Policy S28: Pollution

Showing comments and forms 1 to 30 of 30

Comment

Local Plan Review: Preferred Approach 2016-2035

Representation ID: 373

Received: 05/02/2019

Respondent: Mr Pieter Montyn

Representation Summary:

Policy 28 does is vague and does not specifically refer to air quality, soil. light and noise.
Policy should include reference to Policies DM 23, 24 and 25.

Full text:

Policy 28 does is vague and does not specifically refer to air quality, soil. light and noise.
Policy should include reference to Policies DM 23, 24 and 25.

Object

Local Plan Review: Preferred Approach 2016-2035

Representation ID: 467

Received: 01/02/2019

Respondent: Mr Neil Hipkiss

Representation Summary:

This policy ignores pollution that is already outside appropriate guidelines, e.g. the Stockbridge AQMA, which has been above the maximum allowed NO2 measure for over 6 years. This is unacceptable.

Regarding pollution generated by future developments, a policy committing the Council to "...require that the impacts are minimised and/or mitigated to an acceptable level" is quite simply not good enough and needs to be more specific.

Full text:

This policy ignores pollution that is already outside appropriate guidelines, e.g. the Stockbridge AQMA, which has been above the maximum allowed NO2 measure for over 6 years. This is unacceptable.

Regarding pollution generated by future developments, a policy committing the Council to "...require that the impacts are minimised and/or mitigated to an acceptable level" is quite simply not good enough and needs to be more specific.

Comment

Local Plan Review: Preferred Approach 2016-2035

Representation ID: 515

Received: 29/01/2019

Respondent: Sam Pickford

Representation Summary:

This policy as it is not detailed enough. I would like to see more monitoring and more measures to be included in this policy to ensure actions are taken. These should include Clean Air Zones introduced, cleaner buses, car free day, workplace parking levy, anti-idling zones, increased pedestrianised areas in our villages and towns, better joined up cycle network

Full text:

I have some comments on the Chichester Local Plan I wish to submit:

1) S28 and DM24 Pollution
This policy as it is not detailed enough. I would like to see more monitoring and more measures to be included in this policy to ensure actions are taken. These should include Clean Air Zones introduced, cleaner buses, car free day, workplace parking levy, anti-idling zones, increased pedestrianised areas in our villages and towns, better joined up cycle network

2) Policy AL6 - Land South-West of Chichester
I am opposed to the Stockbridge Relief Road and the allocation of houses to Apuldram and Donnington as it is too close to the AONB, on a floodplain and destroys prime agricultural land.

3) DM 16 Sustainable Design and Construction
The plan should acknowledge the need for the area to become carbon neutral in order to prevent climate change.
Manchester has committed that all new buildings will be net-zero carbon. This should be included in the Chichester Plan.

4) DM17 Stand-alone Renewable Energy
The plan should put aside space for renewable energy as a priority. We need space for wind turbines, battery storage and more solar panels on the roofs. Provision may be required on the coast for enabling the connection of an off-shore wind farm.

5) SA5 Southern Gateway
This policy needs to deliver better plans for people walking and cycling.
The green space should be preserved and an additional pocket park added to the area

The city needs a welcoming bus and train station, a proper public transport hub with toilets, tourist information, waiting area in the dry, warm and shade and proper information with RTPI screens (not just bus stops). The current bus and stations are hideous and unwelcoming and are not in keeping with the rest of the city.

6) S23 Transport and Accessibility
A coordinated package of improvements to junctions within the city is missing from this policy.

The roundabouts on Westhampnett Road near Sainsbury's, New Park Road near the new Coop, Eastgate, Northgate, Westgate and Southgate need redesigning to allocate more space to people on bikes and on foot.

More bus lanes and a linked up and continuous network of proper, protected cycle lanes need to be introduced.

St Paul's Road and Bognor Road need to have less private car parking to enable sustainable means to be prioritised - bus and bike lanes.

Transport measures need to ensure that we reduce our carbon footprint as emissions in this sector are still on the rise.

7) Policy S5 - Parish Housing Requirements
A Second home policy should be introduced to prevent an over dominance of new homes being sold to non-residents.

8) Policy S30
Wildlife Corridors need support but the wording needs to be made stronger so that development within this corridor is not permitted. The plan needs a stronger commitment to the preservation of wildlife within the area, in its current form it is lacking.

All proposals should demonstrate that they will have a net zero impact on climate change in line with the government's commitment in 2008 Climate Change Act as a signatory to COP21 Paris Agreement and the IPCC's report published in the autumn of 2018.

Object

Local Plan Review: Preferred Approach 2016-2035

Representation ID: 574

Received: 29/01/2019

Respondent: Mrs Stephanie Carn

Representation Summary:

This policy is so weak it offers little protection to the environment or to people. There is a presumption that development of housing and roads is necessary. It should be seen the other way round. Protection form pollution is the necessary thing here, and any proposed housing , roads, industry should follow that.

there is no mention of climate change and possible detrimental effects.

Full text:

This policy is so weak it offers little protection to the environment or to people. There is a presumption that development of housing and roads is necessary. It should be seen the other way round. Protection form pollution is the necessary thing here, and any proposed housing , roads, industry should follow that.

there is no mention of climate change and possible detrimental effects.

Comment

Local Plan Review: Preferred Approach 2016-2035

Representation ID: 630

Received: 25/01/2019

Respondent: Mr Philip Waters

Representation Summary:

Air Quality will further deteriorate as a result of the proposed plans. Stockbridge already exceeds the recommended air quality levels and development on this scale will increase the problem. This has serious health implications for residents.

Full text:

I am a resident of Donnington and am disappointed with the ridiculous scheme which you are proposing. In addition, I have not the slightest confidence that the scheme will be completed within budget and on time. The footbridge at the Stockbridge roundabout was a fiasco and if you cannot complete such a relatively small project, I am not convinced any of you are capable of taking on a much larger scheme.

I agree with all of our parish council recommendations and comments below.

DONNINGTON PARISH COUNCIL OBJECTIONS
Donnington residents will be hugely disadvantaged by proposed changes to A27 access arrangements under Policy S23 and the Peter Brett Associates report - effectively no access to the East from Donnington (or the Manhood Peninsula) via A27 unless residents either head West first, encountering the amended Fishbourne Roundabout which will prioritise through traffic and will include an additional junction. Alternative routes to the East are either through the City or via unsuitable "back roads", increasing traffic levels through Hunston and North Mundham. Increased traffic from Whyke (facing the same issue) will cause even more congestion between Donnington and Fishbourne.
* Site AL6 Land South West of Chichester (Apuldram and Donnington parishes) includes a flood plain. Using data from CDC's flood plain assessment, the average height of flood water on the River Lavant is 2.05 metres (6.07 feet) above datum (sea level). This means that the road will have to be elevated by at least 2.5 metres and more with the supporting structures and road thickness itself. Therefore nearer 4 metres (13 feet). This would destroy the iconic views of the cathedral framed by the South Downs. The protection proposed by para 3 of Policy AL6 is unachievable. REMOVE POLICY AL6
* Each of the five junction modifications will require three years of work. This means 15 years of misery for Chichester residents whilst the junction works take place. We all remember the chaos caused by the replacement of one footbridge in Stockbridge, bringing gridlock to the area. (Policy S23 and Peter Brett Associates Transport Assessment)
* Overall, the plans for improvements to the junctions are to the advantage of through traffic not local residents. The proposals bear a marked similarity to Option 3a from the Highways England Improvements to the Chichester A27 Bypass consultation, which were emphatically rejected by the local community - in Donnington and across the whole of Chichester. (Policy SP23 and Peter Brett Transport Assessment)
* Air Quality will further deteriorate as a result of the proposed plans. Stockbridge already exceeds the recommended air quality levels and development on this scale will increase the problem. This has serious health implications for residents. (Policy DM24 & SP28)
* The South Downs National Park should take its allocation of 41 dwellings per annum - without some low level development in the Park, particularly social housing, communities there will not thrive. (Policy S3, Policy S5 & Policy S19 )
* There are no proposals for any new primary schools in the Manhood Peninsula. This will only increase pressure on current schools to provide more places, and lead to increased traffic on the roads as parents are forced to commute to schools outside their local area where spaces may be available.
* Impact on ecology - the Chichester Harbour and surrounding area are designated as an Area of Outstanding Natural Beauty and have the status of being a Special Protection Area, Special Area of Conservation, Site of Special Scientific Interest and is a Ramsar site. It is wholly inappropriate to consider development on this scale in such close proximity to an area with this status. There will be a significantly adverse impact on the ecology of the area and mitigation is not sufficient. (Policy S18 Integrated Coastal Management Zone Manhood)
* Green tourism is a very important part of the Manhood Peninsula economy and to overdevelop and spoil the natural environment which attracts this trade would be inappropriate and hugely detrimental (Policy S18 Integrated Coastal Management Zone Manhood)
* A viable alternative site is available for industrial development within the buffer zone at Goodwood and the employment land should be allocated there. (Policy AL6, S15, S16)

Object

Local Plan Review: Preferred Approach 2016-2035

Representation ID: 710

Received: 01/02/2019

Respondent: Mrs Deborah Hack

Representation Summary:

I live in Donnington with my young family. We are encouraged to walk to school for health. Donnington is heavily congested most days and is horrendous in the summer. I question what the council are doing to decrease and ease this problem in this area full of families? I worry about the health of my young children and how the pollution is affecting them.

Full text:

I live in Donnington with my young family. We are encouraged to walk to school for health. Donnington is heavily congested most days and is horrendous in the summer. I question what the council are doing to decrease and ease this problem in this area full of families? I worry about the health of my young children and how the pollution is affecting them.

Object

Local Plan Review: Preferred Approach 2016-2035

Representation ID: 737

Received: 01/02/2019

Respondent: Mrs Fiona Horn

Representation Summary:

No substance. How are you going to mitigate huge increases in air and light pollution from all these developments ? Each new house generally generates 2 more cars in that area. Air pollution in Chichester city is already at dangerously high levels which are not being addressed and with each new development this is only going to get worse. Less green space , less natural lungs so greater air pollution and danger to health.

Full text:

No substance. How are you going to mitigate huge increases in air and light pollution from all these developments ? Each new house generally generates 2 more cars in that area. Air pollution in Chichester city is already at dangerously high levels which are not being addressed and with each new development this is only going to get worse. Less green space , less natural lungs so greater air pollution and danger to health.

Object

Local Plan Review: Preferred Approach 2016-2035

Representation ID: 773

Received: 01/02/2019

Respondent: Mr Neil Hipkiss

Representation Summary:

This policy ignores pollution that is already outside appropriate guidelines, e.g. the Stockbridge AQMA, which has been above the maximum allowed NO2 measure for over 6 years. This is unacceptable.

Regarding pollution generated by future developments, a policy committing the Council to "...require that the impacts are minimised and/or mitigated to an acceptable level" is quite simply not good enough and needs to be more specific.

Full text:

This policy ignores pollution that is already outside appropriate guidelines, e.g. the Stockbridge AQMA, which has been above the maximum allowed NO2 measure for over 6 years. This is unacceptable.

Regarding pollution generated by future developments, a policy committing the Council to "...require that the impacts are minimised and/or mitigated to an acceptable level" is quite simply not good enough and needs to be more specific.

Object

Local Plan Review: Preferred Approach 2016-2035

Representation ID: 798

Received: 02/02/2019

Respondent: Dr Lesley Bromley

Representation Summary:

Pollution assessment of any changes to the A27 with particular regard to pollution by particulate matter must be taken into consideration

Full text:

Pollution assessment of any changes to the A27 with particular regard to pollution by particulate matter must be taken into consideration

Comment

Local Plan Review: Preferred Approach 2016-2035

Representation ID: 857

Received: 02/02/2019

Respondent: Ms Valerie Briginshaw

Representation Summary:

The Council needs to do more to combat pollution. Poor air quality is one of our biggest problems in the city. I live in Orchard Street and witness daily the build up of traffic and pollution at certain times of the day. The Council needs to do much more to limit pollution caused by vehicles eg introduce clean air zones, clean buses, safe cycle routes, anti-idling zones, more electric car charging points, use of bus lanes, workplace parking levies, car sharing schemes for commuters, use of the car club rather than car ownership, car free days...etc .

Full text:

The Council needs to do more to combat pollution. Poor air quality is one of our biggest problems in the city. I live in Orchard Street and witness daily the build up of traffic and pollution at certain times of the day. The Council needs to do much more to limit pollution caused by vehicles eg introduce clean air zones, clean buses, safe cycle routes, anti-idling zones, more electric car charging points, use of bus lanes, workplace parking levies, car sharing schemes for commuters, use of the car club rather than car ownership, car free days...etc .

Object

Local Plan Review: Preferred Approach 2016-2035

Representation ID: 873

Received: 03/02/2019

Respondent: Karen Jelfs smith

Representation Summary:

This policy ignores pollution that is already outside appropriate guidelines, e.g. the Stockbridge AQMA, which has been above the maximum allowed NO2 measure for over 6 years. This is unacceptable.

Regarding pollution generated by future developments, a policy committing the Council to "...require that the impacts are minimised and/or mitigated to an acceptable level" is quite simply not good enough and needs to be more specific.

