknowledge that active travel provision is likely to be biased towards utility journeys (or even just active commuting) BUT these same routes will still be used safely by walkers and cyclists for leisure purposes, especially those on the outskirts of towns and villages. Furthermore, this provision need not exclude equestrians even if specific provision cannot be made for them. We already know that, where safe access is available, people DO use their horses for active travel: to visit the farm shop, collect the children from school, place their vote, post a letter, withdraw cash from the ATM, etc. The BHS works in partnership with other user groups, local and central government to make rights of way and other access areas useful and open to all, and our roads safer for all users. In the same way, we would be more than willing to work with Chichester DC in this regard. [See attached document for full submission]
We already have an excessive and more than capacity amount of new build properties within the village. There is insufficient infrastructure to be able to cope with the additional specified amount of houses and Southbourne will no longer be a village. It is impossible to get appointments at the local Doctors surgery, the roads are too congested especially around school times and it also does'nt help with the amount of vehicles parked on the kerbside along Stein Road. We are also fed up with the constant daily noise and dust from the current housing estates that are being built.
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Natural England is broadly satisfied with the vision and objectives set out in the submitted document; however, we would support a stronger reference to protected landscapes in the vision given the developments location and the enhanced duty to 'seek to further the purpose' of National Landscapes (Section 245, Levelling-up and Regeneration Act 2023). Similarly, we would welcome clearer consideration of the need to ensure that any future development ensures that designated sites, protected species and priority habitats are safeguarded as far as practicable and are considered in line with paragraph 186 of the NPPF. Notwithstanding the above, Natural England supports the holistic approach to environmental matters within Section 4, and the inclusion of specific objectives relating to 'transport and sustainable travel', climate change moving towards net zero carbon living and the multifunctional benefits associated with the proposed continuous Green Ring.
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4.3 Add "including to the proposed ChEm route" after Active travel sentence 4.7. Add "Support construction of road bridge over railway to facilitate connection of A259 and ChEm route".
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We are disappointed that there is no reference within the vision to Southbourne's historic environment and numerous heritage assets. In view of the general comments above, we believe this is a weakness of the approach to planning the site in that the heritage significance of the proposed locations for development (both actual and potential) is not identified as a key characteristic of the area that may be impacted by allocation of land for development.
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1.3 Hallam control the land north of Gosden Green and west of Alfrey Close which is identified as a potential development location in the current consultation. As will be shown, the Hallam land should be included as an allocation in the Southbourne DPD regardless of which overarching scenario is taken forward, such are its locational merits and the absence of any genuine physical or environmental constraints. 1.4 On this occasion, our representations consider the following: Section 2: Planning policy context Section 3: The consultation documents options Section 4: The merits of the land north of Gosden Green 2 Planning policy context 2.5 Southbourne is an identified settlement in the both the adopted Local Plan and the emerging Local Plan suitable to accommodate new housing development and associated uses. The Southbourne Allocation DPD is being prepared within the context of and to accord with the emerging Local Plan, which, at the time of writing is subject to its examination. The emerging Local Plan is therefore highly germane. 2.6 The emerging Local Plan's spatial strategy is described at paragraph 3.5 to 3.28 of the submission version. Of particular note is the recognition in paragraph 3.6 that the spatial strategy needs to account for the urban and rural nature of the District and that, to an extent, a dispersed pattern of growth is necessary to "help sustain, enhance and make the area's city, towns and villages more self-supporting places to live and work". 