5.22. Questions for Regulation 18 consultation:
This proposal makes sense because it is in Southbourne not Nutbourne (like the other 2 proposals) and it will enable the development of the Southbourne village by adding to existing developments and infrastructure and further create a suitable hub.
The flood risk is being glossed over in all 3 proposals and all the talk of creating a ‘Green Ring’ misses the fact that Southbourne already has a “Green Ring’ as it is surrounded at the moment by arable land with footpaths.
Why wouldn’t a vehicular bridge be built as part of this scenario? It would be cost effective and alleviate the already increasing traffic congestion at the Stein Road level crossing. Scenarios one if correctly thought out and constructed would deliver what Southbourne requires whilst protecting the rural nature of Nutbourne which is a separate village.
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Paragraph 5.14: Whilst the 'Green Ring' is construed as an aim - Scenario 1 as presented fails to deliver in toto. Paragraph 5.15 suggests 'There are multiple landowners to the south of the railway line. Consequently, some additional co-ordination and negotiation with the different landowners is still likely to be required.' Has this negotiation been started / concluded - can this be demonstrated as viable? Paragraph 5.16 suggests 'A key challenge of this scenario is the need to accommodate an existing gas pipeline that runs through much of the north side of this scenario. If development cannot take place within this zone, this could potentially push development closer to the landscape gap addressed in the Landscape Gap Assessment completed for Chichester District Council in 2019. Landscape Gaps will be defined within the DPD Document.' IF development cannot take place in this area will how this influence the Landscape Gap? Paragraph 5.18 suggest that 'Additional vehicular access points south of the Southbourne College could potentially be achieved but rely on third party land.' There is no indication if this land is available to the development (in a viable manner). Paragraph 5.20: 'This scenario has a direct impact on a Brent Geese Secondary Support Area which would need to be comprehensively mitigated as set out by the Solent Wader and Brent Goose Strategy Guidance on Mitigation and Off-setting Requirements Report of 2018.' Does the evidence base suggest this is a viable proposition - particularly when read with paragraph 5.16 regarding closure of the landscape gaps?
Challenge: Increased traffic congestion created by putting all Schools and Community Facilities together. The answers to my comments to Question 2 above all present deeper challenges - particularly underpinned by viability and deliverability.
Traffic Congestion principally at Stein Road Level Crossing; secondly at Inlands Road Level Crossing. Increased risk to informal pedestrian level crossing at Church footpath (as pp. 5.19).
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No answer given
Challenges: -Inadequate sewage capacity -Water extraction -Congestion (particularly onto the A259 and around the new proposed schools). - capacity for the GP surgery
The absence of a vehicular bridge over the railway line poses several challenges and issues, o Without a vehicular bridge, the two proposed access points become less effective, potentially isolating the new development from the existing village and wider area. o Increased reliance on the pedestrian and cycling bridge may strain its capacity, especially if vehicular access is not available for residents, emergency services, and delivery vehicles. o Additional footfall and traffic from the new development may overwhelm existing road infrastructure, leading to congestion in nearby areas, particularly if alternative routes are indirect or inadequate. o A vehicular bridge facilitates seamless integration of the new development with the village, fostering access to the community hub and educational facilities. Its absence may reduce the effectiveness of the community consolidation efforts. o Without a vehicular bridge, other routes around the railway line might become overused, potentially impacting the nearby green spaces and ecological areas, including the Brent Geese Secondary Support Area. o Emergency services might face delays without a direct vehicular route, which could have serious safety implications for residents and visitors. o A lack of a vehicular bridge could hinder the overall deliverability of the development scenario, reducing its appeal to stakeholders and developers who value strong access and connectivity. Mitigation strategies would need to include: • Strengthening pedestrian and cycling infrastructure to ensure it can handle increased usage. • Enhancing existing roadways around the railway line to support indirect vehicular routes. • Coordinating with utility providers to address the constraints posed by the gas pipeline consultation zone. • Ensuring robust flood mitigation measures for alternative access points. • Balancing the development with efforts to minimize agricultural land loss and protect green spaces. In conclusion, while the pedestrian and cycling bridge offers some connectivity benefits, the lack of a vehicular bridge would create significant logistical, social, and environmental challenges that may compromise the success and functionality of the proposed development.
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Please see DPD Response 25.22, 5.34, and 5.47 a pdf file uploaded with question 4.11
Please see DPD Response 25.22, 5.34, and 5.47 a pdf file uploaded with question 4.11
Please see DPD Response 25.22, 5.34, and 5.47 a pdf file uploaded with question 4.11
This is the only viable option, but a vehicular bridge is a mandatory pre-requisite if this is to be a viable option. You cannot say that a bridge 'might be required' when the alternative is to route 800+ cars onto Stein Road, with the vast majority of these heading Southbound onto the A259. The Stein Road Railway crossing is already an issue with long traffic tailbacks at peak times, and with the barriers down for 20 minutes in any given hour, and there is already conflict between cars and pedestrians/cyclists during the school run... we have had two children run over an injured in from of our house. During the school run the South side of the crossing is effectively one lane due to parked cars - it's often effectively one lane for much of the day, but it is very bad around 9am and 4pm. The additional traffic is unlikely to head North as Westbourne is also effectively one lane through Whitechimney Road and East Street. There is also no mention of the issues connecting new housing to the sewage network with the Thornham site at capacity... we have already had issues with overflowing raw sewage in Southbourne and in Nutbourne.
Challenges: - TRAFFIC ... this needs to be explicit. If you don't build a road bridge 800 new houses will ruin Southbourne - SEWAGE ... my understanding is that Southern Water cannot object to new development and just have to cope with it, and this has long been an excuse to ignore this challenge, with this set of documents particularly egregious in this regard. Last year we had tankers pumping sewage for 10 days in Stein Road, with gardens near the station flooded with raw sewage, and Farm Lane in Nutbourne is regularly awash in raw sewage leading to significant harm to the Chichester Harbour (SPA) which is now regularly unsafe for bathing. - the 'Brent Geese Secondary Support Area' seems to have been added to make this scenaro less attractive as an option compared to the other two (worse) options... in 30 years I have never seen Brent Geese there, though we see them every year at Prinsted.