Full text:

This policy ignores pollution that is already outside appropriate guidelines, e.g. the Stockbridge AQMA, which has been above the maximum allowed NO2 measure for over 6 years. This is unacceptable.

Regarding pollution generated by future developments, a policy committing the Council to "...require that the impacts are minimised and/or mitigated to an acceptable level" is quite simply not good enough and needs to be more specific.

Object

Local Plan Review: Preferred Approach 2016-2035

Representation ID: 1068

Received: 05/02/2019

Respondent: Libby Alexander

Representation Summary:

Level of air pollution at Fishbourne roundabout is already breaking legal limits - what will happen with additional development?

Full text:

It is incomprehensible how anyone who lives in this area would contemplate permission for the number of homes that are being forced upon the local communities when this part of the country is so special. One would have to be blind not to look at a map of the South East of England and realise its slow death from concrete and congestion and here - especially west of Chichester is the last remaining foothold of sanity along the coast.
Chichester, a beautiful County Capital, is a Roman walled city with a Georgian centre - its roads reflect this wonderful heritage - THEY WERE NOT MADE FOR MODERN TRAFFIC LEVELS. This has a knock-on effect upon nearby villages including FISHBOURNE. The position of the Chichester Plains including FISHBOURNE is that it is caught between the SDNP and the sea. But that is no reason to concrete it over. All this is in YOUR CARE.Y

FISHBOURNE - The Present State
Fishbourne cannot be accused of Nimbyism - it has built more than the required number of houses requested on sensitive, sustainable sites and therefore there is no moral justification whatsoever to inflict the community with 250 more. There has been no explanation as to why this number and why Fishbourne from the CDC. Apparently the CDC has decided to classify Fishbourne as a 'service village'. Has anyone actually been to Fishbourne to verify this classification?
The truth is:
Fishbourne Parish Council has already submitted and enacted upon the Neighbourhood Plan with the full involvement and support from the local community.
Fishbourne has already reached its boundaries. It is crucial to the well being of communities and in the spirit of the Government's policies to prevent 'coalescence' of villages.
Fishbourne is a Conservation Area and the FISHBOURNE MEADOWS are a crucial part of it.
The Primary School is already filled with children from the catchment area. The Fishbourne Centre is so popular it is functioning at full capacity. The local church and its hall is likewise functioning at full capacity. The Fishbourne Playing Field facilities provide not only tennis courts, bowls, croquet, cricket, etc. and a fully equipped children's outdoor secure play area. All these are used on a regular basis. There is no doubt that Fishbourne is a thriving and active community and therefore there is NO CASE for further growth.

The Disastrous Consequences of Mass Unnecessary and Unwanted Development
If this is 'forced' upon the community it will break every democratically arrived at Policy of the Parish Council and anger the vast majority of residents for, by permitting a few houses on Bethwines Farm will open up the floodgates to 1000. This will destroy valuable green field agricultural land. It will exacerbate flooding. Will cause untold traffic congestion for with every household there will be two cars as a minimum creating gridlock on local roads. Will heighten the already dangerous levels of air pollution. The local sewerage plant in Apuldram is already at breaking point. All this on top of the already permitted 1600 homes at Whitehouse Farm north of Fishbourne. The chaos and damage to the roads, the noise, the mud, the dust, potential danger to locals due to confined sites etc during construction which could take years not months. The agricultural land in this area is of special importance to the national production of horticulture. It provides employment to 9,000 and creates £1 billion in sales - substantial statistics.
CHICHESTER HARBOUR
Is an AONB, an SSSI, a Ramsar, an SAC, an SPA, an SINC/SNCI, a Conservation Area, a Local Wildlife Site, and a Local Nature Reserve. This is the JEWEL IN THE CROWN. It is the duty of every citizen, especially those in Authority, to safeguard this valuable, irreplaceable asset, unharmed for the nation and future generations. NOTHING should be permitted that would endanger it in any way. So why is the Chichester District Council not fighting the Government to protect it? To protect it from:
Mass Developments that are not NEEDED that will damage the waters through flooding - including Apuldram sewerage outflow, will create pollution from additional traffic, will disturb the wildlife and tranquillity from growing disturbances, will create light pollution, and with the growth in population create damaging levels of litter, and many more.
A259 -Main Road
This is the only access for all the developments being planned and being built in Bosham, Chidham, Nutbourne and Southbourne (hundreds and in some instances thousands) that will accumulate at Fishbourne roundabout in order to access the A27 and the City. This route is the only one that all delivery trucks and all agricultural machinery can use. The traffic will continue to grow along this road as the bus schedules are being cut and the SW train service seems to be in permanent decline. This road is also the boundary to the Chichester Harbour Trust. How then will the CDC enforce the protections of the Trust? AIR POLLUTION
AIR POLLUTION
The UN in June 2017 is quoted as saying: 'Air pollution is Europe's leading environment killer'.
NAEI have a map of the Chichester Plains where the average levels are 0.1 - 0.3 but Fishbourne and Donnington roundabouts already reach 25!
Friends of the Earth are quoted as saying 'Costs to the UK of air pollution runs to £20 billion.
Living Streets say '80% of toxic nitrogen oxide concentrations are found at roadsides from motor traffic'.
'40,000 deaths annually are attributed to air pollution'
'38 out of 43 UK zones exceeded legal levels of nitrogen oxide emission in 2013.'
The UK is breaking the law with its current air pollution levels.
We now have children dying with 'air pollution' on their death certificates.
THE LEVELS AT FISHBOURNE ROUNDABOUT ARE ALREADY BREAKING LEGAL LIMITS
So what will these levels reach :
When all these 2250 scheduled developments with two cars per unit take place using the only road available - A259.
When the TRAFFIC DOUBLES OVER THE THREE SUMMER MONTHS creating gridlock down to the Manhood Peninsular
When your proposed Stockbridge link road - whose construction will break all the criteria laid down in the CDC policies by building across major flood plains, by restricting the protected views of the Cathedral, by building on the protected Fishbourne Meadows and into the AONB of Chichester Harbour, and end up TAKING ALL THE TRAFFIC ON TO THE FISHBOURNE ROUNDABOUT.
WILDLIFE CORRIDOR
The last minute offer of a Wildlife Corridor in an attempt to mitigate the horrors being inflicted upon this community you have placed in a narrow strip to the east of the village. This will immediately be irrelevant for it is too narrow, will pass through a built up environment which will lead to disturbances throughout the day, will lead to noise pollution, will lead to light pollution and will therefore NOT PROVIDE a safe haven for any wildlife. The obvious position for such a corridor would be to the WEST of FISHBOURNE where the open agricultural green field sites will enable all forms of wildlife to access both the Harbour Conservancy and the National Park safely.
THE A27
What is the point of this whole exercise when there has been no decision on the route of the A27. Until the CDC issues correct data on present traffic flows, until the CDC issues correct data on 'projected' traffic flows, until the CDC recognises that this is a NATIONAL STRATEGIC road and NOT A LOCAL road, until the CDC re presents the NORTHERN option, then no permissions for further developments should take place.
The Secretary of State for Housing is quoted as saying: 'The message it (NPPF) sends is clear and direct; we want the right number of homes in the right places. CENTRAL TO THIS IS THE VOICE OF THE COMMUNITIES.'
As the community's elected representatives it is your duty to protect the National Assets in this area. It is your duty to provide 'sustainable' developments that do not create or add to the highway safety, air pollution or any other damage to your communities. This area does not NEED new three/four bedroom houses. What it does need is AFFORDABLE housing. Part of the relief could come from allowing Affordable housing in the SDNP which would halt the decline of the communities, fill the empty schools, and provide continuing regeneration. Jake Berry MP in the Ministry of Housing has said that WHERE HOUSING IS NEEDED IS IN THE NORTH where the region is undergoing regeneration and businesses are relocating.
THE FISHBOURNE COMMUNITY
The Fishburne community has acted in good faith throughout this whole exercise. It is now up to the CDC to support it.

Comment

Local Plan Review: Preferred Approach 2016-2035

Representation ID: 1089

Received: 05/02/2019

Respondent: Mrs Claire Wilton

Representation Summary:

Introduce cleaner electric busses, safe cycle routes, car free days, workplace parking levies, more electric car charging points.

Full text:

More needs to be done to combat climate change by introducing cleaner electric busses, safe cycle routes, car free days, workplace parking levies, more electric car charging points.

Comment

Local Plan Review: Preferred Approach 2016-2035

Representation ID: 1328

Received: 06/02/2019

Respondent: Mr Simon Davenport

Representation Summary:

it s necessary to improve air quality not to avoid reduction but to actually encourage measures that can improve health for residents and be more attractive to visitors and tourists.

Full text:

it s necessary to improve air quality not to avoid reduction but to actually encourage measures that can improve health for residents and be more attractive to visitors and tourists.

Object

Local Plan Review: Preferred Approach 2016-2035

Representation ID: 1376

Received: 06/02/2019

Respondent: Miss Anna Gaymer

Representation Summary:

Air quality will further deteriorate as a result of the proposed plans. Stockbridge already exceeds the recommended air quality levels and development on this scale will increase the problem. This has serious health implications for the residents, especially the young and the old.

Full text:

Air quality will further deteriorate as a result of the proposed plans. Stockbridge already exceeds the recommended air quality levels and development on this scale will increase the problem. This has serious health implications for the residents, especially the young and the old.

Object

Local Plan Review: Preferred Approach 2016-2035

Representation ID: 1694

Received: 07/02/2019

Respondent: Mrs Zoe Neal

Representation Summary:

Please can you confirm what you are putting under the umbrella Pollution. Please list the mitigation and what an acceptable level is for each of the pollutants. Does S28 include Air, Light, Noise, Soil and Water Pollution?

Full text:

Please can you confirm what you are putting under the umbrella Pollution. Please list the mitigation and what an acceptable level is for each of the pollutants. Does S28 include Air, Light, Noise, Soil and Water Pollution?

Support

Local Plan Review: Preferred Approach 2016-2035

Representation ID: 1817

Received: 07/02/2019

Respondent: Ms Paula Chatfield

Representation Summary:

Support

Full text:

Support

Comment

Local Plan Review: Preferred Approach 2016-2035

Representation ID: 1865

Received: 06/02/2019

Respondent: Jennie Horn

Representation Summary:

- air/noise/pollution associated with the building of a link road
- increase in air pollution despite traffic volume increasing year on year

Full text:

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.

Comment

Local Plan Review: Preferred Approach 2016-2035

Representation ID: 1873

Received: 07/02/2019

Respondent: Jenny Cole

Representation Summary:

- We already have three AQA zones, how about more robust measures to counter private cars running on diesel and petrol?
- Where are the Park and Ride schemes out of town? I don't see any areas designated for this?

Full text:

Policy S23 A more robust tree and planting policy is required to ensure that Chichester District keeps as many trees and other green planting as possible to mitigate against traffic fumes. All street trees (WSCC) should be given priority over new developments, as mitigation measures (planted afterwards) will never make up for the ecology lost by felling, and removing already established hedges and trees etc. Where the trees aren't stree trees they need to be conserved with TPOs, so that it sends a clear message that Chichester needs its tree cover, particularity in the town centre and along the main roads to provide shade and oxygen, and temperature stability.
Promotion of more sustainable methods of transport, this means building more cycle routes (not just painting lines on roads). West Sussex CC are plainly failing to do this, (28 km planned over 5 years for the whole of the county) so District must work towards this by making sure that all developments have workable junctions onto main roads or off road routes built parallel and then sign posted. District Council may not build these, but it can find funding streams and push for them to be applied locally, and hold the developers to these plans promised, so that CIL money is spent wisely.
Support integration of trains and buses, again this should be a county function, but a unique opportunity to work to integrate the railway station and bus station will be lost in Chichester if the Southern Gateway goes ahead in its current form. And as for losing the taxi rank outside the station too, that beggars belief. Where are the fast charging points for electric cars at the station and throughout our town, West Sussex lags behind the rest of the country in provision, and Chichester especially with just two slow charging points outside the CDC offices which are always full.
Wildlife corridors need to be wider and bolder, and to allow crossings of the roads that block access. The ones on the east side of Chichester are particularly miserly. Most wildlife seems to be seen dead on the roads rather than in the wild. The whole reason for being in this area is that it hasn't got coastal development right along, but has access to the wider landscape of the sea and sky.
Objection to the building of a new road between the A27 and the Birdham Road A286. This particular part of Fishbourne being listed as floodplain 2 will need piling to support a road, which will destroy the character of the Fishbourne meadows and paths to the harbour/sea. This area should instead be a wildlife corridor rather than the site of industrial units.
S26 and S27 Concrete for housebuilding or industrial units or road building is at odds with the provisions for natural environment, and in dealing with floodplains. Any sea level rise or storm surge will make our natural environment more required as a buffer. Where is the provision for climate change? Unless we halt the use of fossil fuels and use more renewable energy there is no way out of this crisis. Building of houses and industry does not give us resilience to be able to cope with the future.
S28 Pollution. We already have three AQA zones, how about more robust measures to counter private cars running on diesel and petrol? Where are the Park and Ride schemes out of town? I don't see any areas designated for this?
S29 Green Infrastructure, the policies map showed no new green infrastructure, which is an opportunity missed.