2.7 Within this context, a logical driver is the importance of "locating development in areas which are well located to other uses, serviced by a choice of transport modes and accessible to the communities they serve". This is a cornerstone of the NPPF and its objective to promote sustainable patterns of growth (§109 refers). 2.8 The practical effect of this is that that Policy S1 intends that new development is concentrated in an east-west corridor in the south of the District (criterion 1 refers). Representations to the emerging Local Plan supported this approach, which, as a matter of principle, is soundly based. 2.9 Associated with this, Policy S2 establishes the settlement hierarchy. Chichester is the pre-eminent settlement in the District and the greatest amount of new development has been directed to edges of this historic city over successive plans. The extent to which Chichester can continue to grow is limited by environmental and physical and infrastructure constraints. 2.10 Alongside Chichester, settlement hubs are identified at East Wittering Bracklesham, Selsey. Southbourne and Tangmere. Map 3.1 identifies that East Wittering and Selsey relate to the Manhood Peninsula, whilst Southbourne and Tangmere are nodes at either end of the east-west corridor. Settlements Hubs are defined as secondary service centres providing "a reasonable range of employment, retail, social and community facilities serving the settlement and local catchment areas." 2.11 Alongside the emerging Local Plan, Background Paper 11 reveals the comparative performance of these four settlements. It is notable that Southbourne is the only one of the four settlements that has all of the facilities assessed. It is one of two settlements with a secondary school and is the only settlement with a train service. These are materially important characteristics in the context of locating new development close to services and facilities as is the intention of the spatial strategy as evident at paragraph 3.6. 2.12 Having regard to the first of the emerging Local Plan's strategic objectives - to mitigate and adapt to climate change - Southbourne is an accessible location where new development would benefit from access to public transport with less of a reliance on the private car. Where travel is a major contributor to such emissions, this is self-evidently important. 2.13 The above are plainly relevant to the Allocations DPD; it is an especially important DPD as it is relied upon to deliver a significant element of future housing to meet the District's identified needs broadly a third of the residual requirement necessary by 2039 are to be provided at Southbourne. In determining where new development should be provided, the DPD must provide certainty of deliverability and a contribution to sustainable patterns of development. 3 The consultation document's options 3.1 The consultation document proposes three options as to how the required amount of new development can be provided. It focuses on a spatial distribution - land to the west, land to the east and land to the north, which purports to be a mixed scenario. 3.2 It is instructive that the consultation document is based on meeting an identified need of 1000 new homes. Allowing for commitments, this refers to a residual requirement of approximately 800 new homes. 3.3 Of course, the selection of a location for new development should consider the most effective use during the plan period and beyond and is not necessarily bound by a single figure. This is especially the case where the emerging Local Plan has adopted a constrained approach to housing provision based on infrastructure capacity and Policy H1 is expressed as a minimum requirement for the District in any event. This is underscored by the fact that the District's housing requirement is expected to increase under the terms of the proposed revisions to the NPPF's standard method. 3.4 In other words, if an option exists that provides for more than the residual requirement adopting this would represent a positive approach to planning. [See attached document for full submission]
Thank you for the opportunity to comment on the above consultation. As you will be aware, we raised concern regarding the potential impacts of increased traffic arising from the level of growth in the Chichester northern plan area on the highway network in Waverley Borough, and it was agreed that recent housing growth, particularly in the Alfold area, will require continued liaison. However, as the Southbourne Broad Location for Development (BLD) is located in the south of the district, we have no concerns to raise regarding this consultation document. We are pleased to see that the Southbourne Allocation DPD seeks to deliver the requirements for the BLD as identified in the emerging Local Plan.
