5.46. Questions for Regulation 18 consultation:
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I think this scenario will just mean that Southbourne will continue to expand , beyond what it can cope with. Housing will far exceed facilities I think it is the worst of all options. Also, as mentioned before, sewerage disposal capability Don't build any houses before SW has upgraded the treatment plant.
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The challenge "Does not provide a vehicular bridge... says "may increase impacts of traffic congestion" Should be changed to will in increase impacts."
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I am writing to recommend that I am strongly opposed to the 'Mixed Scenario' proposed development to Southbourne in the Development Plan 2021-2039. My reason for this is that the congestion along Stein Road is becoming increasingly problematic, especially at school times. I am a resident of Stein Road (close to the railway gates) and there are many times during the day that I don't leave my drive in my car as I can't get out due to the congestion of traffic coming both ways not to mention the railway gates closing often in the day and the build-up of traffic. There has been a huge increase in traffic over the years since the early 2000's (I know from experience as I have lived here since 2000) and without a new road/bridge on either the western or eastern side of Southbourne to take the pressure off of Stein Road the situation would become untenable. As a result I am totally against any option that doesn't provide space for another main road/route that would alleviate congestion from Stein Road. In any of these developments there should also be adequate drainage provided due to the fact that last year there were 4 drainage lorries (perhaps more) situated outside my house in Stein Road and along Cooks Lane draining off overloaded rainwater/sewage constantly for months in October/November 2023. I really hope there is provision for proper infrastructure/drainage. I'm concerned about the sites for Brent Geese/Wildlife and that they will have adequate space. The open agricultural fields are at present flood plains to soak up the huge amount of rainwater we have and could be valuable agricultural land that would be lost at a time when we need more fields to provide food for the country. There are also many other reasons that I am opposed to such huge developments in this tightly squashed and overpopulated area and would hope that any future development is very carefully planned if there has to be such a large one leaving space for wildlife/agriculture.
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Following a review of Scenario 3, we agree that the delivery of this scenario has the potential to provide greater benefit to both nature and people with the delivery of the entire Green Ring around Southbourne Parish. In addition, we agree that this scenario is likely to have a lesser impact upon the setting of both Chichester Harbour National Landscape and South Downs National Park given that 800 homes are to be provided over a greater hectarage and the pattern of development is aligned with the existing shape of Southbourne. We are also concerned that the existence of multiple landowners and planning applications across this site could result in a reduced benefit for nature and people, with a likely piecemeal approach to mitigating impacts to designated sites and green infrastructure provision and agree that development should come forward in a coordinated manner to ensure that these elements are dealt with as strategically as possible. Wherever possible, Natural England would strongly encourage benefits to people and nature being considered in a manner that ensures cohesion and the delivery of multiple benefits at scale.
As with the scenarios discussed above, Scenario 3 will also have a likely significant effect upon the Chichester & Langstone Harbour SPA and Ramsar site, as well as the Solent Maritime SAC, due to the increased levels of recreational disturbance and treated effluent being discharged into the site. Given the larger site area (198.2ha) there is a greater likelihood that mitigation such as greenspace provision or woodland planting will be able to be delivered on site, when compared with Scenarios 1 & 2. In addition, there is greater opportunity for large scale green and blue infrastructure provision which has multiple benefits, for example nature-based solutions to flooding. 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.
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The challenge "Does not provide a vehicular bridge...says "may increase impacts of traffic congestion" Should be changed to will in increase impacts.
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In Scenario 3: Mixed Scenario, which to some extent mirrors Scenario 2, there is potential to impact on two designated heritage assets (Thatchways and Loveders Farm, both grade II Listed Buildings) and their settings. This 'challenge' should be recognised within the policy.