Object

Local Plan Review: Preferred Approach 2016-2035

Representation ID: 1957

Received: 05/02/2019

Respondent: Ms Ann Stewart

Representation Summary:

Object on grounds that policy wording fails to acknowledge that traffic is a major cause of polution and that new transport routes are likely to add to the problem.

Full text:

Policy S 6. Affordable Housing
Paragraph 5.comment
Where a proposal is unable to meet the1 requirements for the delivery of affordable housing due to it rendering the proposal financially unviable, developers will be expected to assess options in accordance with the following

Changes Insert
1 Where the authority has been satisfied that a proposal is genuinely unable to meet the requirements

Justification
The required numbers of affordable housing are simply not being delivered.
Reports by the charities Shelter and CPRE show that developers frequently break promises about the number of affordable housing they will deliver, using a the "viability" loophole. The loophole involves paying high prices for land in the knowledge that the overpayment can be recouped by reducing the obligation to deliver a specified number of affordable houses.
The authority needs to be able to challenge any claims of non-viability, and the onus of proof should be firmly on the developer. Where the developer claim an exemption this should be thoroughtly scrutinised
https://www.thetimes.co.uk/article/loophole-lets-developers-halve-number-of-affordable-homes-8nn3kmcj7
https://www.theguardian.com/politics/2018/mar/03/affordable-housing-rural-england-planning-laws-loophole-exploited-developers-report
https://www.s106affordablehousing.co.uk/

Policy S24 Countryside. 
Section 5.36 comment
Paragraph
Areas outside settlement boundaries are defined as 'countryside' which includes villages, hamlets, farms and other buildings as well as undeveloped open land. In order to protect the landscape, character, quality and tranquillity of the countryside 1 it is essential to prevent inappropriate development. At the same time, it is necessary to provide for the social and economic needs of small rural communities, and enable those who manage, live and work in the countryside to continue to do so.

Changes Insert
1 tranquility, the natural environment and biodiversity of the countryside

Justification
The terms "landscape character, quality and tranquillity of the countryside" imply a limited valuation of the countryside- ie. as long as it looks nice and sounds nice....

This ignores the important issue of biodiversity loss and can make it easier to overlook biodiversity needs and allow developments that will increase the catastrophic losses of recent years.

The Living Planet report of 2018, published by the WWF reports that humanity has wiped out 60% of mammals, birds, fish and reptiles since 1970.

The 2016 State of Nature Report states that the UK is one of the most nature depleted countries in the world, and that in the UK one in ten species is threatened with extinction.

The loss of biodiversity leads to the loss of the many services that they provide, ie. flood control, water and air purification, nutrient recycling, carbon sequestration, pest control, pollination etc.

Section 5.38
Paragraph Object
The Council also wants to find ways of enhancing the character and appearance of the countryside, the amenities and opportunities that it offers, and its biodiversity1. However, there are dwellings and enterprises in these countryside areas, and particular needs arising from rural activities.2
To support a prosperous and diverse rural economy, some limited and carefully planned development may be acceptable to enable the countryside and local rural communities to evolve and thrive. 3

Changes Insert
1 while protecting its biodiversity

2 However, there are dwellings and enterprises in these countryside areas, and particular needs arising from rural activities, which can compete or conflict with these.

3 Where these conflict with the obligations towards character, tranquillity and biodiversity, mitigation measures will be required.

Justification
We are already suffering incremental loss of the countryside. The 2018 report by the CPRE. Government data shows that the loss of greenfield land to development has increased by 58% in the last four years. The present wording in the local plan still seems to give some preference to development in such a way that it will continue this incremental loss.

https://www.cpre.org.uk/media-centre/latest-news-releases/item/4867-countryside-being-lost-to-housing-at-an-alarming-rate-increase-brownfield-development

Section 5.40
Paragraph comment
Where development is proposed in the countryside, the Council will seek the beneficial management of the countryside. This will include encouragement of proposals that enhance the woodlands and recreational links1 to and within this area.

Changes Insert
1 and ecosystem links

Justification
See above 5.36

Policy S24: Countryside
Paragraph comment
Outside settlement boundaries as defined on the policies map, development will be permitted in the countryside provided that:
1. It conserves and, where possible, enhances the key features and qualities of the rural and landscape character1 of the countryside setting; 

2.It is of an appropriate scale, siting and design that is unlikely to cause unacceptable harm to the appearance of the countryside;2 and 

Changes Insert
1 rural, landscape and ecosystem character of the countryside setting

2 cause unacceptable harm to the appearance, ecosystems and biodiversity of the countryside

Justification
See above 5.36 5.38 5.40

Policy S26: Natural Environment
Section 5.50
Paragraph comment
The natural environment is under significant pressure to accommodate a range of demands1. This includes modern farming practices which have an influence on the evolving2 landscape and biodiversity of our countryside as well as development that more directly facilitates addressing housing needs and provides for economic growth.3

Changes Insert
1a range of demands that are often conflicting

2have often contributed significantly to the loss of many native species, biodiversity and local ecosystems

3developments that address housing needs and provide economic growth contribute significantly to this loss of the natural environment

Justification
The Living Planet report of 2018, published by the WWF reports that humanity has wiped out 60% of mammals, birds, fish and reptiles since 1970.

The 2016 State of Nature Report states that the UK is one of the most nature depleted countries in the world, and that in the UK one in ten species is threatened with extinction.

Both reports state that agricultural practices are one of the main drivers of this decline, but that road building and housing are causing ever increasing fragmentation of the countryside. This leads to the collapse of viable habitats and the loss of species and ecosystems at an unprecedented rate.

The loss of biodiversity leads to the loss of the many services that they provide, ie. flood control, water and air purification, nutrient recycling, carbon sequestration, pest control, pollination etc.

Section 5.51
Paragraph comment/comment/object
In seeking to reconcile these1 demands on the natural environment, the Council will only support proposals that do not cause significant harm to the function2 of the natural environment. This includes ensuring the richness of the landscape and biodiversity of the area is not unduly compromised,3 with opportunities taken to enhance their value where appropriate.

Changes Insert
evaluate these conflicting1 demands

2 to the networks that are part of an integrated and functioning natural environment.

3The council will protect the richness of the landscape and biodiversity of the area.
Where developments are likely to compromise the natural environment, strategies that cause the least harm will be used, ie. using brown field sites wherever available as a matter of priority. The council will also prioritise development that have a smaller footprint and therefore require less land.

Justification
A report by the CPRE in 2016 states that there were enough brownfield sites in England to build 1.1 million new homes. There were almost enough brownfield sites for the councils participating in the report to meet their five-year housing targets without releasing any countryside for development.

https://www.cpre.org.uk/media-centre/latest-news-releases/item/4414-more-than-a-million-homes-possible-on-suitable-brownfield-land

Section 5.53
Paragraph object
Much of the undeveloped coastal plain of the plan area is high quality agricultural land which falls within Grades 1, 2 and 3a of the Agricultural Land Classification. In planning for the sustainable growth of the plan area, it is recognised that there may be occasions when the loss of such land is necessary. 1

Delete and replace

1 Where loss of such land may be thought necessary, this can only be granted when all other options have been fully explored and it has been comprehensively demonstrated that there is no alternative.

Justification
The loss of agricultural land has serious consequences for our food self-sufficiency. Defra states that we only produce 60% of our food and this is declining further. Moreover, this level of production relies on intensive farming methods that harms our natural environment and is contributes hugely to biodiversity loss. A recent CPRE reports shows that intensive farming methods are seriously degrading our soil and that future productivity will consequently be reduced. Measures needed to protect agricultural soils have to be less intensive, and consequently less productive. It is important that the loss of agricultural land is kept to an absolute minimum.

https://www.foodmanufacture.co.uk/Article/2018/08/07/Food-self-sufficiency-highlighted
https://www.cpre.org.uk/resources/farming-and-food/farming/item/5013-back-to-the-land-rethinking-our-approach-to-soil

S26
Paragraph object
Bullet point 4
Cons Considering the quality of the agricultural land, with the development of poorer quality agricultural land being preferred to the best and most versatile land. 

Delete and replace
Where loss of agricultural land may be thought necessary, this can only be granted when all other options have been fully explored and it has been comprehensively demonstrated that there is no alternative. The biodiversity value of all agricultural land must be considered.

Justification
Poorer quality agricultural land may have significant biodiversity value.

Policy S28 Pollution
Section 5.60
Paragraph Object
Some forms of development can result in pollutants, but are necessary to meet the economic and social needs of the plan area. These may include industrial and commercial land uses and new transport routes. Developers must submit robust and appropriate evidence to enable assessment whether there is a likely significant adverse effect on health and quality of life as a result of the development. Mitigation measures should be included in proposals where evidence suggests a likely significant adverse effect.

Changes Insert
This needs a whole extra paragraph on the problem of air pollution. It needs to acknowledge that traffic is a major cause of air pollution and that new transport routes are likely to add to the problem as new roads end up meaning more traffic. mitigation measures are unlikely to be a solution. Its needs to make a commitment to proactive measures to promote alternatives. The local plan seems to pay lip service to promoting alternatives such as walking, cycle routes, public transport and EV charging points, but delivery of these seems poor.

Justification
Air pollution, largely due to traffic emissions, is a major health hazard. (On a personal note, a member of my family died a day before his 22nd birthday, last March, from an asthma attack. His asthma was considered under medical control. He was in Bournemouth city centre at the time, so air quality is likely to have been a contributing factor to his death)
https://uk-air.defra.gov.uk/air-pollution/causes

Last year the UK were referred to Europe's highest court for failing to tackle illegal levels of air pollution.
https://www.theguardian.com/environment/2018/may/17/uk-taken-to-europes-highest-court-over-air-pollution

A recent report by the Welsh government demonstrates the cost effectiveness of investing in alternatives to road traffic.
http://www.wales.nhs.uk/sitesplus/888/news/48759

Policy DM28: Natural Environment
Section 7.169
Paragraph Comment
Development proposals must take account of international, national and local designations as part of their application. Exceptions will only be made where no reasonable alternatives are available and the benefits of development clearly outweigh the negative impacts. Where a development proposal would result in any significant harm that cannot be prevented or mitigated, appropriate compensation will be sought. 1

Changes Insert
1 However, the council also recognizes that some developments will cause irreparable harm to local biodiversity, ie ancient woodlands, and that no mitigation or compensation measures will be adequate to make up for this loss.
Where this is the case the council undertakes to
* scrutinise Environmental Impact assessments for their thoroughness and veracity.
* Consider the development along with others in the vicinity, in order to also evaluate cumulative impacts

Policy DM28

Paragraph comment
The impact of proposals will be carefully assessed to ensure the protection, conservation and enhancement of the landscape of1 the Plan area. Planning permission will be granted2 where it can be demonstrated that all the following criteria have been addressed:

Changes Replace
1 and biodiversity
2 only be considered

Paragraph Comment
1.There is no adverse impact on:
* The openness of the views in and around the coast, designated environmental areas and the setting of the South Downs National Park; and 

* The tranquil and rural character of the area.1

Changes Insert
* 1 The biodiversity of the area

Paragraph Comment
3. Development of poorer quality agricultural land has been fully considered in preference to best and most versatile land; 1 

Changes Insert
Poorer quality land will also be assessed for its biodiversity potential, and where this proves to be significant the land should be subject to the biodiversity protection measures.

Justification
Biodiversity is an essential feature of the natural environment. Treating it separately in the local plan risks a conflict between what is permitted under one heading, but not permitted under the other.

The Living Planet report of 2018, published by the WWF reports that humanity has wiped out 60% of mammals, birds, fish and reptiles since 1970.

The 2016 State of Nature Report states that the UK is one of the most nature depleted countries in the world, and that in the UK one in ten species is threatened with extinction.

This is despite considerable legislation to protect our ecosystems and biodiversity, much of it reflected in the good intention that make up part of the existing Local Plan.

The Chichester area has significant populations of threatened coastal, woodland and farmland species. Some of these populations are rapidly disappearing because of the cumulative impacts of farming practices, loss of habitat, disturbance from new developments and climate change. Populations that are barely surviving under these circumstances are likely to collapse completely if one more stress to their survival is added. Any decision to allow a development that will cause such a final collapse should not be taken lightly.

Continued below in D 29

Policy DM 29: Biodiversity
Section 7.172
Paragraph Comment
All new developments are encouraged1 to take account of and incorporate biodiversity

Exceptions will only be made where no reasonable alternatives are available and the benefits of development clearly outweigh the negative impacts. Where a development proposal would result in any significant harm to biodiversity and geological interests that cannot be prevented or mitigated, appropriate compensation will be sought. 2

Changes Insert/Replace
1 required

2 However, this in the recognition that some developments will cause irreparable harm to local biodiversity, ie ancient woodlands, and that no mitigation or compensation measures will be adequate to make up for this loss.

Policy DM29:
Paragraph Comment
Planning permission will be granted 1 for development where it can be demonstrated that all the following criteria have been addressed:

Changes Insert/Replace
1 Only be considered

Section 6
Paragraph Comment
The benefits of development outweigh any adverse impact on the biodiversity on the site. Exceptions will only be made where no reasonable alternatives are available; and planning conditions and/or planning obligations may1 be imposed to mitigate or compensate for the harmful effects of the development. 