If there wasn't a vehicular bridge over the railway line then 800+ additional cars will exit onto Stein Road and join a huge tailback which will gridlock the village, generating a huge volume of additional air and noise pollution for the residents of Stein Road and DISCOURAGING active travel as people will not feel safe to ride through this traffic... I find the gridlock periods off-putting and I used to commute this route for 200 days each year. Without a bridge you will fail to meet the objectives (e.g. the 'integrated village' will be cut in two by backed-up traffic, the pedestrian and cyce routes to the station will be harmed, you will set back air quality and noise pollution levels, make walking for short journeys less attractive and generally degrade the village environment. The 'vision' means nothing if you fail this badly.
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The proposal ignores the site for 84dwellings North of Hermitage, already given approval (despite an on-site inspection deciding the application should be rejected.) This effectively links Hermitage with Southbourne and extends the developed area further west than shown. The lack of information about the location of the gas pipeline Makes it impossible to comment effectively. No reference is made to the impact of additional westbound traffic and residents already finding it difficult to exit from North of A 259 onto the road.
See above. Reference is Made to improvements in the railway crossing North of the proposal but what about the crossing North of the 84dwellings already given permission. Surface water flood risk is both North and South of the railway line. Flood water, and sewage escapes from Manholes, already features during high rainfall when water from the Downs flows South. Loss of the high quality agricultural land to hard surfaces will inevitably make this worse. No reference is made to the need and location of improved water treatment facilities. This is critical.
Lack of a bridge (and access onto A27) will result in increased congestion South on Stein road and development of "rat runs" in villages (eg. Westbourne) North of the A27. With, or without, a bridge the increased traffic flow West on the A259 will make the already difficult access onto the A259 at Hermitage much worse. Is there really sufficient and available for such a bridge in this location?
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I don't think a landscape corridor that provides a spatial + visual gap of 100m is enough. There should be clear space between Southbourne and Hermitage and to build + eliminate this gap is not what residents want.
Loss of prime agricultural land. If fields are built on, where are the 800 homes going to get food? we cannot just keep building on agricultural land. we should protect our land - not build on it. Southbourne as a parish has already decided that development should be to the EAST of the parish All the comments about why it should be to the East still apply.
If there wasn't a bridge, then this new traffic would have to use Stein Road which is already a disaster. it just won't work without a new bridge
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All three of the scenario maps should show the proposed CHEM route along the A259
Benefit This is the only scenario which shows pedestrian cycle route connectivity to the A259/CHEM route
Developers would have difficulty selling properties without a vehicular bridge over the railway line
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The Commissioners largely agree with the list of benefits identified in the DPD and are confident that the challenges identified can be suitably addressed and mitigated in ways that will contribute to the overall quality and character of the development. The technical work undertaken to date confirms that these benefits are feasible and deliverable, and that the challenges can be mitigated. The Vision Document demonstrates how this can be achieved. The Commissioners' concept masterplan for the site shows that a new primary school and community centre can be located near the Stein Road, and a proposed new access to the north. This new hub would accommodate the majority of non-residential uses which could include shops, community spaces, workspace, care and retirement living. As is recognised in the DPD, this is an opportunity to provide consolidated facilities close to the Bourne Community College in a location that can be safely and easily accessed by active travel routes, to encourage maximised use for the benefit of both new and existing residents. There are multiple opportunities to create walking and cycling connections into the existing village. Scenario 1 has potential to address the existing unsafe pedestrian rail crossing through the delivery of a multimodal bridge on safeguarded land to the south of the railway line as well as a new access from Stein Road in the north. New permeable links could then be extended across the development from the new access points. The Commissioners considers that this constitutes a significant benefit that makes Scenario 1 more deliverable than the other Scenarios. We respond further in relation to the delivery of a multimodal bridge in response to Question 4 below. The new walking and cycling routes proposed will weave through the landscape as part of the Green Ring. The DPD includes the delivery of the western section of the Green Ring as a benefit. The delivery of the Green Ring is part of the unique and responsive landscape framework that has been carefully developed for this Scenario, explained in the Vision Document. The DPD recognises that all development would be within proximity to quality green open space. The Commissioners' concept masterplan includes approximately 31ha of open space and diverse habitats. The Commissioners considers that this nature-led landscape framework is an essential part of delivering development that meets the Council's vision and objectives, which should be considered a key benefit. The concept masterplan includes an inner green ring to create immediate accessible-open space around the existing core of the village and the proposed new school and community hub area. Chapter 5 of the Assessment Framework assesses the potential for improved connectivity and integration between the new and existing village as poor, and specifically notes that the education land could create a barrier. This inner green ring has been proposed to mitigate this challenge by providing key pedestrian and cycle movement routes. The Commissioners' concept masterplan features an outer green ring, which will be connected to the inner green ring and parcels of open space by green corridors and existing PROWs which will be retained and enhanced. The DPD identifies the need to accommodate an existing gas pipeline that runs through much of the north side of this scenario as a challenge. We note that this would be an issue affecting all Scenarios. This has been accommodated within the concept masterplan which takes the opportunity to integrate the gas main area within the outer green ring. The gas main area passes east- west through the site. It limits the northern extent of development and instead provides a linear northern parkland area for recreation and diverse habitat provision, including Biodiversity Net Gain. The DPD identifies that development in Scenario 1 involves an area identified as part of the gap from the Landscape Gap Assessment (CDC 2019). A landscape corridor at the western edge of this scenario forms part of the outer green ring and will provide a spatial and visual gap to the north of the railway line; and open space provides a landscape buffer of 100 metres south of the railway. The green infrastructure proposals ensure that there will be suitable buffering and accessible open space to maintain the physical separation between Southbourne and Hermitage. The built character of the development will soften towards the edges of the area, and the landscape character will transition from formal spaces to natural parkland edges to blend with the surrounding context. The feature TPO Beech trees and their local green space designation in the east of the site has been retained