REPRESENTATIONS ON THE CHICHESTER LOCAL PLAN
HIGHGROVE FARM BOSHAM: POLICY AL7

1 Bosham has similar planning issues to Fishbourne and Chidham/Hambrook relating to the location and form of development including landscape setting, relationship to AONB and National Park, drainage, highways and protecting the separate and distinct identities of these villages.

2 An analysis of the Policies AL7 Highgrove Farm Bosham, AL9 Fishbourne Parish and AL10 Chidham and Hambrook Parish shows that there are inconsistencies between the policies for the three villages and that the policies for Bosham are less stringent than for the other two villages.

REP1: OBJECTION TO CRITERION 3 OF AL7
3 Policies AL9 and AL10 both include criterion 3 which state:
"Provision of suitable means of access to the site(s) and securing necessary off-site
Improvements (including highways) to promote sustainable transport options;"

However, criterion 3 of SA7 states:
"Provision of a satisfactory means of access from the A259;"

4 Bosham is a village with two centres severed by the A259. For reasons of social cohesion and to ensure that the new development has satisfactory pedestrian links with the facilities to the south of the A259, including the small employment areas and community facilities, it is essential that some form of pedestrian crossing and other pedestrian infrastructure is installed to support the new development. At the moment the strategy being promoted by the Council cuts against social cohesion and is clearly an inappropriate strategy compared with the alternative which is to require a crossing. Criterion 3 should therefore be more appropriately worded to allow these issues to be delivered. It is recommended that criterion 3 should be redrafted to state:
"Provision of primary access from the A259, pedestrian access to the western side of the site and securing necessary off-site improvements (including highways) to promote sustainable transport options. This would include an appropriately located pedestrian crossing and a footpath link;"

REP2: OBJECTION TO CRITERION 5 OF AL7 - INCONSISTENT POLICY WORDING
5 I am of the view that there is an inconsistency between the policies and their supporting text concerning the treatment of the landscape surrounding Fishbourne and that surrounding Bosham, particularly that part of the village north of the A259. Consequently the policy wording is not effective and will not deliver the most appropriate strategy for the site.

6 Policy AL10 allocates land at Chidham and Hambrook for 500 dwellings. Policy AL9 allocates land at Fishbourne for 250 dwellings. Criterion 5 of each of these policies considers issues of landscape impact when it states:
"Detailed consideration of the impact of development on the surrounding landscape,
including the South Downs National Park and Chichester Harbour AONB and their
settings. Development should be designed to protect long-distance views to the South
Downs National Park;

7 It is logical to include the same criterion 5 in each of these policies since both settlements are close to the South Downs National Park and Chichester Harbour AONB. Bosham occupies a location between Fishbourne and Chidham/Hambrook settlements. Bosham experiences exactly the same setting as those settlements referenced under PolicyAL9 and AL10.

8 It is therefore surprising that criterion 5 of Policy AL7 relating to Bosham states:
"Provision of landscaping and screening to minimise the impact of development on
Bosham, and the setting of the Chichester Harbour AONB and South Downs National
Park, including views to and from the wider and surrounding area;"

9 My concern is that the wording of this criterion implies less stringent assessment and appraisal of the landscape setting related to the AL7 allocation than is the case with Policy AL9 and AL10. This is despite Highgrove Farm Bosham having an arguably more sensitive relationship to the Chichester Harbour AONB and with clear views across the site to the South Downs National Park. The consequence of this is that there is no policy requirement in policy AL7 for a "detailed consideration of the impact of development on the surrounding landscape". The criterion 5 wording of AL7 also does not include any requirement for proposals to be "designed to protect long-distance views to the South Downs National Park".

10 A Landscape Capacity Study November 2018 has been undertaken by Terra Firma for Chichester District Council. The site at AL7 falls within character sub area 91 of the study. The assessment section of this study makes reference to the long views across the study area to the hills within the SDNP and to the valued views identified in the Bosham Parish Neighbourhood Plan. The conclusion and recommendation includes the statement that "Great care would need to be taken to avoid any landscape or visual harm ensuring the separate identities of the settlements are protected and considering valued views". This strengthens the argument for a more robust set of criteria similar to that for policies AL9 and AL10.