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Southbourne Allocation DPD Vision 2.1 Metis is generally supportive of the Vision for Southbourne. However, as discussed at the Local Plan Examination Hearings (October 2024), the use of the word “comprehensive” should not prevent development from coming forward in stages; reflecting different land ownerships and the delivery of smaller scale sites to maintain ongoing housing land supply. It is suggested that “comprehensive” is replaced with “coordinated” as this does not prevent sites from coming forward independently of each other but will still ensure that each phase helps meet the overall Vision. Southbourne Allocation DPD Objectives 2.2 Metis is supportive of the Objectives, particularly the focus on active travel and enabling public transport improvements to ensure climate reliance and positive contributions towards achieving net zero lifestyles. This is consistent with paragraph 11a of the National Planning Policy Framework (NPPF) which states that, “all plans should promote a sustainable pattern of development that seeks to: meet the development needs of their area; align growth and infrastructure; improve the environment; mitigate climate change (including by making effective use of land in urban areas) and adapt to its effects” 2.3 Objectives 3 and 4 are also consistent with paragraphs 108 (c and d) and 109 of the NPPF which promote sustainable transport: 108 “Transport issues should be considered from the earliest stages of plan-making and development proposals, so that: c) opportunities to promote walking, cycling and public transport use are identified and pursued; d) the environmental impacts of traffic and transport infrastructure can be identified, assessed and taken into account – including appropriate opportunities for avoiding and mitigating any adverse effects, and for net environmental gains; 109 “The planning system should actively manage patterns of growth in support of these objectives. Significant development should be focused on locations which are or can be made sustainable, through limiting the need to travel and offering a genuine choice of transport modes. This can help to reduce congestion and emissions, and improve air quality and public health. 2.4 We also support the objective which promotes housing for all and the need to ensure a range of housing and tenure types. Affordable housing delivery is particularly important in this respect given challenging affordability issues in the district. 2.5 Whilst Metis support the Vision and Objectives, when considering how best to achieve these Objectives and having regard to the characteristics of Southbourne as a settlement, we believe that the suggested Scenarios (1-3) are fundamentally flawed. The starting position should be to maximise the development potential south of the railway line, and only then consider where to place the residual development north of the railway line. Alongside this, there should be a focus on providing pedestrian and cycle connections to link development north and south of the railway line rather than new vehicular routes. This would ensure that consistency with paragraphs 11a, 108c and d and 109 of the NPPF are filtered down from the Vision and Objectives to the policies which will deliver development. This approach is also consistent with the the Council’s transport strategy for the emerging Local Plan Review 2021-2039 where Policy T1 acknowledges that it is neither viable nor practical to increase junction capacity on the A27 to accommodate the planned level of growth. Therefore, the transport strategy is instead based on adopting targeted measures to reduce vehicular traffic generation on the A27. This is referred to as a ‘Monitor and Manage’ approach, whereby modal shift is promoted through sustainable and active travel improvements. These measures will be exhausted before considering measures to increase junction capacity and operational improvements for vehicular traffic. This view is outlined in the accompanying report from Paul Basham Associates (PBA) at Appendix A. 2.6 As proposed, two of the Scenarios rely on a new vehicular bridge over the railway line. It is immediately apparent that the construction of a vehicular bridge does not support either the Vision or the broad Objectives. In fact, the construction of a vehicular bridge directly conflicts with many of these Objectives and Policy T1 of the emerging Local Plan Review, encouraging short distance vehicle trips and undermining options for sustainable travel. In addition, given the marginal viability position, the cost of a new multi-modal bridge will divert financial resources way from affordable housing, compromising the delivery of Objective 2 - housing for all. Proposed Amendments 2.7 These representations provide two alternative Scenarios to those presented in the DPD (identified as Scenarios 4 and 5). These maximise the development potential south of the railway line and close to existing services and facilities, reducing the amount of development required north of the railway line and alleviating peak time congestion issues. This will allow the existing crossings to operate safely and efficiently for the planned level of development without the need for a multi-modal bridge and reduce the viability issues identified in the