Changes Insert/Replace
1 will

Justification
Planners must not lose sight of the fact that biodiversity requires a genuine range of habitats. For instance, while the emphasis on ecological networks and wildlife corridors is important for many species, but this is not enough.

Other species need dense woodland. with a well-developed canopy and understory, that provide a range of shelter and feeding opportunities. Developments on the edge of woodland alter habitats, and incrementally we are losing our dense woodland. Old trees are an essential feature of such woodland, providing holes and crevices for shelter and a myriad of feeding opportunities. Replanting young trees is not an adequate compensation.

Environmental Impact Assessments must be scrutinised carefully. The methods used in such assessments can, at times, be superficial and some conclusions can be misleading i.e. the presence of Bechstein bats, the rarest of UK mammals, was dismissed as "only of local value" in a planning application for oil exploration at Markwells Wood.

The loss of biodiversity leads to the loss of the many services that they provide, ie. flood control, water and air purification, nutrient recycling, carbon sequestration, pest control, pollination etc.

Our biodiversity is a precious feature of the Chichester area. While protecting this biodiversity will cause conflict with genuine housing and economic development, we have to guard against more spurious justifications. To put it bluntly, should we really lose our biodiversity for the sake of massive suburban sprawl of expensive executive homes?

Object

Local Plan Review: Preferred Approach 2016-2035

Representation ID: 2004

Received: 04/02/2019

Respondent: Mrs C Shepherd

Representation Summary:

Ill health will be caused by potential build up of fumes from A27 proposals.

Full text:

I am writing to STRONGLY OPPOSE to the proposal of the developments throughout the areas in Chichester.
I attended the consultation and it is unbelievable what I have seen using a picture of what I am assuming is the beautiful houses in the grounds of the Cathedral high lighted and labelled neighbourhood planning. if only this was the case, a pretty picture has been used to disguise what is being planned but without any concrete decisions we are only been told of the likelihood such as 'at least' the 100 homes for the Donnington area. My fear is what does the council mean by homes 100? (flats, maisonettes, houses). Why would we want a country park that would be no consolation for what the council is taking away from us when we already have the green fields, the wildlife, the peace and tranquillity, The proposals for employment is another objection I am making, for families to move into the area to enable them to work we would need a vast improvement in the infrastructure of Chichester to facilitate that, buses to take them to work. medical provisions such as doctors Nhs dentists and schools, education has limited resources, as it is we can hardly provide a good standard for the children with such a short fall in investment and not one new school has been mentioned in all the plans, Chichester council are dreaming, all they see is the £ signs. Affordable housing is also another fact that the council has no idea about what young people can afford when buying their own homes Chichester is far too conservative to understand that along with mortgage they have to run car/cars due to lack of bus services and indeed the lack of fair prices in fares.
Now for the proposed so called road improvements they have taken the plans from H E and included them in the plans which would then come back to haunt us having the road around us, they have a nerve to think that people could possibly live with ongoing traffic from behind ,the side and indeed the front of our homes. The proposed housing up in the Wittering area could be an additional 700 cars coming our way each and everyday, how could the council even think that we could live with that, Then with the changes for the Stockbridge roundabout , The A27 proposal was rejected and funding lost. The council believe they can slip it in through the back door and use the already rejected plans. We will loose the farm, the the greenery for what ? a traffic controlled roundabout, with limited access through no right turns and more commercial traffic. without a doubt some of us will develop ill health caused by the build up of the fumes, we do not know either what kind of commercial, employment establishments will be behind us or what noise impact this will have if we are ever able to sit in the garden if these plans are approved. I am also considering the residents that would be living in these new estates. My other question is why on earth would a flood plain be considered for building either around or alongside. The council can not confirm where any of these homes will be built in Apuldram, this is a total waste of money in their fancy posters and booklets, they are not even aware that in the areas they are submitting that the actual land owners would be prepared to sell to them.
I hope you consider what I have written, as I am both angry and so very sad that councillors can sit and plan all this, its obvious there is no consideration for the existing residents, their well being including, the time and money that they have invested in their homes, The A27 fiasco and concrete city,proves they are making a huge mistake that will ruin Chichester for ever, living in the new over populated areas we will have lost everything we hold dear and which we care and maintain . I would also add that w/c 7/1/19 the government was being held responsible for lack of action to cut emissions in areas, evidence of this was sighted on a young child's DEATH CERTIFICATE, is this what Chichester believes could NEVER happen here? I assure you in the very near future it will happen if these plans go ahead, forget social care there will be an increase for medical and mental health care if people are forced to live in an 'inner city' like Chichester.
I can not be the only person very afraid of what these planners have in mind, funny that they choose only the south side of the county.
One more very important point how dare you make the objection procedure so very complicated and time consuming this is a prime example that Chichester has no regard to the residents and believe that using tactics like this will enable their plans to get through.

We need to safeguard those areas of natural beauty in our area. This is not only to protect the aesthetic beauty of our surroundings but also to encourage visitors to the area to see this has a place to visit and return to, this provides a economic boost to our area.
This location is inappropriate as its environmental impact far outweighs its suggested benefit. Its a flood plain. Any developments need to take into account the impact on the immediate surroundings. The use of agricultural land is short sighted and impacting not only our economy but our capability. The adjacency to the Chichester Harbour AONB will have a destructive effect in terms of pollution caused especially from a suggested link road, already objected to under the A27 rejected proposals.

Support

Local Plan Review: Preferred Approach 2016-2035

Representation ID: 2388

Received: 25/01/2019

Respondent: Mr John Newman

Representation Summary:

Agree with this policy

Full text:

Introduction
I agree with most of the points made in the Introduction, not least the points about affordable housing, (para 2.9) for which there is a clear demand and inherent because of the 0.75%pa rise in population and the yawning gap between incomes and house prices.
I will acknowledge that I am writing as a baby boomer, but I note the above average presence of senior citizens in the CDC area and your anticipation that it will rise to 35% by 2015 (para 2.8). This surely has implications for the facilities that CDC, and probably more so WSCC because of its responsibilities for social care, will need to provide, and I do not notice any focus on this in your introductory section. In fairness I am slightly more encouraged when I read paragraph 3.19
I would also ask how many of the young people educated in the area return here to live and work after qualifying. And if the number is low, why, and what do you propose to do to ameliorate the haemorrhage?
Spatial Vision and Strategic Objectives
I agree with your list of items in paragraph 3.2. That said, I note that you state that people should be able to "move around safely and conveniently with opportunities to choose alternatives to car travel (my emphasis). This surely has major implications for public transport, for walking, and for cycling, and surely these should be highlighted in this introductory summary. I shall look forward to seeing what you have to say about these later in the document.
I agree with paragraph 3.3 - but what do you mean by your hope to "balance the ageing population"? That could sound horribly ominous!
In para 3.4 I understand the wish to diversify the local economy - but where are these new organisations to go? You talk about "new sustainable neighbourhoods on the eastern, western and southern sides of Chichester, which could, especially when one thinks of Whitehouse Farm, appear to presage a level of growth which will frighten many. I think that the example of Summersdale, where I live, does not bode entirely well, for it is largely devoid of any community centres and has no public transport in the evenings.
In para 3.6 you speak of a "highly accessible transit corridor" Do you really mean this, says he thinking of the state of Chichester by-pass, the queues that I see coming east on to the Fishbourne roundabout in the morning, and the rush-hour queues from Bognor? Perhaps I could add what the all too predictable impact of Whitehouse Farm will be on both the Fishbourne roundabout and the Northgate gyratory.
Re para 3.10, my understanding is that rather more than "moderate levels of growth" are proposed between Fishbourne and Southbourne, and I shudder at the impact on the A259, all the more so when I think of all that traffic passing through the narrow main road at Fishbourne and also coming out on to what is already a very dangerous Fishbourne roundabout, which I do my best to avoid now!
Turning to paragraph 3.19 I welcome, amongst the other points you make there, the references to affordable housing, to air quality, to the section on health and well-being, and (at a time of fears about global warming) to the reference to flood risk.
Spatial Strategy
I welcome the list of services and facilities mentioned in paragraph 4.12, as that most certainly is not the case in present-day Summersdale.
In fairness I recognise the increased demand for housing as mentioned in para 4.22, as this is inherent in an area of rising population and probably more single-person households (which I have not seen mentioned). I suspect, for instance, that I am far from alone in living singly since bereavement in the family house where I have lived for forty years and from which I have no plans to move. That said, enormous care will be needed in selecting the areas for expansion and the implications for infrastructure and community buildings. Moreover you are clearly right in para 4.30 to refer to longer term growth.
You are clearly right to talking of "meeting the housing needs of the plan area and tackling homelessness" in para 4.34. In all honesty I was appalled when I saw the numbers of people sleeping out late a night when I happened to walk home at a late hour last March. I did not think that such an inhuman state of affairs obtained in Chichester, and am horrified that it still apparently does. I strongly agree with paragraphs 4.43 and 4.44. I welcome the policy statement S6, even if I think that we really need is a return to council house building, as was used to solve even worse problems in the decades after 1945.
Re para 4.66 I have very mixed feelings. It has pleased me not to see the extent of boarded up properties that one sees elsewhere. That said:-
* I write as one who detests shopping and does very little within Chichester city centre; I probably use only about half a dozen shops and those only occasionally.
* I know that my wife always preferred to go to Worthing and can think of a friend who prefers Southampton.
* I think that you have to recognise as a fact of life that more people are going to shop on-line, not least for reasons of price, and that that inherently impacts on traditional retail shopping.
* I tend to do my shopping on the edge of town as that is where the big supermarkets are and parking is easy. I would take some persuasion to change that.
* Looking at policy S9, do you really need more shipping in the Southern Gateway at a time of decline of town centre retail shopping?
Providing Supporting Infrastructure and Services
Paragraph 4.80 should also include cycle tracks and bus routes if you really want to move away from the use of private cars.
I note that paragraph 4.81 includes a reference to "appropriate revenue support". I fully agree and wish that I could believe that this present austerity-obsessed government would actually provide it.
Your policy S12 seems right to me.
East-West Corridor
I think that you are somewhat optimistic in paragraph 4.88. The 700 bus service is very good, but what about other routes, especially in the evening? The present state of the Chichester by-pass is dreadful, and the Fishbourne roundabout is a particular source of danger, moreover one likely to be made worse by more traffic coming from Whitehouse Farm and from further development along the A259.
Policy S13 seems fine to me.
Paragraphs 4.95-98 describe a situation that I know only too well. I would add that as a cyclist I find the western end of The Hornet and St Pancras to be by far the most dangerous pieces of road in Chichester, and I write as one who usually does not mind where he cycles.
I do not agree with paragraph 4.101 - I think that a park and ride is badly needed, arguably from both the west and the south.
Re policy S.14:-
* Re peripheral car parks, if you want to revive the city centre, is that really the answer? What about those who find walking difficult or who do not want to carry heavy shopping half a mile to their car?
* I shudder what the queues will be like with a bus lane up to the Bognor roundabout.
* I think that the present bus/rail interchange is quite good, though I think that you need safer crossing of the road and seats in the bus station
* I do not notice any statement about solving the problems caused by the level crossings by Chichester Station. Having had to wait there for over five minutes yesterday while a train was sitting in Chichester Station I feel bound to ask whether there cannot be some mechanism to bring the gates down just before a train is due to leave, and when you are going to have either a bridge or an underpass there.
Re paragraphs 4.103-105, wshat consideration has been given to the transport consequences of such development, especially given the absurd decision to remove the Oving lights?
Given that I live in Maplehurst road, you will not be surprised that I have noted policy S15. Essentially I welcome this policy, not least, as having some pretentions to being a musician, I am very aware of noise, and the weekends where un-silenced racing is allowed are truly a misery, which ideally would be stopped as unbelievably selfish and insensitive and at very least should not be allowed to expand beyond the one such meeting per year. In fairness the banks erected some years ago have made a difference, and for the most part aircraft do behave themselves. I also think that any housing development closer to Goodwood Airfield should be out of the question, as the noise would be intolerable to anyone with normal hearing. In policy S16, point 2 I think that un-silenced racing should not be allowed despite their loss of amenity, as the consequent noise is not reasonable.
Re paragraphs 4.111-115, what do you think is going to be the impact of 1600 new houses in that area - to amenity and the rural aspect; to the A259; to traffic through Fishbourne; and the already dangerous Fishbourne roundabout? I think that the scale of this development is highly questionable for these reasons.
Strategic Policies
Looking at policy S20, I agree with all the points that you make. I would add:-
* The need for a public transport system that does not stop in the evening, and
* The need for good bicycle access. When I think that at least twice a promised access to Centurion Way has not been delivered, I think it fair to make that point, especially if you really do want to get people out of their cars.
Re paragraph 5.16 I find it sad that you do not mention in your strategic corridors that the cycle track adjacent to the A259 going west from Chichester is part of cycle route NCN2.
Re paragraph 5.22 our roads are going to be even more over capacity with significantly more housing development. I have already referred several times to my concerns over the dangerous Fishbourne roundabout.
Re paragraph 5.27 I welcome the interest in cycling provision. Living in Summersdale it takes me less than ten minutes to cycle into the city centre - in fact by far the quickest way I can get there. For the most part it is safe, I think, but with the glaring exception of the Northgate gyratory. Whoever designed that clearly forgot that a cyclist is at his/her most risk when pulling away, so to expect cyclists to stop at each exit is a massive deterrent. This cyclist prefers not to use the cycle lane in order to have safer crossing at each exit. I find the St Pauls Road exist especially dangerous. I would also like to have paint markings on the raised kerbs at each exit for safety in the dark.
More generally, if you are in the Low Countries, it is exceptional for cyclists can have two way traffic in what it is a one-way street for motorists - I have seen so many no-entry signs there with "uitgezonderd fietser" below. In fairness there is some of this in Chichester, but I think that there is scope for more.
I also think that Chichester centre needs increased provision for cycle parking, for instance adjacent to the Little London car park, where there is plenty of potential space, and at the eastern end of East Street, where I find the present racks often to be full.
I would also like you to think how cyclists can be safer at the western ends of The Hornet and St Pancras, which are the two roads in Chichester which make me feel very chary.
With the additions of the points made in the previous paragraphs and also restating a need for evening bus services, I generally support the points made in policy S23, though I would repeat what I have already said about expecting people to park too far away from the city centre if you really want people to come there, and I would extend this point by saying that if you are going for distant parking, a park and ride becomes essential. I am agnostic about the Birdham Road to Fisbourne proposal, as I do not know enough about it to comment.
Re policy S24 I would make a particular plea for the Lavant Gap, which is important both to Lavant and Summersdale especially as an important part of our amenity. And we did not fight to save it to have a northern by-pass trundling through there!
I agree with policy S27 and would add that I can remember the floods some fifteen years ago and looking out at the River Lavant east of Maplehurst Road to see how far the waters were going to spread. That too me (besides proximity to Goodwood) would be a major factor in my opposing any development there. I am aware that the Pagham Rife project subsequently ameliorated the risk, but I still think that it needs to be borne in mind, especially given the impact of global warming.
I agree with policies S28 29, 30, and 31. I would make a particular point of air and noise pollution.
Strategic Site Allocations
I agree with policy S32,
How can you write paragraph 6.8? You will know as well as I do that cycling links are not good, and will be worse if Centurion Way is to be diverted. Also how are cyclists supposed to get into the city from the northern end of Whitehouse Farm - down St Paul's Road and coming on to the Northgate Gyratory (which will also be receiving significantly more motor traffic? Please!! I hope that you also know that the plans could well include a really dangerous junction on Centurion Way that is the entrance from Bishop Luffa Close.
As for motor traffic, the same point about St Paul's Road applies. And as for the southern end, surely you know what that is going to do to local roundabouts, not least the dreadful Fishbourne roundabout?
In terms of recreational disturbance, (para 6.12) why is there no reference to Centurion Way?
The points above all are relevant to policy AL1.
Re policy AL2 I do not know enough to comment in much detail. That said, I am concerned about transport access. I know that I am not alone in detesting coming up to the Bognor roundabout from Bognor and often prefer the safer route via the Oving traffic lights. Has any account been made of how such traffic, which is not inconsiderable will be affected, and how this will make the journey from Bognor to Chichester significantly worse than it presently is?
Re policy AL5 I accept the case for redevelopment, though was far from impressed with the last proposal I saw and commented on at the time; I thought, and still think, that the road alternations then proposed were insane and asking for more rather than less jams. I welcome the references to access for cyclists and pedestrian. I am not clear when there are references to the bus depot as to whether that includes the bus station. If you want people to come to Chichester centre, bus access needs to be close; moreover the present bus station is properly close to the railway station, which is important for integrated travel. I do not see any reference to taking away the present crossing gates, which are a serious impediment to traffic at the moment, both on Stockbridge and Basin Road; I think that that is a bad omission.
Re policy AL9 I lack the detailed knowledge usefully to comment, but would ask how far the present state of the A259 has been borne in mind in planning both in Fishbourne and further west from Chichester. It is narrow and at times congested now - major development can only exacerbate such problems.
Re policy AL10 I can comment only as one who fairly often cycles east-west along the A259. The exit from the cycle track on the southern side of the A259 to the east side of Chidham is presently dangerous because of the road layout and the warning sign about cyclists being several; yards too late and often obscured by foliage. Where there is a cycle track in Chidham, parking on that track is not uncommon. There is also a significant gap in the cycle track through much of Chidham. Moreover this is part of a national cycling route, and will become even more significant with more development in Chidham and points west.
Re policies AL11 and AL12 please bear in mind the need for cycle access and for the proposed cycle track between Chichester and Selsey (via Hunston) to develop, especially if you really mean to develop non-motor transport (and also as a valuable and healthy amenity) and bearing in mind how dangerous the B2145 is.
Re policy AL13 cycling provision to the west of the roundabout presently is reasonable; it is not good west of the roundabout. My comments about NCN2 refer here too.
Development Management
I am especially pleased to see paragraphs 7.2, 7.4, 7.6, and 7.8, as with an ageing population and baby bookers such as me passing 80 within ten years or so, increased specialist provision is inevitably going to be necessary. This is not to downplay other specific groups, eg students - I simply write from an area of specific knowledge. I agree with policy DM1.
The principles behind policy DM2 seem right to me and I am pleased to see recognition of the need for affordable housing. I would make specific reference to resolving homelessness, young families with not much money, and people in the twenties moving to a new area to start work.
I agree with what you are saying in policy DM8. I have raised my concerns about such issues as cycling routes, bus services, parking and the impact on existing crowded and/ or dangerous routes earlier in this response.
I can see why you are seeking to protect the city centre and prevent an excessive dominance of out of town areas, all the more so as I have seen this in the USA. That said, I find shopping on the edge of town a lot easier -things are in the same place; parking is easier; prices tend to be better. And how far are you crying for the moon as on-line shopping takes off? I for one would take a lot of persuasion to do much shopping in a city centre especially with poor parking. So, while I accept most of what you say in policy DM12, it is with this big proviso.
I agree with policies DM13 and DM14.
I think that any new building should have to incorporate solar panels (re policy DM16). I know how much electricity my solar panels have saved me, and, were I younger and further solar installation not so expensive (it would take me more than a decade to get my money back) I would seriously consider more to provide solar energy for heating and electricity storage.
We are now so aware of air quality issues that I am very pleased to see policy DM24. I also agree with policy DM25 and would add that this should be a significant issue (because of the noise pollution emanating from Goodwood) for any development east of Maplehurst Road.
Re policy DM33, last time I was there I thought that the canal towpath was very dangerous at the western end, particularly for anyone trying to ride a bicycle there.
My apologies but I do not know enough about the later policies usefully to comment.