and their setting incorporated as part of a new village green. The DPD also identifies surface water flood risk issues evident to the West of the BLD area to the north of the railway line as a challenge. Flood risk and drainage constraints also apply to Scenarios 2 and 3. The surface water flood risk issues should not be considered a constraint to the deliverability of development in Scenario 1 as risk is low and can be suitably mitigated. Initial technical work undertaken by CCE's appointed flood risk consultants, Pell Frischmann, confirms that the site, as a whole, has a very low flood risk from surface water. The site is not shown to be at risk from artificial sources such as reservoirs, and there are no large bodies of open water near the site. Surface water management for the site will ensure that runoff will not be increased and can be fully mitigated for as part of development proposals. SuDS ponds will be provided in the lower-lying areas of the site which will mitigate risk whilst creating an attractive habitat. The Commissioners is aware that the scenario presents a challenge in relation to the Brent Geese Secondary Support Area and are committed to providing comprehensive mitigation measures as set out by the Solent Wader and Brent Goose Strategy Guidance on Mitigation and Off-setting Requirements Report of 2018. The measures will also ensure the avoidance of adverse effects on the SPA, SAC and Ramsar site at Chichester Harbour. These designations and the need to consider the impact of development on ecology are highlighted in the Vision Document. Additional land (located adjacent to Scenario 1 north of the A27, also within the Commissioners' landownership) has been identified by the Commissioners for use as an 'ecological park' to mitigate any loss of habitat for protected species including the Brent Goose. To date, the Commissioners' appointed Ecologist has conducted surveys and have discussed the proposed mitigation measures, including the off-site ecological park and on-site habitat retention, with the Hampshire and Isle of Wight Wildlife Trust. Whilst details of the strategy would require further development, in September 2022 it was indicated that the Trust agreed the mitigation strategy would be suitable. The Commissioners is committed to safeguarding the environment and protecting biodiversity and are making every effort to engage with Natural England on this matter, but to date no consultation has been returned due to their workload. Chapter 6 of the Assessment Framework notes that the Commissioners have potential to mitigate any impact. The consultation document states that development of the site Scenario 1 would result in the loss of Grade 1 and 2 agricultural land. However, given this impact is the same across all three scenarios the Commissioners do not consider that this should be considered a challenge. Scenarios 2 and 3 would potentially additionally involve loss of Grade 3 land. The loss of land is inevitable, and providing a logical extension to the existing village is a sensible approach to minimise the loss of agricultural land elsewhere in the area. Paragraph 83 of the NPPF (December 2023) states that to promote sustainable development in rural areas, housing should be located where it will enhance or maintain the vitality of rural communities; and planning policy should identify opportunities for villages to grow and thrive. The DPD states that a key benefit of this scenario is that the northern side of the site allocation could be largely facilitated by a single landowner. The Commissioners agrees that this is a significant benefit of this scenario which should be given great weight. The land is available and the Commissioners is committed to bringing the development forwards. This single ownership and safeguarded land to the south of the railway line for the potential bridge greatly increase the deliverability prospects of the scenario, particularly as the safeguarded land can be transferred as the proposed of development becomes more certain. As recognised in the DPD and set out in the Vision Document, this single ownership provides more certainty over the delivery of a master planned and joined-up approach to development. To the north of the railway line, a small parcel of land is currently safeguarded for future educational/leisure use which is in the ownership of West Sussex County Council. Some additional co- ordination and negotiation amongst landowners to the south of the railway line may be required. The Commissioners would work collaboratively with the landowners to deliver development. The Southbourne BLD Background Paper (January 2023) confirms that although land within the relevant area is across multiple ownerships, all site promoters were contacted in August 2022 to confirm reasonable prospect that the development is viable and deliverable within the plan period, with no overriding constraints to the sites with the overall BLD coming forward. The Paper states that work undertaken by the Council demonstrates that there are no designations or insurmountable environmental issues that would prevent the successful delivery of circa 1,200 dwellings on the Commissioners' land. The Commissioners request that the Council makes reference to the safeguarded land within the DPD to secure it in Policy. It is currently secured through historic S106 agreements. As part of our representations to the Southbourne Neighbourhood Plan, we urged the Parish Council to safeguard land to the south of the railway line for a future road crossing over the railway to support the growth of Southbourne. This follows the approach in the previously adopted Neighbourhood Plan (2015), which states that "in order to reduce congestion at existing railway crossings and to improve pedestrian safety, the Parish Council wishes to safeguard land to the west of Southbourne as shown on Map Inset A : Southbourne Prinsted, for the provision of a new road and a crossing of the railway line". This safeguarded land was not included within the recently adopted Neighbourhood Plan (2023). Our concern is that if this land is not safeguarded in planning policy, a speculative developer could build on it or compromise its ability to deliver a suitable access to support the strategic growth Southbourne and the delivery of Scenario 1. Overall, the Commissioners is committed to the delivery of a sustainable and well-integrated development that can deliver a multitude of benefits. Scenario 1 is the most suitable, feasible and deliverable option for development. The challenges identified in the DPD have been carefully addressed and have informed the development of the Concept Masterplan, which sensitively responds to these challenges and as a result delivers a responsive, unique and characterful development proposal. [See attached document for full submission]
The Commissioners considers that the potential for a well-connected and well-integrated development should be better recognised. The Interim Sustainability Appraisal (SA) prepared by Aecom identifies Scenario 1 as the option which performs most favourably in terms of transport and accessibility, primarily due to the provision of a multimodal bridge using the safeguarded land. The SA notes that approximately 50% of the proposed development is within 400 metres of an existing bus stop, which is considered a positive contribution and is significantly higher than Scenarios 2 and 3 (10% and 30% respectively). The SA finds that Option 1 would facilitate the greatest number of new homes within proximity to local employment opportunities. There is significant potential to provide new and enhanced active travel connections, as outlined in the Vision Document. The Commissioners would also explore the potential to improve connectivity with the Railway Station, which is approximately 650- 1.5km away from Scenario 1. The Commissioners' commitment to the delivery of a high-quality development should be considered a key benefit. It is high on its agenda for 'The Beeches' to be a new neighbourhood that is of high quality design, locally distinctive and attractive which will evolve and grow as part of Southbourne. As explained in the Vision Document, the design would take cues