consultation document. Further detail regarding these Scenarios is provided in response to the consultation questions below. However, for clarity, the way in which these suggested Scenarios respond better to the Vision and Objectives, is summarised here: Integrated and well serviced community 2.8 The available land south of the railway line in Scenario 1 and 2 is already well served by existing facilities and amenities, including access to high frequency rail and bus services and a strategic cycle route. Maximising development opportunities to the south of the railway line will ensure that development can be delivered in a sustainable manner in the shorter term. This will ensure that the existing facilities and amenities, concentrated south of the railway line on then A259 corridor, are supported alongside a new local centre to the north of the railway line providing complementary services. Proposed Scenarios 4 and 5 shows the provision of pedestrian and cycle connections, where land has already been safeguarded for this purpose. This would ensure that the community (north and south of the railway line) is well connected to existing and new facilities. It would also provide a more positive approach to placemaking. Housing for all 2.9 By focusing on the provision of complementary services and amenities (limiting duplication) and the provision of pedestrian and cycle connections (avoiding the cost of a multi-modal bridge) the viability of development will be improved to ensure no unnecessary reduction in affordable housing delivery. Transport and sustainable travel 2.10 The Council’s transport strategy for the Local Plan (Policy T1) is based on adopting measures which seek to reduce traffic generation on the A27 (Monitor and Manage). In this respect, provision of infrastructure that encourages vehicle use should be the last resort having exhausted all other sustainable transport measures. In this case the Council’s evidence (Stantec, March 2023) confirms that a vehicular bridge is not required without other mitigation in place and our analysis (PBA, December 2024) further emphasises this. Setting aside the implications on viability, to include a multi-modal bridge in two of the Scenarios is entirely unjustified and completely undermines the overall transport strategy. The provision of a multimodal bridge is based on estimates of traffic generation from additional development north of the railway line. Even with the Scenarios as presented, (including Scenario 3 with 800 dwellings north of railway line), there is no highway capacity justification for a bridge. By maximising development potential south of the railway line, the level of development north of the railway line can be limited to 600 dwellings. This is significantly below the threshold in the Council’s evidence (Stantec, March 2023), which overestimates the traffic impacts of planned development on crossings based on our more recent analysis (PBA, December 2024). 2.11 To reduce vehicular traffic in line with the Local Plan transport strategy (Policy T1), the allocation should focus on pedestrian and cycle connections and connectivity to existing public transport services. Land has been safeguarded for the provision of pedestrian and cycle bridges on both sides of the settlement, where one of these connections can be provided as part of an allocation. Provision of a pedestrian and cycle connection over the railway line would provide genuine opportunities for walking and cycling, and in doing so promote sustainable travel choices in line with Policy T1 and the NPPF. It would also encourage existing residents to access existing and proposed facilities and services in Southbourne by walking and cycling. 2.12 The provision of the CHEMROUTE, in combination with contributions from other planned development on the East-West Corridor, would provide onward cycle connectivity to Chichester and Emsworth, to further align with the Local Plan transport strategy (Policy T1) and have the additional benefit of providing sustainable travel choices to the significant existing population that live along this corridor. This would materially reduce traffic generation on the A27 and the two priority junctions at Warblington and Fishbourne. Climate change and moving towards net zero carbon living 2.13 Meeting the policy requirements of the emerging local plan, the NPPF and current building regulations will contribute towards achieving carbon reduction and mitigating the impact of development on climate change. These measures could include but are not limited to: • A 'fabric first' approach to ensure buildings are constructed with sustainably-sourced materials and delivering good energy performance • Electric vehicle charging points for residents and visitors • Measures to achieve reductions in energy and water consumption • Green roofs on garaging to provide opportunities for biodiversity enhancement and reduction of surface water run-off from the development. • Biodiversity Net Gain to ensure that the natural environment is left in a measurably better condition following development. 