11 The lack of such a policy wording implies that the landscaping and design associated with the Highgrove site (SA7) will be judged against a lower threshold than with the AL9 and AL10 housing allocations. The policy is therefore not effective and neither would it deliver an appropriate design strategy for the site

12 It is proposed that to ensure that the plan is consistent, sound and recognises the same sensitivity as a result of the proximity of the Chichester Harbour AONB, criterion 5 be amended to state:
"Detailed consideration of the impact of development on the surrounding landscape, including the South Downs National Park and Chichester Harbour AONB and their settings. Development should be designed to protect long-distance views to the South Downs National Park and Chichester Harbour. Provision of landscaping and screening to minimise the impact of development on Bosham, and the setting of the Chichester Harbour AONB and South Downs National Park, including views to and from the wider and surrounding area shall form an integral part of any application;

REP3: OBJECTION TO PARAGRAPH 6.56
13 This paragraph is in the preamble to Policy AL7 and sets out the specific issues that need to be taken into consideration when planning the development of the allocated site.

14 In paragraph 6.65 of the Policy AL9 the preamble states that:
"Protecting the separate distinct identity of Fishbourne in relationship to surrounding settlements, including Chichester City;"

15 This is logical since the development of 250 homes on land around this settlement could result in a design which is out of keeping with the wider character of the area. In addition, Fishbourne is close to Bosham and consideration of design needs to recognise and plan for that proximity.

16 In the case of Bosham, no issue relating to 'distinct identity' is raised in the supporting text. This is considered to be unsound because the settlement of Bosham has a particular distinct identity and the AL7 allocation is on the eastern side of the village and would draw development closer to Fishbourne. It cannot be the case that Fishbourne has supporting text which seeks to protect its special identity but Bosham, with a large allocation does not. This would not deliver an effective plan due to the inconsistency and neither would it deliver an appropriate growth strategy for Bosham

17 The settlement or village of Bosham is comprised of two built up areas. A neighbourhood called Broadbridge to the north of the A259 and an area located around the historic harbour. Whilst physically separate, they each form part of 'the village' and are interrelated in terms of activity and service offer. The allocation of 250 new homes at Highgrove is a significant number when compared to the existing number of dwellings in Bosham. Consequently, it is important that the identity of Bosham is carefully considered when designs are drawn up. The NPPF continues to advise that design should be of a high quality and certainly this is an important issue when setting the policy context for AL7.

18 It is recommended that a new bullet point be added to paragraph 5.56 which states:
"Protecting the separate distinct identity of Bosham in relationship to surrounding
settlements, including Fishbourne;"

REP4: OBJECTION TO POLICY AL7
19 I am concerned that the policy fails to give appropriate guidance on matters of environmental importance and this is contrary to the NPPF. In both policy AL9 and AL10, a criterion states:
"Demonstration that development would not have an adverse impact on the nature conservation interest of identified sites and habitats;"

20 There is no such criterion in the case of the Highgrove allocation AL7. Environmental assessments have already taken place in connection with application 17/03148/FUL and the site allocations document which allocates a smaller part of Highgrove Farm for 50 dwelling units. This research has identified a population of slow worms on the site. It is also the case that Brent Geese, a species protected under Law, have used the open fields for landing. Given that there is ecology of acknowledged importance, it is considered that to be compliant with NPPF a criterion should be added which protects the habitat and ecology of the area. This would comply with NPPF and be consistent with the way other sites have been treated. The new criterion should state:
"Demonstration that development would not have an adverse impact on the nature conservation interest of identified sites and habitats;"

REP5: OBJECTION TO POLICY AL7
21 Policy AL9 and AL10 include a criterion which states:
"Provide mitigation to ensure the protection of the SPA, SAC and Ramsar site at Chichester Harbour as a result of water quality issues relating to runoff into a designated site, and loss of functionally linked supporting habitat;"

22 Policy AL7 does not include this criterion yet the allocation is as close to the protected Harbour and water courses that flow into it as the sites promoted at AL9 and AL10. In the case of Highgrove Farm there is a drainage ditch running along the southwest corner which would need effective management to ensure hydro carbon pollutants do not enter the catchment. It is therefore inconsistent and contrary to NPPF that AL7 does not have the same criterion. A new criterion should be included which states:
"Provide mitigation to ensure the protection of the SPA, SAC and Ramsar site at Chichester Harbour as a result of water quality issues relating to runoff into a designated site, and loss of functionally linked supporting habitat;"