from Southbourne in terms of scale, massing, details and materials and the landscaping ensures the development has a minimal impact on the sensitive surrounding landscape. The list of benefits for Scenario 1 does not include heritage considerations. The Assessment Framework notes that Scenario 1 is the only Scenario where there are no heritage assets within the site, when considering the potential for development to be sympathetic to existing heritage features. The SA states that Scenarios 2 and 3 are particularly close to Grade II listed buildings 'Thatchways' and 'Loveders Farmhouse'. The SA notes that Scenario 1 is likely to have some impact on the setting of listed buildings in Hermitage and Lumley villages, but as previously discussed this will be mitigated through the landscape buffering and sensitive overall design. The SA concludes that Scenario 1 performs most favourably with regard to heritage. The Commissioners therefore considers that this should be included as a benefit within the DPD. The vision for The Beeches seeks to interconnect place, community and heritage. The DPD should also include the potential for the delivery of high-quality housing as a key benefit. The potential of Scenario 1 to deliver a mix of housing types and tenures is recognised as Very Strong in Chapter 5 of the Assessment Framework. The Commissioners is committed to the delivery of a range of high-quality homes that are energy efficient, which are built to last, from houses for first-time buyers to family homes, including both market and affordable housing. The DPD is based on each Scenario having capacity for 800 dwellings. The Commissioners' Vision Document shows that its landholding could accommodate circa 1,200 homes, which could assist with meeting housing need should the Council revisit their requirement in light of emerging National Policy which would see a significant increase in the Standard Method figure for Chichester District Council. Should the Local Plan Examination conclude that additional housing is required, this site has the capacity to provide additional homes beyond the 800 identified in the draft DPD. Given the ample provision of approximately 31ha of open identified as being deliverable in the Vision Document (significantly above the minimum of 25.5 ha identified as deliverable in the DPD), the concept masterplan remains balanced and able to deliver the necessary infrastructure in a high quality development. Maximising the site's potential to deliver homes will help to ensure the delivery of infrastructure to support the growth of Southbourne. In relation to housing delivery the Stage 1 Viability Assessment (October 2024) includes Scenario 1 anticipated S106 costs in Appendix 1. This includes a Gypsy and Traveller Provision cost of £2.16 million (for 24 pitches). However, the Chichester Planning Obligations SPD (2016) does not include a standard obligation for Gypsy and Traveller Provision and there appears to be a lack of evidence to justify this requirement. In addition, a BNG cost of £1.5M is stated - however, should the BNG requirement be delivered on site, presumably this cost would not apply. Any BNG cost should be fully justified and evidenced by supporting documents. The list also provides an estimated cost for the road bridge. The Commissioners considers that any specific S106 obligations need to be defined at the planning application stage, based on an evidence-based and assessed approach. [See attached document for full submission]
Two new access points are proposed in Scenario 1, from Main Road to the south and Stein Road to the east. Technical work is being undertaken by Pell Frischmann who is exploring the possible provision of a spine road (and associated bridge over the railway line) connecting the A259 Main Road with Stein Road (both access points), to form a continuous vehicle route around the north-western edge of Southbourne as part of Scenario 1. The Commissioners is aware that the delivery of a multimodal bridge is an important aspect for the delivery of growth at Southbourne whichever Scenario is pursued. That said, a sizeable first phase could still come forwards to the north of the site ahead of the delivery of a multimodal bridge in Scenario 1. Development could then continue south, once the spine road is in place to connect the northern and southern access points. The Commissioners is also aware that the informal pedestrian level crossing at Church Footpath is already considered a high-risk crossing as confirmed by Network Rail. The specific challenges that could arise should a pedestrian bridge be undeliverable would need to be subject to detailed technical work. Each applicant would have to refine this testing with their own modelling at an appropriate time closer to planning application stage. The Commissioners considers that Scenario 1 is the most feasible option for the delivery of a multi- modal bridge given the safeguarded area of land immediately to the south of the Scenario area; this is a significant advantage for Scenario 1. This benefit is recognised in the DPD and the SA, which comments that landownership issues are not as much as of a concern given the S106 agreement in place. Pell Frischmann are continuing technical work to determine the likely costs, detailed technical design of a new bridge and road reconfiguration, time frames and overall viability. Summary To summarise, the Commissioners agrees with the Council's vision for the future development of a thriving and sustainable community in Southbourne and consider that Scenario 1 is the most suitable, feasible and deliverable option to realise this vision. As has been explained and is shown in the Commissioners' Vision Document, should the Council choose to proceed with Scenario 1, a range of benefits including a new hub of community facilities and ample green infrastructure to enhance biodiversity and accessibility and those can be delivered. The Commissioners considers that these benefits could be delivered alongside 1,200 high quality homes if required, above the 800 homes stated in the DPD. The challenges identified in the DPD can be suitably mitigated for as part of a future development and have been used to inform a carefully considered concept masterplan. The Commissioners understands that the delivery of a multimodal bridge to provide a railway crossing is needed to allow the full delivery of strategic development at Southbourne - this is a challenge for all three scenarios set out in the DPD. The Commissioners and Pell Frischmann will continue to work with the Council and other key stakeholders with regard to the delivery of the bridge and do not anticipate that this will be an insurmountable issue for Scenario 1. The Commissioners are keen to continue to engage with Chichester District Council on the preparation of the Southbourne DPD. Should you have any questions regarding this submission or wish to meet to discuss the opportunity presented by the Commissioners' land. [See attached document for full submission]
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Following a review of Scenario 1, we agree that the delivery of this option has the potential to provide opportunities for better connections with nature for both the existing and new residents of Southbourne, through the delivery of the western section of the Green Ring as well as quality green open space provision and the retention of existing PROW. Natural England supports the delivery of options that have the potential to facilitate connections between people and nature within the wider community. We also agree that the current ownership of the land would help to facilitate a more 'joined up approach' to development, and Natural England would strongly encourage benefits to people and nature being considered in a manner that ensures cohesion and delivery of multiple benefits at scale. Your authority has identified that a large proportion of the site is designated as a 'Secondary Support Area' by the Solent Wader and Brent Geese Strategy and that any loss will require mitigating, and Natural England agrees that this is a challenge that will need addressing and considering in line with the mitigation hierarchy (paragraph 186 of the NPPF).