2.14 Locating development where it can benefit from existing facilities and services, and public transport opportunities, should be the starting point. Maximising development opportunities to the south of the railway line should be the focus for all Scenarios. Where new development needs to be provided to the north of the railway line, it would be logical to focus on one side of the settlement where new facilities can be concentrated, and a single pedestrian and cycle bridge can provide a connection. 2.15 One of the most significant environmental impacts from the planned development will be emissions from the vehicular traffic associated with the development during its operational stage. In this respect, it is critical that opportunities to reduce vehicular traffic are taken. As noted above, this would also align with the Local Plan transport strategy (Policy T1). The provision of an unjustified and unviable vehicular bridge would be completely at odds with this objective. Alternatively, the provision a pedestrian and cycle bridge on safeguarded land together with delivery of the CHEMROUTE would ensure that vehicular traffic and associated emissions are minimised in respect of planned development and reduced in respect of the existing population. Environment 2.16 Maximising development potential south of the railway line would not undermine the stated Objectives. The land to the east of the settlement and south of the railway line is completely unconstrained when considering the stated environmental Objectives and could provide circa 100 - 125 dwellings using an average density of 20-25dph The land to the west of the settlement and south of the railway line provides secondary Brent Geese habitat, but this can be mitigated alongside circa 100 – 125 dwellings using the same average density range. Character 2.17 The existing undeveloped land between the A259 and the railway line is largely contained in the wider landscape where residential development at a scale of 2/3 storeys will not have a significant impact on the landscape (including the AONB to the south). This has been endorsed in various recent appeal decisions. Therefore, maximising development opportunities to the south of the railway line has the benefit of reducing the amount of development to the north of the railway line where the character is more rural, open and sensitive to landscape change – noting also that the openness of the landscape in northern portion of the BLD is likely to feature in long distance views from the South Downs National Park. 2.18 In conclusion, the proposed Scenarios (1-3) do not promote a sustainable pattern of development in accordance with the stated Vision and Objectives. For the same reasons, these Scenarios are in conflict with the overarching sustainability principles of the NPPF. The proposals, which rely on car led Scenarios, are in particular conflict with paragraph 11a of the Framework which among other things, seek to, “improve the environment; mitigate climate change (including by making effective use of land in urban areas) and adapt to its effects”. 2.19 This means there is also a conflict with paragraph 16a which states that, “Plans should a) be prepared with the objective of contributing to the achievement of sustainable development” 2.20 The alternative Scenarios (4 and 5) promoted by Metis overcome these conflicts by promoting sustainable travel (walking and cycling), whilst also locating development close to the existing bus services on the A259 and close to the railway station. In turn, this will have a positive effect on improving the environment, mitigating climate change (including by making effective use of land in more contained urban areas) and adapting to its effects (paragraph 11a). Therefore, the suggested Scenarios 4 and 5 constitute sustainable development in accordance with paragraph 16a of the Framework. It is in this context that the responses to the consultation questions are framed. We do not consider that Scenarios 1- 3 meet the tests of soundness as set out at paragraph 35 of the NPPF. In particular, the proposals are not considered justified (b) or consistent with national policy (d). 2.21 Paragraph 35b of the NPPF requires that plans are justified, providing, “an appropriate strategy, taking into account the reasonable alternatives, and based on proportionate evidence”. 2.22 Metis have provided two alternative Scenarios is Section 6 of these representations. As demonstrated, these provide an effective and justified strategy for the delivery of development in accordance with Policy A13 of the emerging Local Plan Review: providing credible alternatives to a car led Scenario. Analysis of the Council’s own evidence (transport and viability) demonstrates that there is no justification for a multimodal bridge. The starting point when considering alternatives should have been Scenarios which do not promote the bridge – as presented in Scenarios 4 and 5 below. 2.23 Paragraph 35d of the NPPF requires that plans are consistent with national policy, “enabling the delivery of sustainable development in accordance with the policies in this Framework and other statements of national planning policy, where relevant’. 2.24 For the reasons set out above (paragraphs 2.18 – 2.19), it is not considered that the proposed Scenarios will deliver sustainable development in accordance with other policies of the Framework. Consequently, it is not considered that any of the Scenarios presented in the DPD would meet the tests of soundness as set out in the NPPF [See attached document for full submission]