REP6: OBJECTION TO POLICY AL7
23 A consultation exercise carried out by Bosham Parish Council in December 2018 revealed widespread local concern and anecdotal evidence concerning the ability of the site to drain safely and effectively. The drainage ditch to the southwest corner regularly floods as a result of it being of insufficient capacity and poor management. There is a high water table on the site which aggravates the situation. There is no robust or credible evidence to suggest that this issue should not be specifically identified as a criterion in Policy AL7.

24 The approved development of 50 houses at Highgrove (17/03148/FUL) has a significant area within the development site which is required for storm surface water balancing ponds/SuDS /underground storm water crates within the open space area. For a 250 house scheme the area requirements for would be significantly higher. Any area required for drainage should sit outside of that required for open space, ecological mitigation and other community infrastructure. The number of houses proposed should take into account the space required for the storm surface water balancing ponds/SuDS /underground storm water crates.

25 It is therefore considered that some on site Suds or attenuation pond will be necessary as part of the scheme. The area necessary would need to be established through studies and would need to be independent of the overall open space requirement of the site. AL7 should link to Policy DM18 and the requirements contained in that policy.

REP7 - OBJECTION TO POLICY DM34 - OPEN SPACE
26 The revised Open Space, Sport and Recreation Study including Indoor Sports Facilities and Playing Pitch 2018 has reduced the requirement for open space by almost a third across the whole district compared with the previous policy approach. The District wide reduction in open space requirements may penalise those Parishes where an existing shortfall exists. It is not an appropriate strategy compared with the previous standards for open space.

27 The information in Table 14 of the Chichester open Space Study (Main Report) September 2018 shows that Bosham has the third highest shortfall in the parishes in the District of Parks and Recreation Grounds combined. The extract of the table below shows that in every category Bosham has a significant deficiency.


It is considered that the new standards should not form the basis for the open space requirements for AL7 and that the previous standards should be retained to address the circumstances of Bosham.

REP 8 - OBJECTION TO POLICY AL7 IN RESPECT OF LANDSCAPE CAPACITY, POLICY DM28 NATURAL ENVIRONMENT AND DM19 CHAONB
28 The Highgrove site is located on grade 1 and 2 agricultural land. It would have an adverse impact on the setting of the CHAONB.

29 The draft Landscape Capacity Study (published by Terra Firma, November 2018) concludes that the landscape in which AL7 draft site allocation is located has only medium/ low capacity for landscape change and states "Great care would need to be taken to avoid any landscape or visual harm ensuring the separate identities of the settlements are protected and considering valued views".

30 The character area in which Policy AL7 is located has been assessed as having a medium/ low capacity. The definition of this is:
Medium / Low capacity (orange) - A low amount of development may be accommodated only in limited situations, providing it has regard to the setting and form of existing settlement and the character and the sensitivity of adjacent landscape character areas. In some cases no development would be acceptable and the reason for this is explained in the conclusion.

31 The final paragraph of the character area assessment states:
It is possible that some built development may be accommodated within the existing cluster of buildings and potentially to the north of Broadbridge provided it is informed by further landscape and visual impact assessment and sensitively integrated into the landscape, respecting the historic settlement pattern and local distinctiveness. Great care would be needed to be taken to avoid any landscape or visual harm ensuring the separate identities of the settlements are protected and considering valued views. (NB the BPNP identifies valued views across Highgrove to the South Downs)

32 The housing numbers proposed in Policy AL7 should be reviewed in the light of the Terra Firma assessment conclusions and also the need for on site SUDS and drainage, a 2 form entry school, open space, suitable landscaping and mitigation, suitable ecological mitigation and impacts on the CHAONB. Any development must also have regard to the character of the area and a density which reflects that of the surrounding area. It is noted that Draft Policy DM3 explains at criterion 'b' that locations adjacent to sensitive locations may justify lower densities.

33 The policy AL7 should be reworded to ensure that the extent, layout and numbers proposed in the policy can be achieved while taking account of the above representations.