Given the location of the site, any new overnight accommodation will have a likely significant effect upon the Chichester and Langstone Harbour SPA and Ramsar site, as well as the Solent Maritime SAC, due to increased levels of recreational disturbance and treated effluent being discharged into the site. Nutrient neutrality has the potential to be addressed via on-site land use change, such as woodland planting. Natural England would encourage the consideration of mitigation options that can provide multiple benefits. For example, woodland planting (or other appropriate land use change) can have the additional benefit of providing on-site greenspace to attract some recreational activity away from the Solent designated sites (as part of a mitigation package for recreational disturbance impacs) while addressing increased levels of nutrients. However, we advise that given the scale of the development and its proximity to coastal designated sites, standard financial contributions and on-site greenspace provision are unlikely to wholly mitigate the impact of increased recreational disturbance alone, and may require additional bespoke mitigation measures in line with the Solent Recreation Mitigation Strategy (December 2017). In addition, as the proposed development site for Scenario 1 is smaller than the other scenarios being considered - but still delivers the same number of dwellings - we would suggest that the potential challenges with delivering onsite mitigation should be considered, including whether offsite solutions may be required instead. It is important to note that, although built development will not cover the entirety of the 'Secondary Support Area', changes in land use that do not constitute built development may still constitute a loss of suitable foraging habitat for birds identified within the Solent Wader and Brent Goose Strategy. It is not currently clear what the plans are for the remainder of the Broad Location of Development (BLD), but even the provision of open greenspace is likely to adversely impact upon the suitability of the site (as a secondary support area) as there is likely to be a reduction in the availability of appropriate foraging resource as a result of increased recreational activities in this area. Having used our Agricultural Land Classification predictive tool, we would advise at this stage that this scenario would result in the loss of primarily Grade 1 agricultural land rather than Grade 1 and 2. In line with Policy 48 in your authority's currently adopted Local Plan, development of poorer quality land should be fully considered in preference to best and most versatile land and this should be evidenced within application documents. Given that the Southbourne Broad Location of Development (BLD) is located within the setting of both the South Downs National Park to the north, and the Chichester Harbour National Landscape (formerly 'Area of Outstanding Natural Beauty') to the south, all development scenarios will need to consider potential landscape impacts. In line with Paragraph 182 of the National Planning Policy Framework (NPPF), development within the setting of protected landscapes should be sensitively located and designed to avoid or minimise adverse impacts on the designated areas. We would therefore expect any potential impacts to be assessed in line with Paragraph 183 of the NPPF and Section 245 of the Levelling-up and Regeneration Act 2023.
This question is outside of Natural England's remit, and we therefore will not be providing comment.
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All three of the scenario maps should show the proposed CHEM route along the A259
Benefit This is the only Scenario which shows pedestrian/ cycle route connectivity to the A259/CHEM route.
Developers would have difficulty selling properties without a vehicular bridge over the
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3.6 We support this option. On the basis of the consultation document's analysis and that in the Assessment Framework, it plainly offers the greatest advantages that outweigh the limited genuine environmental or physical constraints. 3.7 This scenario includes land south and north of the railway line and would deliver a substantial part of the green ring and importantly consolidate community facilities and address Church Crossing. 3.8 It is especially important that this option completes the development opportunity west of Alfrey Close; this strengthens and takes advantage of the connectivity that can be achieved with the existing urban area and towards the train station to contribute to active and sustainable modes of travel. 3.9 As the consultation document acknowledges, the benefits and advantages of Scenario 1 comprise the following: - a community hub enabling shared education and leisure facilities; good connectivity to pedestrian and cycle routes via the Green Ring and into the existing settlement; - the potential to address the existing pedestrian rail crossing using the rights and safeguarded land already secured; delivery of the western portion of the Green Rong that will integrate biodiversity, nature, wildlife and arboricultural resources; development that can be facilitated by a small number of landowners - The Church Commissioners and Hallam Land. (The suggestion that there are multiple landowners to the south of the railway line is not accurate; the land shown on the associated map is controlled by Hallam Land) 3.10 In respect of challenges, none of these are considered constraints that preclude development of Scenario 1 and whilst they might have a bearing on the mitigation measures necessary to support development north of the railway line, they do not constrain development to the south. 3.11 The gas pipeline appears to influence each of the scenarios and is not therefore a distinguishing factor. 3.12 The need for an additional vehicular crossing is equally a feature in each scenario and again is not a distinguishing factor; it is instructive however to compare how access is referred to between the scenarios: for the first scenario the term "largely dependent" is used, whereas for the second scenario it is expressed differently: [there is] "a strong reliance on a vehicular bridge being provided over the railway line which is challenged by land not being safeguard for access". 3.13 Indeed, the Assessment Framework indicates that the land where a new bridge could be provided is subject to a planning application for housing development that specifically does not makes such provision; this illuminates the intentions of those developers and the extent of genuine co-operation that exists (page 39 refers). 3.14 Mitigation for the overwintering and breeding birds will require a material increase in the functionality of the remaining area west of the proposed development that increases its utility. Significantly, this only relates to land north of the railway line. [See attached document for full submission]
3.15 Whilst the previous Landscape Gap Study identified the contribution of land around Southbourne to preventing coalescence with nearby settlement it is important to place that in the context that existed at that time. Plainly, with the emerging Local Plan now proposing a strategic development area at Southbourne the relevance of that study is more muted in that expansion of the settlement will occur and this will have an effect on the landscape around the settlement and this may result in new development being closer to existing settlements. To the west of Southbourne the assessment affords a potential gap function to land between the existing settlement and Hermitage. 3.16 Hallam has made submissions in relation to this previously, most notably its submission to the District Council of August 2022 which include a specific Technical Note in response to this. It is unquestionably the case that new development can both be accommodated on the Hallam land whilst also maintaining the separate identity of Hermitage. Whilst this would bring new development closer to Tuppenny Lane that would not have an effect on the character and identify of Hermitage. The character and identity of Hermitage is defined by core areas of housing and not the caravan park that comprises its eastern environs. Significantly this analysis has been adopted in the consultation document which retains a green corridor between new development and Tuppeny Lane. 3.17 In this regard it is of note that the District Council has resolved to grant planning permission for development north of the Caravan Park within an area identified by the gap assessment as having a potential function in maintaining separation. Clearly, the notion of such a designation is not inviolable. 