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This note sets out West Sussex County Council’s (WSCC) officer level response to the consultation on the Southbourne Allocation Development Plan Document (DPD) and associated documents. It highlights key issues and suggested changes to which Chichester District Council (CDC) is requested to give consideration. We will continue to work with CDC in the preparation of the Southbourne Allocation DPD regarding WSCC service requirements in order to mitigate planned development, as it evolves. Minerals and Waste Reference should be made to the Joint Minerals Local Plan, 2018 (Partial Review, 2021) – JMLP and the West Sussex Waste Local Plan (2014) - WLP. All three development scenarios fall within the sharp sand and gravel Minerals Safeguarding Area (MSA) and any proposals within the MSA will need to accord with Policy M9 (Safeguarding Minerals) of the JMLP and the associated Minerals and Waste Safeguarding Guidance. Any policy relating to development in these locations will need to include a criteria/development principle to ensure the safeguarding of minerals is taken into consideration. Policy W23 (Waste Management in Development) of the WLP also requires the design and layout of new development to complement sustainable waste management and this should also be reflected in the DPD. Vision: In order to access some services, there will be a need to travel beyond Southbourne. The West Sussex Transport Plan advocates a vision-led approach to development planning that prioritises sustainable modes of transport and plans to achieve a high sustainable transport mode share for the location and type of development. The county council considers the vision for access/ movement should make reference to using the existing railway station and A259 as main access routes with enhanced bus and active travel facilities to enable sustainable travel behaviour. Para 5.8 refers to a multi modal bridge being required to address traffic congestion if 800 homes approx. were delivered. The wording within this paragraph appears a little open. The provision of a multi-modal bridge will have a significant cost implication for any development/s as well as a sizeable footprint impacting potential on the scale of development that will be achievable. There is the further concern that a single development may not come forward that may then be required to deliver the bridge; as has already been the case, with there being a number of permitted development parcels within areas forming part of the potential allocation that have come forward without needing to contribute to or provide the bridge. It is also unclear whether both level crossings would be closed, if so what is the impact on north / south walking and cycling journeys. CDC should work with Network Rail to ensure that any changes to the level crossings that would be needed as a result of the development are understood at an early stage and can be taken into account in planning the site and associated infrastructure. There should be much greater clarity on whether or not a bridge will form part of the development and the means by which it will be delivered. [See attached document for full submission]
I live in Emsworth, just across the Chichester/Hampshire. I went to the open session at Southbourne church on Nov 20th. I was dismayed to find apparently no awareness of Havant Borough Councils plans for 2,500 new houses at Southleigh just across the border. Meanwhile you are planning 1,200 at Southbourne in addition to all the already approved developments along the A259 The inevitable consequences will be disastrous and include: Highways In the absence of agreed funding for any new links with the A27 we all face the prospect of, at the very least another 6,000plus cars joining the A259 from the north and heading either east or west. The road between Emsworth and Fishbourne and the roundabouts will be gridlocked. Sewage/flooding It is well known that Southern Water’s Waste Water Treatment facilities are completely overloaded, sewage spills are routine and Chichester Harbour and the Chalk Streams are poisoned. Building on the flood plain and on land which already floods already will only make matters worse. Wildlife is being decimated and not even the planned very limited corridors can possibly retain thriving populations of all the creatures on which our ecosystem depends. Schools, surgeries etc are already overloaded. Solutions Work with Havant to Insist on infrastructure development prior to any more new build because the wholly forseeable consequences for future residents of both Chichester and Havant will be tragic. Impose Grampian clauses on all new properties to ensure connection to Southern Waters’s services cannot be made until the capacity is developed. Reuse/refurb existing buildings and brownfield sites, with some densification, to preserve as much open land for wildlife as possible. Permit only the houses required for local need including to facilitate downsizing, and employ measures to limit inward migration and the proliferation of second homes. Local feelings run very high on these issues so thank you for the opportunity to comment. I will copy these comments to our local MP’s as these issues stem from Gov as well as District plans and targets.