Summary
In case it helps for me to summarise what I have been seeking to say:-
* As a cyclist I have inevitably had a lot to say about present inadequacies in the network. These need remedy if you really want people to get their bikes out in a city that is made for cycling and feel safe in so doing. Moreover there are the clear health and pollution gains from more cycling, and it is actually often the quickest way from a resident anywhere in the city to get into the centre.
* Housing is important - to resolve homelessness; to provide affordable housing; to meet the needs of young families with not much money or young singles moving here to begin a job/ career.
* There are particular issues re an ageing population and the increased needs are so predictable now even if perhaps not immediate.
* If you really want people on buses, fares have to be lower so that they are competitive with the marginal cost of a car journey for a family, which they are not at present. Services need to be good and to include the evenings.
* I think that there is a danger of Canute tendencies re retail when I think of the attractions of edge of city shopping let alone on-line trading.
* This is linked with car parking - reasonably central car parking and/or a park and ride are crucial if you really want to maintain/expand the city centre.
* The present situation over the level crossing is unacceptable.
* The Fishbourne roundabout is unacceptably dangerous, and the present "by-pass" is a denial of your hopes of an easy east-west transit.
* I am pleased to see the sections on air and noise pollution, and also the encouragement of solar electricity, and I hope that these will really mean something

Attachments:

Object

Local Plan Review: Preferred Approach 2016-2035

Representation ID: 2472

Received: 04/02/2019

Respondent: Southbourne Parish Council

Representation Summary:

Weak policy - strategy need to recognise different forms of pollution and more detail on how to address

Full text:

S3, S4, AL13
Strategic policy should be included that consider the area west of Chichester as a whole rather than as a series of unrelated settlements along the A259 transport route, which is implied by it being referred to as the "east-west corridor". A number of common issues would benefit from collective and co-ordinated attention eg waste water treatment, traffic congestion/management, landscape protection, wildlife corridors and the need to prevent coalescence (para 6.87). The area is expected to provide for a minimum 2250 new dwellings, in addition to the allocations in the current Local Plan (475), and is under great pressure due to its being squeezed between Chichester Harbour and the National Park, both being areas having the benefit of particular protection. This pressure is exacerbated by the National Park not accommodating its fair share of new development and by substantial development in neighbouring Emsworth, Hampshire, that adds to the pressures on the Chichester Harbour AONB and West Sussex infrastructure including road traffic and the capacity of Thornham Wastewater Treatment Works.
Supplementary Planning Guidance is required to address the issues specific to this area, provide clarity of guidance for developers and enable co-ordinated solutions.
S6
Affordable housing should relate more closely to local income levels. Local residents have made the point many times, during the preparation of the current Neighbourhood Plan and more recently in connection with the Neighbourhood Plan review, that local people cannot afford local housing, either to buy or rent. The Parish Council intends to commission a Local Housing Needs Survey which could help identify the quantity and type of need in the Parish.
(add to end of para 4.34) This means housing is unaffordable to many people in the Plan area and why income levels will be taken into account in establishing house prices and rent controls. 80% of the local market rent is the maximum, but lower rents are likely to be justified in some instances.
Developers must deliver their "affordable" requirement if sufficient housing to meet local needs is to be provided. This should not be a problem if proper account is taken of the cost of land acquisitions and development at a sufficiently early stage. Subsections 1 and 5 in Policy S6 allow too much flexibility, especially the use of the word "appropriate" in subsection 1 which is too subjective.
Delete or amend subsections 1 and 5, as appropriate.

DM2
The Parish Council fully supports Policy DM(2). It considers that there is likely to be a need in the Parish for more rented accommodation, especially social rented, than is proposed in Policy DM2. It is understood that this is one of the most expensive areas for housing in the country and young people, in particular, struggle to find accommodation they can afford close to their families. A Local Needs Housing Survey of the Parish is likely to be undertaken in preparing the review of the Neighbourhood Plan to help identify the extent of local need and investigate ways to meet it. Accordingly, an alternative housing mix may be prepared for Southbourne Parish (para 7.19)
Local consultation has revealed a shortage of specialist housing, especially for the elderly and the disabled. It is considered that creative policies promoting adaptable "lifetime" dwellings are required to enable the elderly to remain in the community for longer. The Local Housing Needs Survey of the Parish is expected to confirm this.
The market housing 4+ bedroom % needs to be reduced in favour of more single person accommodation. The Parish Local Housing Needs Survey is expected to confirm this
S20, DM1, DM2
Local consultation has revealed a shortage of specialist housing, especially for the elderly and the disabled. It is considered that creative policies promoting adaptable "lifetime" dwellings are required to enable the elderly to remain in the community for longer. The Local Housing Needs Survey of the Parish is expected to confirm this.
Add "the disabled" into the policy.

AL13

It seems likely that most of the 1250 dwellings proposed (and this is a minimum figure) will be in Southbourne village. Some sections of the local community are very concerned about the change that an over 50% increase in households, over and above the current new development of 300 dwellings, will bring. Some consider that it provides an opportunity to bring some creative thinking to the future format of the village. Whatever increase in development may come, it appears that most residents do share the view that the 30% "affordable housing" proposed in the Local Plan should be truly affordable for those people in the Parish who are in housing need, and the Parish Council has made comments on the relevant policies in this Plan accordingly.
However, at present, it is clear that Southbourne is not in a position to successfully accommodate 1250+ further dwellings due to inadequate infrastructure. While it is recognised that Southbourne village may qualify as a "hub" due to existing services, it must be recognised that a number of these are currently inadequate and substantial improvement is required before development on this scale is delivered. It is understood that new development cannot be required to pay for current deficits, but it is unacceptable to add to these problems without some "up-front" provision to cater for increased needs. Three examples serve to make the point:-
(1) Crossings over the railway, both road and pedestrian, are required before any delivery of 1250 new dwellings. Even if this development is phased, it could be assumed that there will be a completion rate of some 80 dwellings a year (1250÷15). The additional pressure on the Stein Road level crossing arising from a combination of construction traffic and new residents will create unacceptable congestion, pollution and waiting times at the barriers. Inlands Road and Cooks Lane are not suitable for lorry routing. AL13(4) "Opportunities as they arise to improve the situation relating to the various existing or planned railway crossings" is much too weak to secure timely delivery. While this may be addressed in the review Neighbourhood Plan Masterplan, support at District level is required with appropriate priority in the CDC Infrastructure Delivery Plan (IDP) (Policy subsection 14).
In addition, no attention has been given to traffic management, either on the A259 or within the village, in the Preferred Approach. Strategic sites of a broadly similar scale around Chichester have integral transport proposals, but they are lacking in Southbourne. One key issue is that all along the A259 from Emsworth to the Apuldram junction it is becoming increasingly difficult for traffic entering onto the A259 (whether heading east or west) due to the high volume and at times seemingly continuous flow of traffic in either direction: this is a cause of driver frustration and potential cause of road accidents.
(2) The Parish Council has raised the issue of Wastewater treatment many times, and there have been difficulties arising from the current development sites. Reassurance is required that AL13 subsection 16 will be adhered to (16 - Ensure sufficient capacity within the relevant Wastewater Treatment Works before the delivery of development as required).
Stormwater discharges to Chichester Harbour appear to be on the increase and this is not satisfactory. The issue needs to be addressed and resolved by the Wastewater Water Quality Group (para 5.71).
(3) The Parish requires a significant increase in Public Open Space. The proposed Green Ring has received considerable public support and a Trust has been established by the Parish Council to deliver it. Some sections of the Green Ring will not be able to rely on developer delivery and while the project is included in the IDP it is accorded almost no priority (Policy subsection 14). This needs to be remedied.
Specific commitment in the Preferred Approach to the delivery of crossings over the railway, assured delivery of timely and appropriate Wastewater Treatment and specific commitment to the delivery of the Green Ring.
6.88 - To sustain and enhance Southbourne's role as a hub it is VITAL that development is properly phased AND that necessary infrastructure provision is made prior to new occupations.
Policy AL13 item 12: the protection of the SPA, SAC and Ramsar site at Chichester harbour necessitates the reinstatement of the Ham Brook wildlife corridor as part of giving the harbour and wildlife that uses it 'breathing space' and a ladder to the SDNP and as part of the strategy to relieve the pressure imposed upon the harbour by walkers and dogs.
7. Expansion and provision of community infrastructure potentially to include early years' childcare provision, community hall/centre and expansion of doctors' surgery plus flexible space for employment/small-scale leisure use;
As the open space and pitch reports put the improvement of the Bourne college facilities and the recreation ground improvements as a high priority project, this should be mentioned in this point
7. Expansion and provision of community infrastructure potentially to include early years' childcare provision, community hall/centre and expansion of doctors' surgery plus flexible space for employment/small-scale leisure use;