3.18 The quality of agricultural land is a characteristic across the District as a whole. It is widely understood that to achieve the sustainable pattern of development that the spatial strategy is predicated on will involve development of best and most versatile agricultural land. This is not a distinguishing feature between the three scenarios. 3.19 Surface water flood risk is evident around the settlement; this appears to be largely in the form of ponding on the north side of the railway. This does not appear to be a distinguishing factor between the scenario 1 and 2, although the Assessment Framework refers to future tidal flood risk affecting land east of the settlement which affects the vehicular route proposed. Undoubtedly this is a more significant constraint. 3.20 None of the above challenges represent absolute constraints to development west of Southbourne as promoted in the first scenario. For the most part they give rise to masterplanning considerations rather than factors that preclude development. 3.21 What is evident is that the development opportunity south of the railway is eminently suitable whichever scenario is taken forward. It provides a discrete development opportunity, free of significant constraints that can be easily assimilated with the existing settlement pattern via the recent development at Gosden Green and Alfrey Close. Scenario 2: land to the East [See attached document for full submission]
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Benefits 3.1 Metis agree that a new primary school and local centre will help create a new community hub with associated social, economic and environmental benefits. The provision of improved pedestrian and cycle connections (paragraph 5.12) will add to these benefits alongside additional health and well-being benefits. 3.2 We do not agree that the existing pedestrian rail crossing is unsafe. There is no evidence to support this. If Network Rail believe there is a safety issue, the evidence and justification should be made publicly available. However, we do acknowledge that land is already safeguarded for a pedestrian and cycle bridge, which provides a benefit in terms of deliverability (paragraph 5.13). 3.3 It is also agreed that the single land ownership of land to the north of the railway line is a benefit in terms of deliverability (paragraph 5.15). However, as set out elsewhere in these representations, a focus on land to the north of the railway results in a more unsustainable pattern of growth than the available alternatives, and as such it is not justified. Maximising development opportunities on available land to the south of the railway line would result in a more sustainable pattern of growth, and be better aligned with the Objectives cited in the Vision. Whilst land to the south of the railway line is in multiple ownership, this land is deliverable and developable (as evidenced by recent planning applications and HELAA submissions) and this would not prevent sites from coming forward in the most sustainable part of the BLD area. Challenges 3.4 Challenges surrounding the need for and the delivery of a multi-modal bridge are noted, and it is agreed that these present a significant challenge in terms of viability, deliverability and implementation (paragraph 5.18). However, based on the evidence available, including the Council’s own evidence, we do not agree that access is dependent on two new vehicular accesses (north and south) together with a vehicular bridge. The delivery of a vehicular bridge should not be identified as a challenge as it is not required. [See attached document for full submission]
3.5 Any Scenario which relies on a new vehicular bridge presents a significant challenge. Metis do not consider that the bridge is justified in transport terms or supports good placemaking – it undermines the Vision, the Objectives and the Local Plan transport strategy. Conversely, a pedestrian and cycle bridge supports all of these. The allocation should not be designed for a car led Scenario. In response to improving connectivity, the first solution should not be to build a vehicular bridge. Instead, it should be to encourage non-car journeys by providing Infrastructure that facilitates non-car journeys and makes non-car journeys convenient, attractive and safe. 3.6 It is also considered that clarification on the distribution of development is required. Even with only 100 dwellings to south of the railway line, it leaves only 700 to north, which is well within capacity given that the Council’s evidence states that, “between 750 – 1000 dwellings, a road bridge may be beneficial”. Our estimation is that a minimum of 200 dwellings could be constructed to the south of the railway line which would leave a residual requirement of 600 to be provided north of the railway line, making a vehicular bridge completely unnecessary. Again, this points to the need to maximise development to the south first, reducing the residual requirement to the north. 3.7 An Assessment has been prepared by Paul Basham Associates (PBA) and can be found at Appendix A of these representations. This reviews the Council’s transport evidence prepared by Stantec, which considers the need for a multi-modal bridge. The Assessment concludes that there is no justification for a multi modal bridge to deliver the residual requirement of 800 dwellings. By maximising development to the south of the railway (a minimum of 200 dwellings), the case for a vehicular bridge is diminished further, as there is no evidence to suggest that a bridge is required for 600 dwellings north of the railway. 3.8 A further challenge with this Scenario is that the inclusion of a vehicular bridge significantly undermines viability, and therefore compromises the viability/deliverability of affordable housing, the local centre and other community infrastructure which are key elements of the Vision. Maximising development opportunities to the south of the railway line, where existing services and facilities are located, would support these existing services and allow the new Local Centre to focus on complementary provision. This would assist with the overall viability and deliverability of development, also ensuring that affordable housing delivery is not undermined. 3.9 An analysis of the Council’s Stage 1 Viability Assessment (Dixon Searle) has been carried out by Sturt and Co. A copy of this analysis can be found at Appendix B of these representations. 3.10 The analysis highlights a significant inconsistency in that the Dixon Searle reporting includes appraisals of development Scenarios of 1,050 dwellings, whereas the consultation is being undertaken on the basis of identifying an allocation for 800 dwellings (the residual requirement net of committed development), Sturt & Co question the relevance and legitimacy of Dixon Searle assessing the viability of 1,050 dwellings, noting that the obligations for the 250 committed dwellings are already secured through their respective permissions, and should not be included in viability modelling for 1,050 dwellings Scenarios, as appears to be the case in the Dixon Searle reporting. 3.11 Sturt & Co also highlight that requests were made to CDC for electronic copies of the Argus Appraisal worksheets for the appraisals at Appendix 2a of the Dixon Searle Assessment, but this information has not been provided on the basis that it is information that would need to be made available to all parties, which is not considered appropriate while the consultation process is underway. Consequently, it was not possible for Sturt & Co to undertake a full and detailed assessment. 3.12 However, the analysis has highlighted a number of significant issues relating to assumptions made by Dixon Searle in respect of Sales Values, Benchmark Land Value and Finance Rates – which have a significant impact on viability, both individually and cumulatively. 