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National and Local Context We note that the content sections do not acknowledge two key matters in regards the South Downs National Park and we ask that these two matters are reflected. Firstly, the relationship between the South Downs National Park, this area in the East-West corridor and the Chichester Harbour National Landscape. As raised in our response to the Chichester Local Plan Review 2035 Regulation 19 Consultation, this is a sensitive stretch of land in the coastal plain between the coast, the south coast railway and the A27. This corridor provides the connection, including intervisibility, between the protected landscapes of the South Downs National Park and Chichester Harbour National Landscape, for example views of the channels within the Harbour from the Trundle and Stoke Clump. Secondly, the National Parks & Access to the Countryside Act 1949, as amended by Section 245 of the Levelling Up & Regeneration Act (LURA) 2023, requires all relevant bodies - including Chichester District Council (CDC) - to seek to further the purposes of the South Downs National Park (SDNP). This duty is important context for CDC in the preparation of this DPD. Vision and Objectives Question I - Do you agree with the vision and objectives set out? Response: We welcome and support this objective in the Southbourne DPD. As raised in our response to the Chichester Local Plan Review 2035 Regulation 19 Consultation, this is a sensitive stretch of land in the coastal plain between the coast, the south coast railway and the A27. This corridor provides the connection, including intervisibility, between the protected landscapes of the South Downs National Park and Chichester Harbour National Landscape, for example views of the channels within the Harbour from the Trundle and Stoke Clump. The principles set out in this objective, such as integrating development into the wider landscape setting will be important to address the sensitivity of this location between the two protected landscapes. Welcome reference to the South Downs National Park in 4.10 as part of the DPD objective on character. However, we advise adding 'and their setting' as set out below in order to appropriately reflect both the paragraph 189 NPPF December 2024 and the S245 Duty; the National Parks & Access to the Countryside Act 1949, as amended by Section 245 of the Levelling Up & Regeneration Act (LURA) 2023, requires all relevant bodies - including Chichester District Council (CDC) - to seek to further the purposes of the South Downs National Park (SDNP). 'Harmoniously integrating development into the wider landscape setting, protecting and mitigating impact on views and character of the Chichester Harbour National Landscape and South Downs National Park, and their settings. Create a built form that is influenced by and respects the local character and heritage whilst using best practice design principles."
We support the proposed inclusion of a vision and objectives within the SADPD which have been informed by the Neighbourhood Plan and the emerging Local Plan. As with our above comments, any changes to the emerging Local Plan should be reflected in the SADPD. Whilst we broadly support the SADPD Vision, we note that the Neighbourhood Plan also recognises the wider role played by Southbourne as a focal point for the Bournes area. This should be reflected in the SADPD Vision. We note the objective in respect of “housing for all” highlights a number of different forms of housing. Notably no mention is made of the need for market housing both to meet housing needs (including for the wider area) and the role of market housing in supporting the delivery of affordable housing and other forms of infrastructure provision. The objective should therefore be updated to also refer to the provision of market housing. As set out in the accompanying i-Transport response (Appendix Two), the “transport and sustainable travel” objective is overly focused on connections to the railway station. Reference should also be made to bus stops and other key amenities. Reference should be made to providing direct walking and cycling routes to multiple points of access into the site, so as to minimise walking distances and thus increase the likelihood of making trips by walking or cycling. Doing so would accord with the first two bullets of paragraph 114 of the NPPF. [See attached document for full submission]
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Whilst most of the vision and objective detailed sounds positive, it is impossible to achieve in my opinion. 1) You can’t double the size of a village in to a small town and retain the character. 2) The SDNP and Chichester Harbour conservation area (Between which the new development will be squeezed) will be negatively impacted both in visual aspects and by light pollution. 3) Wildlife will be displaced from their natural habitat. 4) I have seen no evidence whatsoever that this community needs 1100 new houses. 5) The houses being built are within a narrow corridor that simply does not have the infrastructure to accommodate the increase in traffic demands.