As the open space and pitch reports put the improvement of the Bourne college facilities and the recreation ground improvements as a high priority project, this should be mentioned in this point

DM3

The Preferred Approach advocates a flexible approach to housing density. While an average of 35 dwellings per hectare is recognised as a reasonable guideline, the Parish Council considers that some areas of a higher density would be appropriate, especially where single person accommodation could include small privet patios, terraces or balconies (for flats) in recognition that not all householders want a large private garden, provided that appropriate public open space is delivered as an alternative. Higher densities, as appropriate, also reduce land take.
S23
Southbourne Parish Council responses on the Jacobs Chichester Area Transport Model Report (March 2013), Chichester District Council Chichester Local Plan - Key Policies 2014-2029 and Chichester Local Plan Issues and Options Consultation has consistently drawn attention to the restricted scope of the transport studies undertaken to establish the impact of proposed development allocations within the Plan area. Studies have been concentrated on establishing the effects in the immediate vicinity of Chichester, particularly on the junctions of the A27. Traffic movements generated within/or destined for Southbourne Parish are assigned to a single Traffic Zone (TZ73). These movements are aggregated with other movements in the other TZs of the Western Corridor in order to assess the impacts at the cordon boundaries of the County boundary with Havant/Hampshire but most significantly the point of contact with the A27. Mitigation requirements have been assessed solely in respect of reducing increased congestion at A27 junctions. In respect of Southbourne generated movements these relate to the Fishbourne Roundabout.
CDC, in association with WSCC Highways, has failed consistently to examine local network impacts other than those projected to arise on the 19 junctions in the immediate vicinity of Chichester and the A27. This remains the situation with the update by Peter Brett associates of the Jacobs Study. However, in respect of the Bourne Villages this approach fails to take into account the impacts likely to arise within the local road network of the respective traffic zones. In particular, this lack of examination fails to take account of the potential impact arising from the scale of proposed housing allocations in this corridor. The adopted Chichester Local Plan Key Policies 2014 - 2029 document allocated a total of 620 additional houses comprising: Westbourne 45, Southbourne/Nutbourne 350, Chidham & Hambrook 35, Bosham 70 and Fishbourne 70. The Review Document proposes additional housing allocations (minimum) at Southbourne 1250 houses, Chidham & Hambrook 500, Fishbourne 250, Broadbridge/Bosham 250 - a total of 2,250 additional houses, an increase of + 246% over previous allocations and with these villages taking a 46% share of proposed total additional allocations in the Local Plan Review area.
CDC together with WSCC Highways should undertake to provide specialist advice to those Parish Councils chosen to implement proposed strategic housing allocations through Neighbourhood Plans in order to assess the impacts of the scale of such allocations on the local highway network. Such advice should be provided in order to aid site selection prior to any master planning of the subsequent development proposal and to help find solutions to traffic problems arising.
The above comments/representations also relate to the following Plan references:
Strategic Development/Design Strategies, pages 92-93, paras 6.1-6.6. Policy S32
Strategic Site Allocations - Southbourne, pages 127-129, paras 6.68-6.90; Policy AL13
Transport & Accessibility, pages 148-149, paras 7.4-7.52; Policy DM8.
Spatial Vision and Strategic Objectives
Objection
3.4 Given the huge amount of development proposed for the settlements to the west of Chichester we object to the emphasis placed on Chichester in the special strategy at the expense of the settlements on the receiving end.
There needs to be a fresh look at the cumulative impact on the settlements along the A259. We are not primarily an East-West corridor; we have our own distinct identities and histories. While the term 'East-West corridor' describes the road and rail links to the west of Chichester it is not a sufficient description of the Bourne villages.

3.7 Maintaining and enhancing the relationship between the SDNP and the Harbour AONB requires the reinstatement of the proposed Wildlife Corridor at Ham Brook. Without this corridor, this aspiration has no teeth.
3.8 Southbourne's "good transport links" have recently been downgraded with loss of all north-south buses which will be needed to connect any new housing growth north of the railway line to both the station and the A259. The station itself needs nearby parking and/or drop-off points, electric car chargers and secure cycle storage.
We suggest that the Bourne villages area be considered a 'green / blue ladder' between the AONB and the National Park rather than an East-West transit corridor. Varied countryside views from the Bourne villages towards the SDNP and AONB should be protected, as should views from the A259 and railway of the local countryside and countryside gaps. This will require properly contoured development and good screening.
Sustainable Development Principles
Objection
A reliance upon national 'sustainable development' principles is insufficient as these national policies are inadequate for delivering genuinely sustainable development.
There needs to be an emphasis on economic, social and environmental sustainability. The built environment and history, so frequently lumped in with environmental sustainability, should be considered as part of economic and social sustainability where this conflicts with natural environmental sustainability.
The construction industry is a significant contributor of carbon emissions and while we recognise that there is limited scope to make requirements beyond those mandated by national legislation the Local Plan should nevertheless indicate the direction of travel. It should set out what the community will increasingly come to expect from the industry in the years ahead, including the increasing weight that may in future be given to developments and developers which are making serious attempts to become carbon neutral.
The objective of the Local Plan should be to aim higher. While recognising that not everything is possible, we suggest referring to the principles set out in the Wildlife Trust's 'Homes for People and Wildlife' policy guidance: https://www.wildlifetrusts.org/sites/default/files/2018-05/homes_for_people_and_wildlife_lr_-_spreads.pdf and the World Health Organisation's 'Urban Green Spaces - A Brief For Action': http://www.euro.who.int/en/health-topics/environment-and-health/urban-health/publications/2017/urban-green-spaces-a-brief-for-action-2017 .
See comments in section above.
S17
Object
We welcome the presence of the military base and recognise that the needs of the military will determine policy while the base is maintained, including the need for an upgrade of the housing stock on the base.
However, should Thorney Island cease to be required for military purposes, rather than masterplanning for new development, the island should receive at least equal protection to other areas within the AONB, including the presumption against new development. Any proposed development should follow the principles laid out in the Chichester Harbour Conservancy's Planning Principles policy: www.conservancy.co.uk/page/planning.
In addition, while not seeking anything that would compromise the base's security, the policy should be to expand the Dark Skies sites and, where necessary, to take additional steps to support the existing ones e.g. by upgrading or redirecting street lighting. It should be possible to reduce vertical light pollution without any negative consequences for the existing use of the base. Further information on possible measures that could be considered may be found in the SDNP Technical Note here: https://www.southdowns.gov.uk/wp-content/uploads/2018/04/TLL-10-SDNPD-Dark-Skies-Technical-Advice-Note-2018-2018.pdf
We welcome the presence of the military base and recognise that the needs of the military will determine policy while the base is maintained, including the need for an upgrade of the housing stock on the base.
However, should Thorney Island cease to be required for military purposes, rather than masterplanning for new development, the island should receive at least equal protection to other areas within the AONB, including the presumption against new development. Any proposed development should follow the principles laid out in the Chichester Harbour Conservancy's Planning Principles policy: www.conservancy.co.uk/page/planning.
In addition, while not seeking anything that would compromise the base's security, the policy should be to expand the Dark Skies sites and, where necessary, to take additional steps to support the existing ones e.g. by upgrading or redirecting street lighting.
S24
Support
However, much of the language in this section is weak and aspirational rather than strong and definitive.
5.37 The coastal, alluvial agricultural plain has a particular historic and environmental character which we value greatly. This includes, but is not limited to recognition of its value for agriculture / food production. While we do not expect that this landscape will have the same protection as that inside the SDNP, it forms part of the setting for the National Park and deserves some recognition of the threats facing it from piecemeal (though rapid) development.

The draft Plan in its present form does not give sufficient recognition to the inherent value of the land. It would make sense for this to be rectified as part of a strategy or vision for the whole of the Bournes area, perhaps in a supplementary planning document.
We would like to see the preservation, protection and even reintroduction of bees and their habitats be given real consideration, given their ecological importance. It makes sense to do this as part of a policy covering countryside gaps so as to avoid conflict with humans.
We call for greater support to be offered to the establishing of community orchards and nut plantations. Doing so would also contribute to improving the balance between people and nature, enhancing social sustainability goals and promoting wellbeing.
5.40 We strongly support the "encouragement of proposals that enhance the woodlands and recreational links to and within this area."
5.41 There needs to be greater engagement with the SDNP and greater recognition from the SDNP that it is at risk of becoming an island, which will have serious negative impacts upon the park. We need the National Park to be more flexible in accepting a greater amount of housing within the park in order to relieve some of the pressure on the park's surroundings. While development is concentrated around the Park, we need to know that the Park will not object to the provision of infrastructure that such development needs to be sustainable, provided that it is planned sensitively.
5.42 We strongly support the maintenance of individual settlement identities. Southbourne would like to have a significant input into the formation of a settlement gap policy (and expects other communities along the A259 to feel the same). We would like a meaningful input at an early stage so that we can help shape a policy that commands wide public support.
S25
Object
This policy is very weak. A policy for protecting and managing the coast simply must address the wholly inadequate waste water infrastructure capacity and the frequent discharging of untreated waste into the Harbour.
It must also include a robust strategy for mitigating pressure on the harbour and coastal habitats from walkers and dog walkers by providing for alternative, attractive routes. This should clearly link up with policies promoting wildlife corridors, countryside gaps and green/ blue space.
The Plan should also seek to work with agriculture and horticulture businesses to reduce the impact of chemical and nutrient run-off into the Harbour. We recognise that there are constraints both in terms of national policy and market forces but the Plan should make clear that the direction of travel is towards greater environmental sustainability and reducing the environmental impact from businesses.
S26
Object

This policy is too weak.
5.52 & 5.53 The Plan should seek to work with agriculture and horticulture businesses to reduce the impact of chemical and nutrient run-off into the Harbour. We recognise that there are constraints both in terms of national policy and market forces but the Plan should make clear that the direction of travel is towards greater environmental sustainability and reducing the environmental impact from businesses.
We note that the adopted Local Plan links its Natural Environment strategy to that which protects and promotes biodiversity, but this link seems to have been dropped in the draft proposal. We recognise that there is a section on biodiversity but question the implication of the breaking of this link.
The policy needs to be strengthened.
S27 and S30
Object
It is very disappointing not to see a much stronger role for the use of green / blue space in mitigating flood risk. E.g. reed banks and areas designated for wildlife can form both a natural flood defence and promote other environmental goals of the Plan. Tree planting should also form part of this strategy, as should other measures to strengthen the land's resistance to flood degradation.
The reinstatement of the Ham Brook Wildlife Corridor would provide an opportunity to introduce many of these features in a part of the District prone to the flooding of homes and to storm-related discharges of untreated wastewater into the harbour.
The policy must think beyond what individual sites can do to mitigate the risk of flooding on small areas of land and look at the wider picture and what a more ambitious strategy could achieve.
The reinstatement of the Ham Brook Wildlife Corridor would provide an opportunity to introduce many of these features in a part of the District prone to the flooding of homes and to storm-related discharges of untreated wastewater into the harbour.
The policy must think beyond what individual sites can do to mitigate the risk of flooding on small areas of land and look at the wider picture and what a more ambitious strategy could achieve.
S28
Object
We are astonished that this policy is so thin. There needs to be a strategy which recognises different forms of pollution, including air quality, inland and coastal water and carbon emissions (not least from the construction industry). We need more detail on strategies to address the different forms of pollution and to be looking to a less polluted future, not simply mitigating against the deterioration of the status quo.
S29
Support
However, there needs to be an explicit recognition of the sometimes conflict of interest between green infrastructure primarily intended to be of human / community use and enjoyment and that intended to protect natural habitats and which may require restrictions upon access by the community.
There also needs to be much more thought given to coordinating the creation and protection of multiple green / blue infrastructure sites across the Plan area (or sub-sections of it). Many opportunities will be lost if sites are considered separately rather than as part of something larger. 'Islands' of green space are of much less benefit to humans and wildlife than larger, linked green and blue infrastructure. Again, this supports the reinstatement of the Ham Brook Wildlife corridor.
S30
Support
We are delighted to see a wildlife corridor policy included within the Neighbourhood Plan, as this builds upon the aims pursued in the made Southbourne Neighbourhood Plan and the work of the Southbourne Environment Group. We do however very strongly object to the removal of the previously proposed Hambrook Wildlife Corridor, referred to only obliquely in the Background Paper. It should be reinstated.