3.13 The analysis concludes that the viability position is challenging based on the issues outlined above. However, the inclusion of bridge infrastructure costs is the most concerning given the significance of these costs and the lack of any supporting cost analysis. Based on their analysis, there are strong indications that these costs have been significantly underestimated and as such the marginal viability position being reported is incorrect. Sturt & Co confirm that the viability of development is significantly compromised with a multi-modal bridge. Development is more likely to be viable with a pedestrian/cycle bridge. 3.14 In summary, by not directing development to where services already exist along the A259 corridor, the benefits are not being maximised in this Scenario. The A259 corridor provides a sustainable and viable location for development, which reduces the costs associated with development of north of the railway. This avoids putting unnecessary and avoidable pressure on viability, and in turn affordable housing, it supports the wider Vision, Objectives and Local Plan strategy, it responds in a positive way to environmental challenges including landscape character and supports measures to address climate change. 3.15 The challenges with Scenario 1 are exacerbated by not maximising development on land to the south of railway. These challenges would be avoided or significantly mitigated by proposed Scenarios 4 and 5 as shown in Section 6 of these representations. [See attached document for full submission]
3.16 Metis do not consider this to be a challenge, but instead it presents an opportunity to encourage more non-vehicle journeys. The provision of a pedestrian and cycle bridge, providing a sustainable connection between development north and south of the railway line, and linking existing facilities to a new community hub centered around the existing secondary school, would result in a well-connected and sustainable community. It would provide genuine and convenient opportunities to walk or cycle, achieving the modal shift which the Monitor and Manage approach relies upon. Conversely, a vehicular bridge will encourage short car journeys, leading to further congestion and undermining measures designed to tackle climate change. A vehicular bridge would not be a benefit but a significant challenge to the delivery of the Local Plan strategy and DPD Vision and Objectives. [See attached document for full submission]
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Scenario 1: Challenges may include the need to divert existing PRoW and, as a minimum, the landowner would need to grant permissive cycle rights (along with improvement works) over PRoW that fall within the proposed green circle route. Internal routes should: • consider the continuation of Footpath (FP)241_2 should any new bridge replace the existing railway crossing otherwise it leads to a dead end, and • links with FP243_1 which links the site with Park Road to the east. FP240 and FP3591 would also require surface improvements to mitigate against increased use. Para 5.13 The potential for two separate bridges is referenced; one for pedestrians/cyclists and potentially another for all modes. The financial viability deliverability of the bridges again needs to be considered. Due consideration should be given to the likely footprint required for a bridge with ramps that meets Inclusive Mobility guidance. Para 5.19 In answer to Q4, whilst the operation of the existing crossing is a matter for Network Rail, it’s not clear how a comprehensive and cohesive development to the existing part of Southbourne south of the railway could be created without an appropriate and safe link across the railway. [See attached document for full submission]
The consultation is for potential development in a broad location. In most cases when a site is identified for allocation there is usually some proportionate technical background work undertaken to justify the allocation and identify what critical and essential mitigation will be needed as part of the development. In this case there is no site-specific technical work associated with the options, thereby making it difficult to make detailed comments. Technical assessment of the options should therefore take place before a preferred option is selected. The county council would welcome the opportunity to give pre-application advice to the site promoters on the highways and transport impacts of development. In the absence of any technical work on transport impacts of the options, it is difficult to comment on the acceptability of a multi-modal bridge, to serve 800 homes, or whether any of the options are preferable from a transport perspective. There may be some unintended consequences with the delivery of a bridge across the railway which may open up the north / south route as a rat run to avoid congestion; for example, between B2146 and A259. This will need to be taken account of in any transport assessment. Therefore, if any of these options are taken forward, there will need to be a detailed transport assessment to determine whether a road bridge is acceptable. In addition, there is also a need to understand whether a road bridge would be financially viable. A road bridge at Southbourne is not identified as a priority for investment in the West Sussex Transport Plan 2022-36 to address transport issues, so it would need to be developer funded and delivered. [See attached document for full submission]
We support the reference in the 'challenges' section for Scenario I to a landscape buffer being required to protect the landscape corridor in the west of the scenario. We are concerned at the significant erosion of the landscape gap identified in the Chichester District Council Landscape Gap Assessment 2019 arising from this scenario, and the subsequent potential impacts on the connection between the SDNP and Chichester Harbour National Landscape and the setting of the National Park. Page 43 of this study advises that:'Development in much of this area would be conspicuous and could block valued views. The open character of the landscape provides positive open views between the settlements across open countryside including across the AONB, to the South Downs National Park and to Southbourne church spire. This contributes to the perceived separation of the settlements, their individual identities and rural settings. These views include positive long views across the gap to the hills within the South Downs National Park'. It is also noted that the wildlife corridor would be adjacent to the proposed Green Ring. A suitable buffer to the wildlife corridor should be accommodated to ensure that activities which could potentially result in disturbance of habitats and species of the wildlife corridor are avoided, such as recreational activity.
We support the reference in the 'challenges' section for Scenario I to a landscape buffer being required to protect the landscape corridor in the west of the scenario. We are concerned at the significant erosion of the landscape gap identified in the Chichester District Council Landscape Gap Assessment 2019 arising from this scenario, and the subsequent potential impacts on the connection between the SDNP and Chichester Harbour National Landscape and the setting of the National Park. Page 43 of this study advises that:'Development in much of this area would be conspicuous and could block valued views. The open character of the landscape provides positive open views between the settlements across open countryside including across the AONB, to the South Downs National Park and to Southbourne church spire. This contributes to the perceived separation of the settlements, their individual identities and rural settings. These views include positive long views across the gap to the hills within the South Downs National Park'. It is also noted that the wildlife corridor would be adjacent to the proposed Green Ring. A suitable buffer to the wildlife corridor should be accommodated to ensure that activities which could potentially result in disturbance of habitats and species of the wildlife corridor are avoided, such as recreational activity.