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3.6. Bloor is generally supportive of the Southbourne DPD vision and objectives. Specifically, the vision and objectives detailed are consistent with a number of the facets of sustainable development. 3.7. It is clear however that the key will rest on successful translation of both the vision and principles into a means against which to assess relevant planning applications. This will require a degree of flexibility and pragmatism to be imbedded within the final DPD document, which recognises that not all sites may contribute towards the vision and objectives in an equal manner. For example, it will need to be recognised that not all sites may be suitable for providing a range of housing types. Additionally, it will need to be acknowledged that schemes benefiting from an outline planning consent prior to the emergence of this DPD, may not be able to demonstrate full accordance within the DPD given the differing policy environment in which they were consented. [See attached document for full submission]
So, now we have in front of us a 'plan' for Southbourne's ARMAGEDDON! '1000' extra houses accommodating '4000' people, all to be situated north of the railway line! What is ANYONE thinking? Certainly not about the impact of such proposals and their effect on existing (and future) residents. Certainly not on the impact on nature and biodiversity. Certainly not on the need for local food production to counteract food miles in a county which has declared a Climate Emergency! It seems to be a case of just lazy incompetence. 'Stick a pin in a map and that's where (much needed, in the global sense) housing will be built and we will let the developers 'loose' to decide how, what and where they build seems to be the limit of planners' thinking processes. No serious thought given to infrastructure, facilities and services needed to support such a level of build and none given to the affect on peoples' well- being by being crowded into such a small area and the loss of open space for exercise and enjoyment. Still, it 'gets the numbers' and that is what it is all about. What is even worse is that it is no use even protesting. The decision is made, the die is cast. The new 'democracy'! ARMAGEDDON for Southbourne is almost here! Yours in absolute disgust! PS. I attended yesterday's exhibition - at least, that was my intention. Why such a small room? It took several minutes of patient waiting to get near the first two display boards on the north side and, even then, one could only look over the shoulders of others which made it impossible to read the key to the coloured shading. Another few minutes waiting to try to get near the boards on the west side, but I failed to do SO. I gave up! Spoke to one of the 'peeling name-badged' people about it, whose response was a shrug of the shoulders. Had the issue been down to huge numbers attending, I would have understood. But, around twenty? Poorly thought out and managed. Should have guessed, really.
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National Highways has been appointed by the Secretary of State for Transport as strategic highway company under the provisions of the Infrastructure Act 2015 and is the highway authority, traffic authority and street authority for the strategic road network (SRN). The SRN is a critical national asset and as such Highways England works to ensure that it operates and is managed in the public interest, both in respect of current activities and needs as well as in providing effective stewardship of its long-term operation and integrity. We will therefore be concerned with policies and proposals that have the potential to impact the safe and efficient operation of the SRN. In the case of Southbourne, our interest relates to the A27 which runs along the northern boundary of the Parish. We note that the submission Chichester District Local Plan 2021-2023 Policy A13 identifies 1,050 new dwellings to be allocated within Southbourne. The Southbourne Allocation DPD seeks to allocate specific sites for this housing quantum, and having deducted newly consented housing developments from the 1,050 total allocation, proposes 3 alternative scenarios to provide a total of around 500 dwellings. National Highways does not wish to comment on the three scenarios under consideration.
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The County Council will not be providing comments on each of the proposed site scenarios or indicate a preferred site option at this stage. Instead, I refer to the comments made as part of the evidence submitted for the Examination in Public, (document reference: M4a.16). This document sets out the County Council's position on Policy A13 Southbourne: Broad Location for Development, including potential highway impacts on the A259 and emerging associated mitigation schemes. The County Council would like to be continually engaged with Chichester District Council as the preferred site option develops, to ensure that any possible cross- boundary issues affecting Hampshire are identified and mitigated. I trust that these comments are of assistance to you. If you have any queries, or wish to discuss this response in further detail, please do not hesitate to contact me. [See attached document for full submission]
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 which 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 IN THE JAMS IS MERELY WISHING TO 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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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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We have looked into this and have determined that the boundaries of Southbourne Parish Council are outside of South East Water’s supply area. Based on this, we are not able to comment on housing numbers as that would be applicable for our colleagues in Southern Water and Portsmouth Water as well as any comments related to infrastructure reinforcement to accommodate the future growth.
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