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Scenario 3: Mixed scenario 3.23 Again, having considered the benefits of scenario 1, none of the benefits associated with scenario 3 appear overwhelmingly more important. It is instructive that the absence of a new railway crossing appears to create additional traffic congestion which is a clear disbenefit of the third scenario. Moreover, the extent to compensate for the loss of brent geese habitat does not appear to be catered for with an absence of green infrastructure in comparison with scenario 1. [See attached document for full submission]
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5.1 Metis agree that this Scenario minimises risks regarding viability and deliverability as it does not propose a multi modal bridge (paragraph 5.36). For the reasons set out previously, the requirement for a multi modal bridge has not been evidenced in highway terms and will undermine viability, compromising the delivery of affordable housing and community infrastructure. 5.2 Metis disagree that the dispersal of educational facilities across the village is a benefit (paragraph 5.38). This Scenario would result in the proposed Primary School and local centre being located a significant distance from the existing Secondary School and Bourne Leisure Centre, with poor pedestrian and cycle infrastructure provided on the existing network north of the railway line between these locations. This dispersal of facilities without suitable pedestrian and cycle connections will encourage car journeys across the village. Sustainable patterns should be promoted, and car journeys should be discouraged as a first principle. Any Scenario which encourages car journeys is at odds with the Local Plan strategy and the BLD Vision and Objectives. It is also in conflict with Paragraphs 108 and 109 of the NPPF, 5.3 We agree that a pedestrian/cycle bridge using safeguarded land is a benefit (paragraph 5.39). However, the potential to deliver a pedestrian/cycle bridge on the eastern side should be added to list of benefits. Challenges 5.4 This approach places the entirety of the 800 dwellings requirement to the north of the railway line, which results in the greatest impact on the existing crossings. The accompanying PBA Assessment at Appendix A confirms that the existing crossings can conceivably accommodate 800 dwellings to north of the railway line. However, the potential to mitigate the impacts on crossings – through internalisation of trips and Travel Plan measures encouraging modal shift - are significantly more challenging for this dispersed Scenario. 5.5 It is not considered that the concerns regarding the railway crossings have been substantiated by evidence and rely on comments from Network Rail (paragraph 5.43). 5.6 An analysis of the Council’s Stage 1 Viability Assessment (Dixon Searle) has been carried out by Sturt & Co. A copy of this analysis can be found at Appendix B of these representations. 5.7 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. 5.8 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. 5.9 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. 5.10 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. The absence of a vehicular bridge In this Scenario makes the viability position more favourable than Scenarios 1 and 2. However, the provision of two pedestrian and cycle bridges, based on a dispersed approach to development introduces an unnecessary burden on the viability of the allocation. [See attached document for full submission]
5.11 The opportunity to create village-wide convenient, safe and enjoyable linked routes for pedestrians and cyclists as part of a wider Green Infrastructure (GI) network, should be seen as a significant benefit. Challenges 5.12 Scenario 3 locates all new development to the north of the railway line, omitting all land to the south. This is non-sensical and unsustainable. Existing facilities and services are located to the south of the village along the A259 corridor. New development to the south would help support these local businesses, which can be reached by pedestrians and cyclists as well as being located close to bus stops and the train station. For all three Scenarios, the viability of development is already marginal and given this marginal position, planned spending on community infrastructure and the creation of a new local centre should focus on complementary services rather than duplicating existing services. This should be served by a single pedestrian and cycle bridge. 5.13 In this Scenario, the lack of a multi-modal bridge is justified due to the dispersal of development to the east and west of Southbourne (paragraph 5.43). However, Scenario 3 locates all of the new development north of the railway line. The Stantec Assessment (March 2023) states that it is only development north of the railway line which impacts on the capacity of the crossings. It states that a bridge “may be beneficial” (not required) for development Scenarios of 750 – 1,000 dwellings. Whilst the PBA Assessment at Appendix A confirms that the impact on crossings is significantly less than that presented by Stantec when the benefits of modal shift and internalisation are applied to the analysis, it is nonetheless difficult to understand the Council’s rationale for this Scenario, i.e. how a vehicular bridge is deemed necessary for Scenarios 1 and 2 which locates less than 800 dwellings north of the railway line, but not be necessary for Scenario 3 which locates all 800 dwellings to the north. [See attached document for full submission]
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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. This scenario does not require any diversion of PRoW but again, the landowner would need to grant permissive cycle rights as a minimum, if not full bridleway rights and deliver surface improvement works over affected FP247. This scenario offers the opportunity to seek landowner permission to consider upgrading the remainder of FP247 northwards both within the site and north of the A27 to link in with the bridleway network within and beyond Westbourne parish. Para 5.43 The main concern with this option is the ability of the existing highway network to accommodate the proposed additional traffic. Concerns have already been raised by other parties (namely Network Rail) or are alluded to within the submitted DPD document. There is concern also regarding the ability to comprehensively master plan the development to ensure suitable connections between parcels as well as infrastructure (i.e. the railway crossings) are provided in a timely manner. [See attached document for full submission]
It is welcomed that this scenario does not encroach into the landscape corridors to the west and east. These landscape gaps are identified in the Chichester District Council Landscape Gap Assessment 2019. The study says the following regarding the west and east gaps respectively: "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'. And "Development in much of the northern and southern area of the gap would be conspicuous, particularly from the public right of way crossing the gap, and could block characteristic views. The open character of thelandscape provides positive views between the settlements across open countryside including across the AONB and to the SDNP. This contributes to the perceived separation of the settlements and their rural settings'. It is also welcomed that this scenario appears to be relatively lower risk for potential impacts to the wildlife corridors either side of Southbourne. We would ask that any opportunities for facilitating non-motorised access northwards are considered to support potential opportunities for access and enjoyment of the South Downs National Park.