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2.19 Whilst our clients do not have land interests in this scenario, we do wish to highlight the following matters. 2.20 The SADPD highlights that a key benefit of this scenario is that that the northern side of the site allocation could be largely facilitated by a single landowner and land is safeguarded to the south of the railway line for a potential bridge (via existing S106 agreements). The potential bridge is also listed as a benefit of the proposals. 2.23 In the absence of a bridge, any intensification of the existing use of this crossing is likely to face objection by Network Rail. Network Rail are likely to expect a safe (grade separated) alternative, given likely increases in walking demands. Any order to extinguish the footpath, in the absence of a bridge, is likely to fail because the order making authority (Chichester District Council) will need to consider the detriment to existing users of the crossing when they come to their decision. The footpath cannot simply be taken away from existing users. The significance of this risk needs to be given appropriate weight in the SADPD decision making process. The matter is considered further in the technical note by i-Transport at Appendix Two, which include a case study from a development site that was similarly close to a pedestrian level crossing of a railway line. 2.24 Whilst the SADPD suggests there would be multiple opportunities to create walking and cycle connections into the existing village, as demonstrated by the i-Transport Technical Note at Appendix Two, there are in fact only three pedestrian routes into the site other than vehicular access points. Of these the St John’s Road access would require third party land (thereby running contrary to the suggestion that the land control position is less complex); the footpath 243_1 route would need improvement from the current grassed route through a recreation ground and would again require third party land. If the St John’s Road access could not be secured then the new residents would be subject to lengthy diversions for pedestrian and cycle access to many local facilities to the south and east. 2.25 With regards to the existing gas pipeline, it is noted that if development cannot be accommodated within this zone then it will push development further south and west. Whilst it is suggested that this “could potentially push development closer to the landscape gap addressed in the Landscape Gap assessment completed for Chichester District Council in 2019” this is considered to be incorrect. We comment on the Assessment Framework in Section Three but note that the proximity considerations identified by the Landscape Gap assessment have been incorrectly transposed onto the composite constraints map. These are correctly shown on Figure 2.2 of the Assessment Framework which clearly shows the “area for development 800 dwellings” under Scenario 1 would already encroach into the proximity considerations area. Clearly this would be further worsened if the area for development were to be pushed further south and west as a result of the pipeline constraint. Further information is also required on the relationship between the pipeline and the proposed access arrangement. 2.26 Whilst the SADPD notes that “a landscape corridor at the western edge of this scenario will mitigate and provide a spatial and visual gap to the north of the railway line,” at this stage it is unclear how successful such a solution would be and it is understood that no further assessment work has been undertaken to inform such an assumption. Indeed it is noted that the 2019 Landscape Gap Assessment concluded in respect of this gap that: “It is important that the area between Hermitage and Southbourne is retained as open countryside. The gap is essential in preventing the coalescence of the settlements and maintaining their separate identities.” 2.27 Furthermore, as set out in the SLR response at Appendix Three, any development to the west of Southbourne would be breaking out into open, agricultural land which would fundamentally change the form of the settlement. Whilst no Landscape and Visual Assessment has seemingly been prepared for Scenario 1, as noted in Appendix Three, there are unrestricted views potentially available to the South Downs National Park as noted at paragraph 2.16 of the Assessment Framework. 2.28 The majority of the site under Scenario 1 is identified as a Brent Geese Secondary Support Area. The Solent Wader and Brent Goose Strategy Guidance on Mitigation and Off-Setting Requirements Report (2018) makes clear in relation to such areas that “Loss of or damage to Secondary Support Areas should be discouraged, and on-site avoidance and mitigation measures considered wherever possible. However, where impacts cannot be avoided or adequately mitigated on-site, there may be scope for a more flexible approach to off-setting the impacts to these sites, provided the continued ecological function of the network is maintained and significant enhancements additionally delivered, for example by improved long term management.” The eastern section of the BLD (Scenario 2) is not subject to this designation and as such is a clear alternative which would avoid the loss of or damage to the Secondary Support Area. The SADPD has seemingly skipped the first step of the mitigation hierarchy (avoidance) and instead focused on minimisation and mitigation. The SADPD process should be updated to follow the mitigation hierarchy and consider opportunities for avoidance before other forms of mitigation, particularly in light of the availability of other spatial scenarios which would not affect this designation. 2.29 In light of the above, the benefits and challenges in relation to Scenario 1 should be updated, including the summary text, in order to accurately reflect the comments provided above. 2.21 We note however, that there are multiple landowners to the south of the railway line and indeed part of the land to the north of the railway line is owned by West Sussex County Council, and as recognised by the SADPD, further negotiation is likely to be required in respect of the bridge, including with Network Rail. This is similarly reflected in Appendix A which notes that a ‘land swap’ may be required to deliver the bridge footing. Further detail is therefore likely to be required in order to assess whether the bridge can be delivered and considered a benefit of the scheme. If further discussions have taken place, including with Network Rail, it is important that this is shared as part of future consultations and to inform the assessment of any financial implications so this can be factored into the viability and deliverability of this Scenario. [See attached document for full submission]
2.23 In the absence of a bridge, any intensification of the existing use of this crossing is likely to face objection by Network Rail. Network Rail are likely to expect a safe (grade separated) alternative, given likely increases in walking demands. Any order to extinguish the footpath, in the absence of a bridge, is likely to fail because the order making authority (Chichester District Council) will need to consider the detriment to existing users of the crossing when they come to their decision. The footpath cannot simply be taken away from existing users. The significance of this risk needs to be given appropriate weight in the SADPD decision making process. The matter is considered further in the technical note by i-Transport at Appendix Two, which include a case study from a development site that was similarly close to a pedestrian level crossing of a railway line. [See attached document for full submission]
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Building to the West will close the gap with Hermitage. Siting two educational premises together will cause even greater congestion at peak times on minor roads around them. The land to the west is a secondary feeding area for Brent Geese at high tide and is vital to this internationally important area for them. It is important to retain a wide area around the high pressure gas line for safety reasons.
NO
Q4 Effect of no Road Bridge No scenario where a road bridge is not provided should be considered as there is already dangerous congestion at peak times with blockages as traffic tries to pass parked vehicles in the road occurring regularly leading to tailbacks on to the railway line. Any new development will lead to an increasing volume of traffic that will bring this community to a standstill and potential safety issues.
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Westbourne Parish Council supports development to the east of Southbourne as it considers any development to the west would reduce the strategic gap between the settlements of Westbourne and Southbourne, and would affect the wildlife corridor which is important to protect for environmental and biodiversity purposes. It is important to leave plenty of green space between the two communities to protect the local identity of villages and avoid coalescence. The Council considers that a bridge for vehicles, bikes and pedestrians over the railway is essential to take pressure off the level crossing and connect any development to the A279.
The Council is concerned that the viability of the road bridge is marginal and if land values reduce or other financial pressures emerge, the road bridge solution may not go ahead. This could result in a situation where the housing proceeds but no road bridge is provided and would have a serious outcome, not only for Southbourne with gridlock at the level crossing, but also for Westbourne with traffic through the village seeking an alternative to the chaos at the level crossing. Whitechimney Row in Westbourne does not have the ability to take any more traffic due to the narrow and historic nature of the road. The Parish Council strongly objects to any scheme that does not deliver a road bridge over the railway. The Council considers the Community Infrastructure Levy must pay for the road bridge on any option and the number of houses should be increased if necessary to ensure enough funding to provide the bridge. 800 new homes without a road bridge would be a disaster. 900 new homes with a road bridge would make little difference overall in terms of the spatial plan but so much better as a solution to the need to grow Southbourne
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