Having trawled through the CDC Local Plan, which I have to say at the outset is the least user friendly document I have had the misfortune to read in a long time. The sceptic amongst me , would claim that CDC has deliberately done its best to make it as inaccessible as possible and these points go to explain my reasons for coming to that conclusion.

:- It was released just before Christmas, when CDC knows that people are busy.
:- It was released with very little advertising and only now has there been a little more effort but still not enough..
:- Very few public exhibitions have been put on or advertised , many actually put on by local communities horrified at what has been included.
:- Only available really to those who have access to the internet as there is a charge of £15 for a paper copy so excluding many of the older generation who do not have access to the internet.
:- the fact that the software being used only allows one response from an email address. Any others are not acknowledged.

I would like these issued raised and acknowledged. For such an important Consultation to be conducted in this matter is harmful and actually against a democratic process.

I have commented electronically but because of the constraint of 100 words this makes commenting properly very restrictive , I am therefore submitting this email as well and insist that both my electronic comments/objections are taken together and that neither is excluded.
I welcome a need for a Local Plan to safe guard the uniqueness and sustainability of our beautiful city, but this plan is wholly unfit for purpose. In places it is so biased and contradictory , it has actually made me laugh ! This is a Local Plan so why has there only been development in the South , East and West. For some reason Goodwood and the North has either been included and then removed or excluded completely. This is not a LOCAL PLAN, this is a biased and incomplete plan because of this exclusion.

The Southern and western areas that border Chichester Harbour AONB have been repeatedly included in the plan for significant development despite having the a same or greater criteria for exclusion than Goodwood and the area to the south SDNP which have been excluded. This invalidates the Plan as it contradicts all the criteria used and makes a mockery of the Plans integrity.

TRANSPORT

The transport study done by Peter Brett Assoc (PBA) is completely unfit for purpose. The study has only explored short term transport infrastructure which is completely unacceptable for this Plan which specifically states that is should be looking at short, medium and long term transport models especially the considering the Plan is supposed to last until 2035. It has included a link road in AL6 which was roundly opposed in the democratic Highways England (HE) consultation of 2016 along with hybrids of Options 2 and 3 also rejected, so it should not have been included unless all other options including the preferred Mitigated Northern route had also been included.

There has been no detail of how these large housing developments (over 2000 homes) along the A259 are going to access the A27 which is already at full capacity at the Fishbourne Roundabout. There is also no evidence that the required consultations between CDC, PBA and HE have taken place so any inclusion of link roads and junction upgrades are invalidate and should be removed and if not adequately addressed in future iterations of this plan , I will raise it with the examiner at the appropriate time .The PBA actually claims that there will not be an increase in air/noise/pollution by the building of a link road. REALLY ! You are proposing to build an elevated road (due to it being on a floodplain 3 zone !) which would have to be 4 metres high in an open flat topography, bordering the highly sensitive Chichester Harbour AONB with dark skies and noise/air pollution protection and restricting right turns only, necessitating Stockbridge and Whyke roundanabout traffic to travel twice as far and the report states that there would be no increase in air pollution.Absolutely ridiculous and totally unrealistic.They also state that there will be no further increase in air pollution despite traffic volume increasing year on year. Chichester, especially Stockbridge Roundabout has frequently breached air quality limits in recent years and continues to do so. So this part of the report is just nonsense.(DM24/SP28)
There is also no mention of any realistic funding. Again you cannot include junction upgrades which come under the jurisdiction of HE and for which no consultation evidence has been shown in the report. CDC Local Plan should not include any upgrades that they do not have confirmed funding for when the plan is produced. Anyone can produce a plan with a nice wish list but this does not make a professional /viable document .
CDC said itself that "any highways improvements should mitigate congestion on the A27"....the limited detail in this plan actually adds to the congestion it does not mitigate it and it again hugely disadvantages local traffic.

All the proposed developments along the A259, at Chidham/Hambrook, Bosham, Southbourne and Fishbourne all claim that they are sustainable because they have good transport links in the form of bus and rail links. They do not and these transport link viabilty and frequency cannot be influenced by CDC as they are run by independent companies. At present the bus service is fairly frequent at peak times but other times is not so cannot be relied upon. It is also not a very cheap option for many people. Rail links have been cut significantly in recent years with timetable rearrangements and places like Bosham and Southbourne have one train stopping once an hour at peak times, to and from Chichester. Not what I would call good links. and again is expensive..£2.80 for a single from Fishbourne...a journey of 5 minutes !! So these developments would realistically rely on cars again so increasing the burden on the Fishbourne of Emsworth junctions that are already running at full capacity.

Unless these issues are adequately addressed in future iterations of this plan, i will raise it with the examiner at the appropriate time.

HOUSING

( including 3.17,S3,S5,S19,4.3 )

Why is CDC not insisting that SDNP take back responsibility for the allocation of 41 houses a year . It would remove the need for CDC to find areas for another 200+ houses within their local plan and SDNP should be promoting small scale house building within the Park in order to sustain local services such as schools and local services which will die if more families are not encouraged.