Doing so would work towards the policy objectives of S30 and complement its specific proposals.
1) There are a great many "preferable sites available outside the wildlife corridor" so reinstatement would not hinder the District or Parish's ability to meet its housing target.
2) Without prejudging the community consultation, it is conceivable that proposed development sites WITHIN the proposed corridor could be approved provided they do "not have an adverse impact on the integrity and function of the wildlife corridor".

In considering alternatives to the Chidham / East of Nutbourne Wildlife Corridor, paragraph 5.5 of the Background Paper states that "West of Nutbourne there are a number of ecological features but the close proximity of residential areas and proposed development, mean that the [proposed] corridor may be too narrow to act as a suitable functional strategic corridor." This actually prejudges the review of the Southbourne Neighbourhood Plan and we reject this argument. The proposed Ham Brook Wildlife Corridor is or could easily be as wide as others in the policy paper and it is for the community - through the Neighbourhood Plan - to determine where development goes ahead. The community cares very deeply about the local environment and could easily choose to focus development outside of the proposed route of the Ham Brook Wildlife Corridor.

There is no national or local policy reason why there should be no more than one wildlife corridor in a single Parish, especially where there is no conflict with the points above / in policy S30 and where the parish is one of the largest in the District and is home to several distinct communities. On the contrary, reinstating the Ham Brook corridor would strengthen the goals set out in paragraphs 5.64 and 5.65 of the Local Plan, namely, allowing the "movement of species between areas of habitat by linking wildlife sites and reducing the risk of small, isolated populations becoming unsustainable and dying out... They also function as green infrastructure."

This last point is itself emphasised by the Plan's policy AL13 for Southbourne and many objectives would be advanced by reinstating this particular Wildlife Corridor. i.e.:

8. It COULD provide for some public open space for the Parish (not all of which is, will be part of or will be connected to Southbourne VILLAGE's Green Ring).
9. It would enhance the setting of the SDNP and reduce settlement coalescence (without restricting development elsewhere in the Parish).
10. It would expand provision for green infrastructure.
11. As per background paper paragraph 5.5. referenced above, it would reconcile the need to avoid an adverse impact on the nature conservation interest of identified sites and habitats while maintaining a wildlife corridor wide enough to be of ecological value.
12. It would provide mitigation to ensure the protection of the SPA, SAC, Ramsar site at Chichester Harbour.

As per Supporting Document 024, Solent Recreation Mitigation Strategy, paragraph 2.12, there is a requirement for the creation of a Suitable Alternative Natural Greenspace (SANG). Furthermore, Southbourne's made Neighbourhood Plan's Green Ring policy specifically aims to provide alternative routes for dog walkers to relieve pressure on the harbour. As per paragraph 4.12 "these could be created by a developer as part of a very large housing scheme [such as is proposed for Southbourne] or alternatively will be implemented through the Solent Recreation Mitigation Partnership."

The Background Paper does not present any, let alone the full picture of the area's ecological importance. The Ham Brook follows a natural environmental feature from the AONB to the SDNP. This natural water course is home to water voles (seen by CDC Wildlife Officer and local environmental volunteer as recently as January 2019) and the land north of Priors Leaze Lane is a Barn Owl Habitat (as referenced in Chidham and Hambrook Parish's made Neighbourhood Plan). There is ancient woodland either side of the railway line next to the trout farm and this is a dormouse habitat too.

In conclusion, S30 is an excellent policy but it MUST be strengthened by the reinstatement of the Ham Brook Wildlife Corridor. Doing so would not compromise any development objectives of the Local Plan. Indeed, doing so would advance several objectives and policies within it.

S23 and AL6

Object
To the proposed Birdham Road to the A27 Fishbourne Roundabout.
With so much new development - and traffic - proposed for settlements along the A259, our road is going to be the focus of a huge amount of new congestion, with all of the associated negative impacts on air quality and sustainable transport goals. Feeding more traffic into the Fishbourne roundabout will only make it harder for drivers from the A259 to get onto / across the A27.
In addition, the proposed link road goes straight through a flood plain and site of great environmental importance - one which links the coast to the city of Chichester. Furthermore, the proposed link road would have a significant negative impact upon views from the coast to the city and the SDNP and from the city and SDNP to the coast and Manhood Peninsula. It would also negatively affect the setting of the proposed Fishbourne Wildlife Corridor.
We support creation of an integrated and sustainable transport plan for the District, or at the very least for the area west of Chichester. This plan should draw upon the ongoing work of the ChEmRoute group's investigations and proposals for the National Cycle Route 2 (NCN2) and be coordinated with WSCC with the goal of introducing high quality and separated cycle links between the villages along the A259 and Chichester. The route or routes may include a fast but safe link along the A259 aimed primarily at experienced cyclists and commuters as well as a slower, more meandering and leisurely route north of the A259 (and perhaps the railway). To make these cycle routes sustainable they will need connections and feeder routes from new and existing developments.
In developing a more ambitious and safer scheme for cyclists care must also be taken to ensure that pedestrian routes are protected too. The vision must be to ensure that both cycle and pedestrian traffic is encouraged and supported and not brought into competition with each other.

Spatial Strategy, Transport Infrastructure , Page 78 s5.27
In addition, the County Council is expected to continue to support new development through a package of transport improvements which will continue to aim to reduce congestion and encourage people to use sustainable modes of travel such as walking, cycling and public transport.
This supports Southbourne's desire for a pedestrian bridge over the railway line as that will encourage people to walk rather than drive, as well as supporting a road over the railway line as this will also reduce the walking time for many residents wherever the road is placed. It may avoid current routes which involve walking through fields and over unmanned rail crossings. A road would be safer and more useful to pedestrians. The requirement for bridge should be included in policy S23.
DM34
Object due to issues in the supporting evidence.
Chichester Infrastructure Delivery Plan, Southbourne Parish - Local Plan Review Policy SA13 page 90 section 15.4
In the title, play space (children) is given, when the project is actually children and youth combined.
The heading needs to be amended to Play Space (Children and youth)
Chichester Open Space, Sport Facilities, Recreation Study and Playing Pitch Strategy: Open Space Study Sub Area Analysis (Part 2 of 2) Page 13 table 4
This table says there is good provision for childrens play space, when section 2.3 table 3 shows there to be a shortfall throughout the district.
Object due to issues in the supporting evidence.
Chichester Infrastructure Delivery Plan, Southbourne Parish - Local Plan Review Policy SA13 page 90 section 15.4
In the title, play space (children) is given, when the project is actually children and youth combined.
The heading needs to be amended to Play Space (Children and youth)
Chichester Open Space, Sport Facilities, Recreation Study and Playing Pitch Strategy: Open Space Study Sub Area Analysis (Part 2 of 2) Page 13 table 4
This table says there is good provision for childrens play space, when section 2.3 table 3 shows there to be a shortfall throughout the district.
Water Quality Assessment
Housing allocation: The Thornham evaluations have been based on a housing increase in the Thornham catchment area, over the period covered by the report (2020-35), of 1,000-1,500 dwellings. In view of the fact that the Havant-Emsworth plan also has many hundreds of new builds planned in this catchment area, this estimate would seem to be grossly under-estimated ref. Page 25, Table 26. Page 15: "Westbourne" should be added to Table 1.1. Page 60 para. 3.10.2 claims to include Havant but Havant is excluded in other parts of the report e.g. Table 1.1.
Climate change: it is disappointing that any effects of climate change have been specifically excluded (page 28).
Assessment of Headroom: in assessing headroom, AMEC's report states that the Environment Agency guidelines, specify 150 litres/person/day and five people per dwelling. The report has used different figures i.e. 120 litres/person/day and 21/2 people/dwelling. Their justification for this (para. 3.2.12) is that Southern Water prefer these figures. The effect is to reduce the Thornham WwTW's current headroom from 1,063 dwellings down to 400. Any calculations must be formally agreed with the Environment Agency. Page 29 para 3.2.4 suggests that this has yet to be agreed. There is considerably inconsistence in the quotation of dry weather flow (DWF) and Headroom. Page 60 para. 3.10 indicates that consented DWF (hence Headroom) is already in excess of consent (consented DWF 6,565 m3/day, current DWF is 6,580 m3/day). Statement of headroom, without dates, or methodology are meaningless.
Discharges: some assessments are omitted on WwTW, which discharge directly into estuary/coastal waters and Thornham WwTW has been put into this category (table 2.2). In practice, Thornham discharges onto Eames Farm from where it flows through Little Deep, into Great Deep before discharging into the shellfish beds (already classified as "unfavourable") at Prinsted (Chichester Harbour) as in Page 61 para. 3.10.13. Page 21, Table 2.3 is incorrect. In its objectives (page 10), the report indicates that it should be considering any impact on shellfish. No impact on these shellfish beds seems to have been assessed.
Storm discharges and shellfish: the report (Page 61 para. 3.10.9) states that storm discharges have been a significant problem for the Thornham WwTW. However, it specifically excludes any consideration of storm discharges over this period (2020-2035). It does not assess the effect of large quantities of primary-treated sewage (filtered only) on the Eames Farm marshland or the Prinsted shellfish beds (Page 23 para. 2.2.12, Page 25 para. 2.2.19). The AMEC report seems to suggest that the discharges processed through Thornham WwTW will have a minimal affect. This observation does not take into account, the very large levels of (Grade 1) untreated storm discharge.
Data: There are significant areas, where Thornham WwTW's data has not been provided and National Average data used instead.
Objectives not met: Page 9 Objective "investigate demonstrably deliverable ways of dealing with Wastewater treatment capacity". The MWH Report (2010) page 17 clearly indicates that expansion of Thornham WwTW was not viable. No comment or way of dealing with capacity limitation has been investigated.
Clear statements of exactly what additional works and what realistic dates are required.
5.69-5.72 , Section 9.1 of the Surface Water and Foul Drainage SPD and its referenced Headroom Tables are out of date, need to be updated, and its guidance amplified, to cover the timescale of the Local Plan Review 2019 to 2035 and the impact of future housing development.
Reasoning
Headroom Table 2 of the Water Quality Assessment Report states that as at 31st October 2018 the Estimated remaining headroom (households) was 1,020. This is well below the combined Southbourne and neighbouring West Sussex parishes Local Plan Review planned housing development numbers without even taking into account that Thornham WwTW also serves the Emsworth area in Hampshire which is is the subject of increased and significant additional housing development.
This issue is of particular importance given the large scale development proposed for the Southbourne Parish under the Local Plan Review, that this SPD is "a material consideration when assessing planning applications or appeals for any new dwelling(s)" and that the Local Plan Review itself states that "measures will need to be put in place at each WwTW and their associated catchments and sewer networks in order to tackle current and future water quality issues to support future housing growth." These measures include "Upgrades to physical capacity and Upgrades to sewer networks".

5.72, Policy S31 states that "Proposals for development within the Plan area should be able to demonstrate no adverse impact upon the quality of receiving waters" It is proposed that this statement should be amended to be clearer and more appropriate to local circumstances, as follows: "Proposals for development within the Plan area must be able to demonstrate no adverse impact upon the quality of receiving waters including with regard to the capacity and condition of existing wastewater and sewage systems, local storm discharge risk and the capacity of the Wastewater Treatment Works. The Council as planning authority will look to satisfy itself on these matters including to ensure sufficient capacity within the relevant Wastewater Treatment Works before the delivery of development as required."
Reasoning
The referenced Surface Water and Foul Drainage SPD is out of date and insufficiently clear and rigorous in its guidance and requirements. The SPD needs strengthened with regard to new development requirements and potential adverse impacts on Chichester Harbour AONB, on the small watercourses feeding into the Harbour waters, given known local problems with the sewer network (as referenced in Para. 2.4) e.g. at Nutbourne, and as Para. 2.3 of the Surface Water and Foul Drainage SPD states "The condition of the water environment is not currently good enough to meet the required standards (of the European Water Framework Directive). Policy AL13 for Southbourne Parish also states that "Development will be expected to address the following requirements (including), !6. Ensure sufficient capacity within the relevant Wastewater Treatment Works (i.e. Thornham) before the delivery of development as required".