It is welcomed that this scenario does not encroach into the landscape corridors to the west and east. These landscape gaps are identified in the Chichester District Council Landscape Gap Assessment 2019. The study says the following regarding the west and east gaps respectively: "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'. And "Development in much of the northern and southern area of the gap would be conspicuous, particularly from the public right of way crossing the gap, and could block characteristic views. The open character of thelandscape provides positive views between the settlements across open countryside including across the AONB and to the SDNP. This contributes to the perceived separation of the settlements and their rural settings'. It is also welcomed that this scenario appears to be relatively lower risk for potential impacts to the wildlife corridors either side of Southbourne. We would ask that any opportunities for facilitating non-motorised access northwards are considered to support potential opportunities for access and enjoyment of the South Downs National Park.
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2.35 Given the nature of Scenario 3, where relevant to Scenario 3, our earlier comments in respect of Scenarios 1 and 2 should be reflected in the assessment of Scenario 3. As noted above, our client’s consider Scenario 3 to also potentially be a suitable scenario, subject to further consideration on the delivery of infrastructure and how this could be equalised across the parties. We provide further comments on the specifics of Scenario 3 below. 2.36 It is noted that Scenario 3 proposes the location of the new primary school to the east of Southbourne as in Scenario 2. The SADPD notes the potential beneficial effects of distributing traffic across the village by spreading the educational facilities within Southbourne and connectivity to the Green Ring. We do not repeat our earlier comments but note that further technical assessment work may be required to support the SADPD from a highways perspective. As per our earlier comments, land to the east benefits from significantly more pedestrian and cycle connections into the existing settlement which will enhance the accessibility to both new and existing services and facilities. A proportion of the proposed new homes would therefore benefit from this greater connectivity to the east, compared to Scenario 1 which would only have the more limited connections. 2.37 Scenario 3 is suggested to not require the delivery of a multi-modal bridge. It is likely that additional evidence will be required to demonstrate this is the case, noting that in particular Scenario 3 would result in a significantly higher number of vehicles travelling down Stein Road. Our previous comments in relation to the delivery of the footbridge to the west also apply to this Scenario and are expanded on at Appendix Two. As with Scenario 1, further information is also required on the relationship of the proposed access and the pipeline. We note that our information indicates that the access road to the east would not be impacted by the pipeline with little loss of development area so this does not represent a constraint to the proportion of growth which could be accommodated to the east. 2.38 We disagree with the assertion that Scenario 3 would create a more balanced spatial growth pattern that is aligned with the shape and form of Southbourne. This is inconsistent with the statement in 2.16 and 2.17 of the DPD that settlement form is more compact to the west, but that recent development has already expanded from the eastern side of the village. Whilst Scenario 3 would result in a reduced scale of growth to the west, it is important to recognise that any development to the west of the village would be breaking out into open, agricultural land which would fundamentally change the form of the settlement. In contrast development to the east would be in the direction of existing low density development, meaning that the overall form of the settlement would not change substantially. Current ‘consented’ residential schemes and the eastern scenario development proposals would serve to form an extension that continues to ‘infill’ gaps in the urban form as well as linking with existing good transport corridors. As such, it is considered that the assertion that Scenario 3 would create a more balanced spatial growth pattern is not reflective of the evidence. It is noted that Scenario 3 would continue to deliver some of the benefits of ‘infilling’ gaps in the urban form to the east which would not be achieved under Scenario 1. 2.39 It is noted that this scenario is stated to “retain flexibility for future growth of the village if required.” The accompanying Figure for Scenario 3 does not include a proposed gap annotation (our assumption of the meaning of the green annotation although not identified on the key) to the west of the settlement as shown in Scenario 1. It is understood that proposed gaps are to be included in the DPD, however it is unclear whether this is under all scenarios. Furthermore, it is considered that all three Scenarios potentially retain flexibility for future growth whilst allowing comprehensive masterplanning through the DPD process rather than resulting in an onion skin approach to the growth of the settlement. This is particularly imperative in light of our wider comments on housing growth and the likely need for additional growth to be brought forward at Southbourne. [See attached document for full submission]
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I simply do not see the logic that suggests that having housing spread randomly on both sides of the village will in any way negate the need for the increased traffic to require a road bridge, the same number of cars will be using the same roads?
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Q.8 Are there other benefits and challenges that you feel should also be included? 3.11. This question relates to Scenario 3: Mixed Scenario. 3.12. As is the case for Scenario 2, Scenario 3 would also see Four Acre Nursery contained within the red line for the Broad Location for Development. Accordingly, we consider that the response provided to Q.6 applies equally to Q.8 and Scenario 3. [See attached document for full submission]
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