Why has the north of Chichester ,been removed from the plan...houses along the A259 amount to well over 2000 houses with the same environmental sensitivities and yet houses south of the SDNP to Chichester NONE. There is no justification for this as there is suitable land around Goodwood airfield and Rolls Royce that could be used and was originally included in the plan but again was removed for no justifiable reason. Why can large villages like Lavant and Boxgrove not have any housing allocation ? They are classed as local service hubs as they have shops and schools and yet are excluded. Unless this is adequately addressed in future iterations of the plan, I will raise this with the examiner at the appropriate time.

New housing need to be smaller less intrusive developments so that they don't overwhelm and swamp existing residential areas. They also need to be a majority of affordable housing for people with local connections. These local connections should actually mean people born in the city or whose parents have lived in the area for the majority of their lives. Local young adults don't stand a hope of buying or even renting in Chichester as the prices are so high compared to wages of most ordinary people.There should be a ban on second homes and but if they do slip though and are rented out, then rents should be capped to make it less attractive to landlords.

New developments should not include 'executive' 4 and 5 bedroomed houses. There are enough of these in Chichester and so developments should consist of 1, 2 and 3 bedroomed properties only with a few 4 bedroomed houses to satisfy housing association demand.

Why are brownfield sites like the one bordering Swanfield Drive / Portfield near Sainsburys not being used for housing if demand is so crucial. We do not need anymore out of town entertainment which is killing the town centre.It should be reclassified for housing , as it would have less impact, is within walking distance of services and already borders residential areas..

Unless these issues are adequately addressed in future iterations of the plan, I will raise it with examiner at the appropriate time.

SCHOOLS/SERVICE INFRASTRUCTURES

(including 4.85)

Although there is lip service paid to providing schools, it is all very vague. If you are building developments of 250 + then you are going to need school provision. Most schools in places like Bosham are already at full capacity from local children so expansion or new schools need to be built very early on in any development. The threshold should be very low , for example when the 50th house of 250 is built, that way the services will already be in place before the houses are occupied. Most primary schools within Chichester city and surrounding villages are now already at full capacity necessitating parents to have to travel in cars to get their children to less local schools. The schools like Parklands Primary that have been expanded recently to take two form entry have suffered from substandard design and building. Stairs out of action for months. Disabled toilet out of use and worst of all classrooms too hot in summer due to lack of air conditioning which meant children had to be sent home for several days. This particular issue has still not been addressed so will occur next year when the temperature rises.

Although the Free School has recently been completed( but because of its site requires most children to access by car at least some if not all of the way,) relieving pressures on primary and secondary school places, no provision has been made for future developments around the southern peninsula of Witterings/ Bracklesham etc which necessitates huge transport movement twice a day as there is no secondary school provision within a 6 mile radius.

Funding for such new schools are not funded by CDC and therefore these should have been properly costed and funded before they could be legitimately included in the Local Plan...again a fictitious wish list !!

No mention of where people are going to find other services such as doctors and dentist, many of which are already running at full or near full capacity.If there are no services available locally then people will be forced to travel. No mention of increased travel because of this and lack of local school places in the Local Plan.

Unless these issues are adequately addressed in future iterations of this plan, I will raise it with the examiner at the appropriate time.

AIR QUALITY

DM24/SP28 There is no acknowledgement of the fact that the air quality levels especially at Stockbridge Roundabout exceeds quite substantially acceptable levels set by the Government. Such an omission is significant and has a huge influence on future planned developments and unless it is adequately addressed in future iterations of the plan, I will raise this with examiner at the appropriate time

AL6.

Well where do I start on such an utter inaccurate piece of wilful destruction and vandalism. AL6 contradicts everything that the Local plan states .
It does not protect the biodiversity of the area...It DESTROYS it
It does not protect the historic views of the only Cathedral visible from the sea...It DESTROYS it.
It does not enhance the natural environment (S26)... It DESTROYS it
It does has an adverse impact on the openness of views in and around the coast. (S26)..It DESTROYS them.
It does not have regard to flood and erosion policy (S27)...It WILL increase the likelyhood of flooding and contamination of Chichester Harbour water.
It does not protect the area from light/air/noise pollution(DM23/24 etc)....it would DESTROY the dark skies policy and hugely increase air pollution.

I could continue. AL6 should be removed completely. The Plan itself states that no proper study has been done into the impact of AL6 and so that very admission should have been enough to exclude it from the plan.How can you include a destructive option like this without doing any sort of environmental study or impact study first. Unprofessional and disgraceful AL6 comes within 100 metres of Chichester Harbour which has AONB status which holds the same protection as the SDNP but does not have the same 5km exclusion that the SDNP has been given....strange that !! Unfortunately Chichester Harbour does not have a landed Estate as its neighbour !!

AL6 is on a category 3 Floodplain , which under Governments own rational means that it should not be developed for housing or industry at all because of the unacceptable flood risk and only then developed if ALL other less risky sites have been developed first and only then for suitable light use. Land to the south of the SDNP has been removed due to it being under risk of flooding and yet it is mainly classed as Flood zone 2 , a lesser risk. So why was it removed for this reason and AL6 left in place ?
INCONSISTENCY and BIAS. REMOVE AL6.

Under CDC own data, a link road would need to be elevated to 4 metres in order to be safe from flooding.How on earth are you going to mitigate a road that high which is on a flat topography with historic views of Chichester and the Cathedral ? .This would then contravene Government policy on pollution and housing , as the toxic fumes from the road would reach higher into the air.REMOVE AL6.

This link road and Options 2/3 were hugely unpopular in the 2016 Highways England Democratic Consultation and were emphatically rejected by the vast majority of Chichester residents as they knew it would be short term and ineffectual and that along with the no right turns at junctions would hugely hinder the movement of local traffic. CDC were seen to accept that and Cllr Dignum said that "any Highways improvement should mitigate congestion on the A27". Clearly this scheme would not and so why is the link road included. If you want an unbiased complete Plan then surely the mitigated Northern route should have been included in this plan as the criteria are the same...no funding and no HE acceptance, or exclude both proposals. Again double standards to the detriment of the south.No roads should have been included as they do not come under CDC remit or funding and the protection under Para 3 AL6 is unachievable. Total betrayal under Cllr Dignum leadership.REMOVE AL6

In order to instigate a link road , junction upgrades are also mentioned...(but not funded by CDC and no consultation evidence with HE in the Local Plan S23 and PBA report) Each junction is estimated to take a minimum of 3 yrs to complete, that's 15 years of gridlock, air pollution and misery. Seriously. Chichester city and tourist industry would be destroyed. REMOVE AL6

There is no mention of only a 100 metre border with the Chichester Harbour AONB and yet frequent reference is made to the SDNP 1km border. Double standards and inconsistency again.REMOVE AL6

There is no mention that the land earmarked in AL6 is floodplain 3 category. Frequent reference to SDNP/Goodwood being in Flood zone 2 and a small amount in Flood plain 3. Again double standards and inconsistency. REMOVE AL6

No mention to the destruction of the views and yet time and again SDNP/Goodwood views of the Cathedral are mentioned and pushed. The views from SDNP/Goodwood are far less prominent and actually are invisible because of the topography of the land in many places. Not the case for views in AL6 where uninterrupted views of the Cathedral can be seen from the coast in almost any position looking north. Double standards and inconsistency again.REMOVE AL6

No amount of mitigation could protect Chichester Harbours unique ecology. It has status as an AONB, SPA,SAC,SSSI and is a Ramsar site. There is no detail of how a successful buffer zone would be applied.There appears to be no room for a proper successful wildlife buffer zone, with proposed building up to 100 meters of the harbour.There would be significant adverse ecological damage done, from light, noise and especially air pollution,which already breaches Government and EU safe levels. There is no mention of waste water management and the capacity for any further waste water to be processed at Apuldram Water Treatment plant is not an option as it has reached capacity so the risk of polluted water entering Chichester Harbour is incredibly high and an unacceptable risk.(Policy S18) REMOVE AL6

There are other much more suitable areas already identified around Goodwood Airfield and Rolls Royce which meet the criteria set out in the plan for housing and light industrial employment and already have suitable infrastructure but have been unjustifiably removed. These should be reinstated and AL6 REMOVED.

Any development of AL6 would necessitate movement by car due to its proximity to the A27 .This is against CDC Local plan policy of encouraging any new developments to either be well served with public transport or sustainable transport ie cycling and walking. The position of this site will not meet this criteria. REMOVE AL6.

There is no mention of the fact that this site is part of the River Lavant floodplain. Those of us who remember the 1990's , remember the hugely damaging flooding that affected Chichester partly because the water courses and natural drainage had been allowed to deteriorate. AL6 covers a significant part of the River Lavant natural drainage basin. It would be insane to build on this land. It could well result in renewed flooding in the city centre as we get wetter winters and the rain water has no where to go.REMOVE AL6.

The plan is totally inconsistent as to numbers in the development. How can we possibly comment on a plan that in one place states there would be 100 houses and industrial units in AL6 and yet elsewhere it says 200 + homes and industrial units. Ridiculous inconsistency and very unprofessional. REMOVE AL6.

Unless all these issues are adequately addressed in future iterations of the plan, I will raise these with the examiner at the appropriate time.

In summary, The CDC Local Plan in its form at present should be rejected and rewritten with the inconsistency and bias removed. Any development site should only be include when a proper and realistic viability study has been commissioned by independent consultants who will have been given a complete and unbiased brief (unlike the PBA study which is incomplete ,short term and does not reach the brief that was supposedly set). This is hugely important to the Chichester area and its residents. We want and deserve a fair ,complete and transparent plan and this version is not.

CDC along with WSCC should go to central Government and insist that until proper funding is put in places to sort the transport/A27 and services (Schools etc) infrastructure out then although the Plan can be written, no housing will be built until funding has been secured and work started on this vital infrastructure. We cannot sustain this level of development without serious investment on infrastructure and the addressing of dangerous pollution levels because of the lack of it.

Until this Plan has been fairly and properly amended so it provides a properly informed, fair and complete document it should not be adopted and should then be rewritten and only then reissued for full public consultation again. Unless this is adequately addressed in future iterations, I will raise it with the examiner at the appropriate time.