We would need to have a clearer idea of housing location to comment in more depth however would wish to see a reduction in the allocation at this location.

The Chichester Harbour Trust objects to the allocation at A13 at Southbourne. This proposal represents major development adjacent to the Chichester Harbour AONB and is disproportionate to the size and facilities of the existing settlement. It is within the 5.6km zone of influence for Chichester Harbour SSSI. It is our observation that this allocation represents a conflict with the policies outlined in the Plan chapter 4 on the natural environment, which makes it hard to justify the soundness of the Plan, particularly: Policy NE2 Natural Landscape Policy NE3 Landscape Gaps between settlements Policy NE6 Chichester’s Internationally and Nationally Designated Habitats Policy NE7 Development and Disturbance of Birds in Chichester and Langstone Harbours, Pagham Harbour, Solent and Dorset Coast Special Protection Areas and Medmerry Compensatory Habitat Policy NE13 Chichester Harbour Area of Outstanding Natural Beauty Policy NE16 Water Management and Water Quality

It is difficult to make an assessment of the impact of housing development in the broad location without specific site allocation plans, which we understand would come through the neighbourhood plan process. However our general concerns about the allocation relate to: - the impact on the sensitive landscape setting of the AONB and loss of open views to the South Downs
- the over-reliance on developing greenfield sites, mostly on grade 1 & 2 agricultural land leading to concerns about unsustainable loss of countryside and impact on food production and food security
- the inadequate waste water treatment infrastructure at Thornham WWTW and lack of funded improvements in the timescales required
- the additional flood risk and ground water issues raised by construction on low lying coastal plain sites
- the impact on biodiversity and species that rely on the interconnectivity between the protected landscapes
- the additional recreational pressure within the SSSI zone of influence
- the inevitable increase in air, noise, and soil pollution

Overall, we feel that the allocation does not reflect emerging government rhetoric (which may soon translate to policy through the NPPF) about overdevelopment of countryside in the South East of England, and that the timescale is not compatible with the NPPF review which may lead to an alternative method of determining housing allocations in the district. For this reason we find the plan to be unsound.