Characteristics of the Plan

Proposed Supplementary Planning Guidance
Object
Objection is raised to the use of the term East-West Corridor with regard to west of the City of Chichester. The use of the term corridor implies the focus of policy is on transport and through movement to the detriment of a more balanced focus on local settlement, existing residential, local countryside and amenity issues.

There is a lack of vision, clarity and coherence of planning policy towards the Bourne Villages, their character and the surrounding countryside that lies between the South Downs National Park and Chichester Harbour AONB. The current piecemeal policies approach that focuses on the individual settlements and individual thematic policies is detrimental to the coherence and effectiveness of planning policy, the character of these settlements and their surroundings and to the South Downs National Park and Chichester Harbour AONB.
The Preferred Approach fails to take account of the potential impact arising as a result of the scale of proposed allocations. The adopted Chichester Local Plan Key Policies 2014 - 2029 document allocated a total of 620 additional houses: Westbourne 45, Southbourne/Nutbourne 350, Chidham & Hambrook 35, Bosham 70 and Fishbourne 70. The Review Document proposes additional housing allocations (minimum) at Southbourne 1250 houses, Chidham & Hambrook 500, Fishbourne 250, Broadbridge/Bosham 250 - a total of 2,250 additional houses, an increase of + 246% over previous allocations and with these villages taking a 46% share of proposed additional allocations in the Local Plan Review area.
The absence of a Countryside Settlement Gaps Policy at Local Plan Review stage is regretted and one is only verbally promised for June 2019. The lack of a coherent vision for the Bourne Villages is at odds with the approach taken to other Chichester areas and their communities which is reflected in a statement made by Cllr Tony Dignum (Leader of CDC) on 18 October 2018 in the Chichester Observer: "there is no doubt that we live and work in one of the most beautiful areas of the country and we want to keep it that way. We aim to deliver improvements within our city and towns so that our area continues to be one of the best places to live, work, and visit in the UK. These improvements are being expressed through 'vision' projects for the city and for each of our towns" (Selsey, Midhurst and Petworth are cited as examples).
There is at least an equally strong case for there to be a vision for the Bourne Villages, the band of settlements, countryside and amenity land that lies between Emsworth and Chichester, the South Downs National Park and Chichester Harbour AONB. Not to have a coherent vision for this area is detrimental to the Bourne villages and to the neighbouring areas. Much of the character of these settlements, especially Southbourne, derives from the wider area within which they are situated.
1 Chichester District Council should prepare Supplementary Planning Guidance on a vision for the Bourne Villages, comprising Westbourne, Lumley, Hermitage, Prinsted, Southbourne, Nutbourne, Chidham, Hambrook, Bosham and Fishbourne, the surrounding countryside and their relationship with neighbouring Emsworth/Havant, the City of Chichester, the South Downs National Park and Chichester Harbour AONB.
2 The use of the term East-West Corridor with regard to west of the City of Chichester be restricted and only be used for transport issues and the A27 itself, and not be applied to the Bourne Villages and their surroundings..
The above comments/representations also relate to the following Plan references:
i) Page/para nos: page 22 §2.29
Policy reference: Character of the Plan Area.

ii) Page/para nos: p24 - 25; §3.3 - §3.10
Policy reference: Spatial Vision & Strategic Objectives: East-West Corridor
iii) Page/para p35
Policy reference: Spatial Strategy - Policy S3: Development Strategy
iv) Page/para nos: p82 - 84; §5.34 - §5.42 & §5.44
Policy reference: Strategic Policies - Countryside S24: Coast S25
v) Page/para nos: p 92; §6.4 - §6.6
Policy reference: Strategic Development - S32

Comment

Local Plan Review: Preferred Approach 2016-2035

Representation ID: 2483

Received: 20/02/2019

Respondent: Fishbourne Parish Council

Representation Summary:

Next to the M25, the A27 has the worst congestion rates in the country and the air pollution from this has caused several "hot points" along the Chichester bypass. EU Regulations concerning air pollution are already being breached and air quality will worsen as a result of traffic from all the proposed developments feeding onto the A27. It is also a matter of concern that this section does not cover noise or light pollution.

Full text:

See attachment

Support

Local Plan Review: Preferred Approach 2016-2035

Representation ID: 2551

Received: 07/02/2019

Respondent: Chichester Harbour Trust

Representation Summary:

This policy, whilst welcomed, is not sufficiently comprehensive and should certainly identify and address the different forms of pollution likely to arise from housing development (and its relating infrastructure) including:
- Noise pollution
- Air pollution
- Light pollution
- Water pollution

The policy should recognise there are three designated Dark Skies Discovery Zones within the District (in the AONB) and seek to introduce measures to protect these.

Full text:

We object to the allocation site at Highgrove Farm, Bosham with approximately 13 ha of open countryside allocated to a minimum of 250 houses.

This development in the countryside directly conflicts with policy S24 Countryside and Policy S26 the Natural Environment; which clearly states there should be no adverse impact on the openness of views in and around the coast, designated environmental areas (i.e. the AONB) and the setting of the South Downs National Park. The proposed development at Highgrove Farm directly contradicts these policies.

We strongly believe that this development would cause irretrievable harm to the landscape character, setting and context of Chichester Harbour AONB and the intervisibility with the South Downs National Park. We feel that the measures proposed within the policy would not be able to sufficiently mitigate for the damage this development would cause.

Comment

Local Plan Review: Preferred Approach 2016-2035

Representation ID: 2573

Received: 06/02/2019

Respondent: Earnley Parish Council

Representation Summary:

No significant deterioration of air quality is recognised.

Full text:

The South Downs National Park occupies approximately 70% of the land area of Chichester District. The remaining 30% includes Chichester City with fairly limited opportunity for major housing sites. The remainder of CDC land area includes Chichester Harbour AONB, which is a RAMSAR site and SSI, Pagham Harbour which has SPA status and Medmerry which is designated as a potential SPA. For Government to require CDC to raise its Local Plan allocation from 435 dwellings p.a. to 609 dwellings p.a. (i.e. by 40%) and then expect CDC to accommodate a further 41 dwelling p.a. from the SDNP is wholly unreasonable. This is particularly so when many Parishes in the SDNP have expressed concern about the sustainability of their communities due to the lack of housing for their younger generation.

For the Manhood (3.11) "emphasis will be mainly upon protecting and enhancing the special qualities of the coast and its rural hinterland" and there is a "need to adapt to the potential impacts of climate change and sea level rise" (4.122).
The total housing numbers for the Manhood parishes is 950, and the plan also seeks to provide new employment opportunities "to reduce out-commuting". It also acknowledges the Manhood has "Significant areas at risk from coastal erosion and flooding, which is further accentuated by a high water table and poor land drainage" (4.121). Residents would add to this a barely adequate sewer system. In view of these factors it is hard to see how the plan's housing objectives can be achieved without building on a considerable area of prime agricultural/horticultural land which is surely one of the "special qualities of the coast and its hinterland" which the plan is "protecting and enhancing" (3.11). Development in East Wittering Parish is further constrained by its settlement area adjoining and spilling over into the parish of West Wittering whose allocation is just 25 dwellings.

The existing adopted plan recognised the problems of large-scale development on the Peninsula. The Western Mannhood's allocation of 330 homes (up to 1929) has already been exceeded. It is hard to see how a further 600 homes can be justified when the previously identified problems have not been mitigated and have been made worse by the development which has already taken place.

The plan acknowledges the "unique character" of the peninsula, and its tranquil nature. Each development lowers the physical attractiveness and uniqueness of the area, while the only road with "major" noise impact identified in the Peter Brett Transport Study is Bell Lane, passing through the Somerley Conservation Area. No significant deterioration of air quality is recognised; how can this be, even with an increase in the proportion of electric/hybrid private vehicles, if commercial development is envisaged, especially that south of the A27 close to residential Stockbridge?

A further disincentive to living, working, and holidaying on the Manhood is the difficulty of access, which gets worse as the A27 traffic increases, as it must do with further large-scale development along the East-West corridor. The planned mitigation in the form of a Stockbridge by-pass is at best a short-term solution, improving the problems with the Stockbridge Road roundabout. But any commercial development in the same area, south of the A27, would further raise traffic levels attempting to reach the A27 from the new route. So
at worst, if the proposed commercial development at AL6 is taken into consideration, the proposed new Link Road from the western end of the by-pass to Birdham Road is likely to create a new "Vinnetrow Road" situation at the Fishbourne roundabout.

The proposed industrial / housing development at AL6 is largely within an area of agricultural land prone to flooding: it is close to the R. Lavant and susceptible to further damage from rising sea-levels. AL6 does not mention these major risks, though AL4 specifically mentions the need to avoid the flood-plain of the Lavant in relation to Madgwick Lane. Further, such a development contradicts DM28, there being "adverse impact on the openness of the views in and around the coast, designated environmental areas and the setting of the South Downs National Park"; and the tranquil and rural character of the area. Salterns Way cycle route would be alongside the development; the much prized peacefulness of the route and the views of the cathedral and Downs would be destroyed. Furthermore, AL6 is adjacent to Chichester Harbour which as previously mentioned is not only an AONB but is a RAMSAR site and SSI. There is evidence of Winter grazing by migratory birds in the area designated as AL6.

Traffic levels within the Manhood are already such that heavy commercial vehicles choose to use country lanes which were not built for the capacity, while the transport of agricultural/horticultural produce, particularly on the B2145, and the movement of agricultural machinery has a significant impact on journey time. Further housing and commercial development will require mitigation on the Peninsula itself.

Turning to the Brett Transport Study and the Appendix dealing with Air Pollution, given what they say in 3.2.22 and particularly in 3.2.23, it is staggering that in 3.2.24 they make their glib 'standard' statement when we know already that 4.1% of deaths in Chichester are due to PM2.5 pollutants from vehicle emissions.

How can 3.2.24 consider future vehicle uncertainties ref 3.2.22, if they are uncertain? There is no risk analysis in the Brett report to support the assertion that: the report is 'an appropriately conservative assessment.' The real risk to lives in this area is too significant to be dealt with in this superficial way.

In considering alternative industrial / housing sites to AL6, AL4, which is included in the current CDC Local Plan, is ideal. It is recognised that this has been withdrawn from the HELLA; consideration should however be given to using compulsory purchase powers to acquire this site for industrial use. Most airports / airfields in the UK have industrial area on their boundaries.
The Peter Brett Transport Study estimates that the cost of mitigation measures at £68m, this level is clearly way beyond the level at which it could be funded by developer contributions. Without defined future funding plans, housing development should be phased in line with actual funding.

It is encouraging to see the proposed introduction of "wildlife corridors" to the east and west of Chichester linking the Downs with Pagham and Chichester Harbours respectively. However they should not be positioned where they conflict with 5.24 which addresses the possibility of an A27 northern relief road. They should also be wider at the coastal end: the two to the east of the city could even be joined to form one.

As the plan recognises the international importance of the two harbours and the Medmerry Realignment for wetland habitat (2.25), it would be a positive step to designate a protected area to link Chichester and Pagham Harbours in the same way.

Earnley Parish Council is pleased that small-scale Horticultural Development will still be focussed on the two former LSA sites in Almodington and Sidlesham, and applauds DM21, which sets out the conditions for redevelopment of buildings in the countryside, where currently there seems to be a presumption in favour of housing.

Currently there is a demographic imbalance on the Manhood and in CDC in general. Locally we are all aware of the need to provide accommodation which attracts younger people into the area and gives our own young people the opportunity to make their homes here. How can this happen? To use the term "affordable housing" is a deception. In an area with such high market-rate housing, "affordable" is simply not affordable. In a holiday area, the rental market is limited and distorted by the high number of holiday lets; there is no guarantee that new housing would not benefit tourists rather than prospective residents. The proposed Plan is, of course, moulded and constrained by government policy, but there is nothing in it which comes close to solving this part of our "housing crisis".

To sum up, Earnley Parish Council:
* Is opposed to the scale of development proposed for the Manhood Peninsula
o Believes this level of development to be unsustainable
o Believes it to be incompatible with maintaining the rural character of the area and the mixed nature of the local economy
* Finds the mitigaton propsed for the A27 to be insufficient and ineffective
* Is opposed to the AL6 development
* Is concerned by the increases in air and noise polution
* Urges CDC and WSCC to consider more closely the social housing needs of the area

Support

Local Plan Review: Preferred Approach 2016-2035

Representation ID: 2642

Received: 05/02/2019

Respondent: Barton Willmore

Representation Summary:

Support policy.

Full text:

See attachment

Attachments:

Comment

Local Plan Review: Preferred Approach 2016-2035

Representation ID: 3078

Received: 06/02/2019

Respondent: Chichester Harbour Conservancy

Representation Summary:

The Conservancy is unsure what is meant by "pollution" since it is not defined.

Full text:

See attachment

Support

Local Plan Review: Preferred Approach 2016-2035

Representation ID: 3254

Received: 07/02/2019

Respondent: WSCC (Estates)

Agent: Henry Adams LLP

Representation Summary:

Support policy.

Full text:

See attachment

Object

Local Plan Review: Preferred Approach 2016-2035

Representation ID: 3455

Received: 07/02/2019

Respondent: A + D Lygo-Baker

Number of people: 2

Representation Summary:

Concerned about the impact on Air quality in the Stockbridge Road locality

Full text:

See attachment

Attachments: