Policy S30: Strategic Wildlife Corridors

Strongly support.
If this Policy is altered, I may wish to make further representations, including at Examination in Public.

The Wildlife Corridor East of Chichester connecting SD National Park to Pagham Harbour, has the potential to be extended to link to the series of lakes around the East side of Chichester, which are havens for wildlife. More emphasis could be given to this to protect wildlife and provide a local amenity for quiet leisure activities - eg bird watching, walking.

Ref: S30a West of City Corridors Map

Centurion Way provides a VITAL Wildlife Corridor Linking SDNP with Chichester Harbour and the Manhood Peninsular - taking in Brandy Hole Copse Nature Reserve. The 20m wide heritage railway route links 2 SARs (Singleton and Cocking Tunnels) within SDNP. There is Evidence of at least 12 species of Bat in the Whitehouse Farm 1600 House Development Area (14 Species nearby). It is proven that Bats require many miles of suitable habitat to forage and complete their Life Cycle. Bats particularly require linear routes with continuous tree cover for dusk and dawn travel.

Policy S30

During the last century our natural habitats have been lost on a frightening scale. With the present spread of developments it is more important than ever to have a policy to protect our wildlife .
I support the wildlife corridor policy . It is important to ensure , that corridors are of sufficient size so that where they passd near developments the wildlife are not disturbed by non-native species or by pollution,noise or artificial light. Consideration would need to be given to how the A27, A259 and the railway line would be crossed

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.

If Fishbourne is to be the subject of unavoidable further residential development, I would suggest that the derelict land in Clay Lane located between A27 trunk road and Salthill Road would be a more suitable prospect than prime agricultural land comprising Bethwines Farm located to the west of Blackboy Lane towards Bosham.


The declaration of a wildlife corridor north/south across the derelict land adjacent to the A27 defies logic as birds would have to overfly the trunk road at turbulent and elevated level before it starts to fall away into a cutting towards Salthill Road. Conversely, the farmland at Bethwines Farm is on gently rising ground and woodland beyond that naturally overflies the deep cutting of the A27. Take a look - it's obvious. Watch the birds! This provides a natural wildlife flightpath between the upper reaches of the harbour and the South Downs and is confirmed by our observations.


We live immediately adjacent to Bethwines Farm and have an excellent overview of the relevant area - north/south. Large numbers of gulls track this route NE/SW and barn owls and bats follow the hedgerows. Raptors also follow and hunt over this farmland. I have no experience of such wildlife activity across the proposed nominated corridor east Clay Lane/A27.


Bethwines Farm comprises highly productive agricultural farmland under the excellent stewardship of lifelong farmer Mr. Richard Strange. It is my experience that this land is of the highest quality and has reflected this criteria by producing three salad crops in one farming season. This bears good comparison with the most productive areas of
Lincolnshire fenlands. It also produces yields of good quality milling wheat in quantities well in excess of the county and national average.

For reasons of the above it follows that this land is fairly 'heavy'. At times of high rainfall, the land adjacent to the barn/farm buildings and the full width at the northern 'hollow' section
of this field suffers from local area flooding. If this flooding and subsequent natural drainage to the south is interrupted by residential development, the direction of this run-off water will be deflected onto the lower lying areas comprising Blackboy Lane and onwards towards Salthill Road and cause a hazard to all those who live in the area which has also been the subject of a lot of in-fill development in recent years.


Bethwines Farm provides an excellent strategic gap between Fishbourne and Bosham and has been previously acknowledged as such. It also is a most fully-used productive farmland area at a time when every forecast states that we must do more to provide food for our increasing population.


There is only one logical decision if Fishbourne is to be the subject of further domestic development: build on the land that no-one seems to have found a use for extending across my local knowledge of this land over some 50 years.


Anyone with local ornithological knowledge will know that this is a most illogical place to 'nominate' as a wildlife corridor - the avian crowd will not co-operate.

To describe Fishbourne as a Service Village is blatantly wrong. It has very few facilities, no surgery and only one shop. It has a Primary school that is always at full capacity with waiting lists. The community centre provides a wide range of facilities that are already very successful and which attract customers from a wide region and does not rely solely on Fishbourne to sustain itself. Yet proposals suggest that Fishbourne can accommodate the same increase in housing numbers as, for example, Bosham who have shops, hotels, takeaways, pubs, and a GP surgery, and accommodate more additional houses than Hunston, who have many more facilities than Fishbourne.

Your policies state that 'to protect the landscape, character, quality and tranquillity of the countryside it is essential to prevent inappropriate development'. Development of this scale in Fishbourne is inappropriate and does not meet this policy. As a result of the late introduction to a wildlife corridor to the East of Fishbourne, proposed land availability in the village has been halved and the village no longer has the capacity for 250 new houses without destroying its rural character. The allocated number of 250 homes in Fishbourne should be reduced to account for the removal of potential land available for development. Due to the introduction of the wildlife corridor, the remaining large site identified for housing in Fishbourne is land on Bethwines Farm. I believe it is fundamentally wrong to promote building on a viable arable farm when many suitable brownfield sites are still available within the District. Losing Bethwines Farm to development would not only impact on local jobs but would also destroy the village landscape and character.
Although a wildlife corridor is proposed between Fishbourne and the new development currently under construction on Clay Lane, there doesn't appear to have been any consideration given to the wildlife on the West side of Fishbourne. Kites, foxes, buzzards, badgers, water voles, geese, and bats are all frequently observed on and around the Bethwines Farm area, raising the question that perhaps it would also be appropriate to designate the West of Fishbourne as a wildlife corridor too? Building on the West side of Fishbourne will have a significant negative impact on our wildlife.

If additional housing is required in Chichester District, we should be first looking to regenerate existing brown field sites and also to do more to develop our coastal area and enable our tourism industry to grow. Many other towns and villages along the coast of Britain already take advantage of their location to improve their economy without detriment to the environment, for example along the Jurassic Coast in Dorset. I would like to see increased numbers of homes and businesses in the area south of the A27 to Selsey, giving more opportunity for water sports and marine based tourism to grow.

In summary, the additional housing proposed for Fishbourne should be reduced from 250 to recognise there is limited land available in the village especially since the introduction of the East wildlife corridor. Your own policies are now acting to promote the destruction of one of the areas viable farms by building in a strategic gap between villages and, judging by previous withdrawn Planning Applications on Bethwines Farm, leaving the door open for the future construction of 100's of more houses in the future. How can this be in keeping with your countryside policy? Rather than destroying the rural character of the District's villages, we should be concentrating on fully developing Brownfield sites and doing all we can to encourage our tourism industry by providing greater opportunity to take advantage of the coast around the Manhood Peninsula. The current proposals as they stand do not give this adequate consideration.

We have seven comments to make about the above plan:


Strategic Site Allocations
We are concerned by Strategic Site Allocations AL3 and AL12, and would also like to bring to your attention some matters about Strategic Site Allocations AL6 and AL8.

1. Strategic Site Allocation AL3
Drayton Gravel Pit is in the south-east corner of the AL3 site, just north of the railway line. We believe that this Pit is a good site for birds, although because of access difficulties it is under-recorded. Certainly the two nearby New Drayton House Gravel Pits, on the south side of the railway line, are recognised to be excellent sites for birds, to the extent that SWT recognises them as an LWS candidate-site because of their importance for birds, particularly water birds. This is because several pairs of Common Pochard are recorded as breeding annually on these two Pits south of the railway line. (Common Pochard is a duck whose breeding numbers nationally have fallen so low that it is monitored by the Rare Breeding Birds Panel - despite its name breeding birds are far from common, and the breeding population at these Pits is over one half of one percent of the national breeding population). Also more than 100 species of bird have been recorded on this site during the last 10 years which is 25% of all the species ever recorded in the whole of East and West Sussex.

Given that the Local Plan proposes building 650 houses on site AL3 north of the railway line we believe that wildlife and house building could both be accommodated if a buffer zone (ideally of 50 metres) could be established around the shores of Drayton Pit in which no development or landscaping took place. If such a buffer zone were protected to allow it to remain wild then it should provide the wildness that waterfowl would need to successfully breed.

We understand that even with such a buffer zone put in place around the Gravel Pit this site should still be able to accommodate 650 new houses.

2. Strategic Site Allocation AL6
It is noted that the western side of this site abuts the Chichester Harbour AONB and the River Lavant Marsh LWS (whose eastern boundaries are Apuldram Lane and the road to BIrdham), and lies close to the boundaries of the Chichester Hbr SPA/SAC/ SSSI/RAMSAR site.

It is also noted that condition 6 of Policy AL6 states that development must
Provide mitigation to ensure the protection of the adjacent SPA, SAC, SSSI and RAMSAR at Chichester Harbour.

We believe it would not be acceptable if the SPA/ SAC/ SSSI/ RAMSAR site, or indeed the AONB or LWS, were in any way affected by the development of AL6 and that the only mitigation measures that should be required are recreational mitigation measures. To make this clearer we would like to see condition 6 reading as:
"Ensure the protection of the adjacent SPA, SAC, SSSI and RAMSAR site at Chichester Harbour, the AONB and the River Lavant Marsh LWS. This should include mitigation measures to avoid recreational disturbance"

We welcome the penultimate paragraph of policy AL6, namely that
Proposals will have to demonstrate that sufficient capacity will be available within the sewer network, including waste water treatment works, to accommodate the proposed development.

3. Supporting habitat for the Pagham Hbr SPA/SSSI/RAMSAR
Before commenting on Strategic Sites AL8 and AL12 below it is appropriate to address the supporting habitat that is required for the birds cited in the designations of the Pagham Harbour SPA and SSSI, because if the supporting habitat no longer becomes available to the cited birds they will go, and Pagham Harbour could then lose its European SPA designation.

The SSSI citation states "The numbers of wintering Pintail, Ringed and Grey Plover and Black-tailed Godwit regularly reach 1% of British Populations, and the site is of International Importance for wintering Ruff and Brent Geese". Of these species Brent Geese is particularly important from a planning point of view, as it alone feeds primarily outside the Pagham Hbr SPA - mostly on fields of autumn planted (winter) wheat which is widely grown around the Manhood peninsula (the other species all primarily feed within the SPA).

WeBS records show that the wintering Pagham Harbour Dark-bellied Brent Geese population varies between 2100 and 3000 birds a year, and is relatively stable. Significant numbers build up in November, and stay around to late February/early March. Typically by late March only a handful remain. One ha of winter wheat can support 2200 Brent Geese for a day and assuming an average population of 2600 birds are present for up to 100 days a winter, plantings of 118 ha of winter wheat are needed to sustain this population over the winter.

Much more than 118ha of winter wheat is planted every year on the Manhood Peninsula, but:-
a) Bird scaring devices, such as roped off fields, are extensively used on winter wheat fields, especially between Siddlesham and Selsey, so that Brent Geese are denied access to a large proportion of the fields planted up with winter wheat.
b) Brent Geese are wary birds so they need buffer zones between the fields on which they are grazing and humans (and their dogs).

Because of the above the Pagham Hbr wintering Brent Goose population could easily come under pressure if development is not planned for in a way that avoids development on fields that are known to have been used by them to forage on. In many instances we recognise that land owners have better knowledge of where they forage than SOS or RSPB, as birders tend to watch birds within the Medmerry and Pagham Hbr RSPB Reserves, rather than in the surrounding fields. An example of the consequences of lack of bird records of where Brent forage is that in Arun DC fields along Pagham Road were allocated for housing development (Arun Planning application P/140/16/OUT) because there were no records of Brent Geese foraging on them. It now turns out that in 2018/19 up to 3000 geese a day (the majority of the 2018/18 Pagham Hbr Brent population) have been recorded foraging on winter wheat in these fields over a 7 week period - which is probably near the maximum number of geese that these fields can support.

This winter SOS have taken over from RSPB a project to map the foraging fields that are used by the wintering Pagham Harbour Brent Geese, as this has not been mapped by the SWBGS, but this project needs to run for several more years. Until we have a full understanding of what fields (suitably planted) are used by the wintering Brent Geese we will oppose any development on fields potentially used by them for foraging, as we just do not currently have the data to hand to fully understand the consequences of allowing such development around Pagham Hbr and Medmerry. In addition to the fields where we record Brent Geese foraging (such as the South Pagham site in Arun DC) we regard any fields planted with winter wheat which farmers take the expense and trouble to erect bird scaring devices on, as fields that have probably been used by foraging wintering Brent Geese in the past and could be suitable for use by them in the future.

When we have gathered such information about where they forage and what suitable fields have bird scaring devices we then need to agree with affected parties, including Natural England and Chichester DC, what steps need to be taken to ensure sufficient acreage is protected to provide foraging for future generations of overwintering Dark-bellied Brent Geese.

From what we can see the needs of the Internationally important Pagham Hbr Dark-bellied Brent Geese population for access to suitably planted fields may not have been adequately addressed in allocating strategic sites for development.




4. Strategic site AL8
We note that this policy requires The East Wittering Neighbourhood plan, which includes Bracklesham Bay, to produce proposals for a minimum of 350 new houses, and that the settlement boundary may be adjusted to accommodate these.

The RSPB Medmerry Nature reserve lies immediately to the east of Bracklesham Bay. It has no formal conservation protection, so we feel that it is important that it is protected through the planning system.

Recognising this we would like to see point 7 of policy AL8 rewritten. It discusses two very separate matters, the impacts of more housing causing recreational disturbance in the Pagham SPA/Ramsar site and the Medmerry realignment, and the impact of development on functionally linked supporting habitat.

Firstly, we welcome the fact that point 7 talks of providing mitigation for the impacts of recreational disturbance arising from this development and believe in this respect that this should not be a case of "mitigation if required", but that it must be a condition attached to the development of any more houses in East Wittering/Bracklesham Bay.

Secondly, given the comments we have made in 3 above, we believe that all supporting habitat must be protected if development is to be allowed. We are not opposed to the development of 350 more houses in this area but we are totally opposed to such development having an impact on either of the two RSPB reserves, or on the fields used by the wintering Brent Geese and waders that underpin the conservation citations for Pagham Harbour.

We would therefore like to see two paragraphs replacing point 7 in Policy AL8, so that it reads:
7a) Demonstration that suitable mitigation measures will be put in place to ensure that development will not create recreational disturbance that will have an adverse impact on the Pagham Hbr SPA/Ramsar and Medmerry realignment sites.
7b) Demonstration that development will not occur on any land that can be shown to be functionally linked supporting habitat for the birds on these two RSPB reserves.

5. Strategic Site AL12
SOS has over 900 records of birds at Park Farm during the last 10 years (the site of AL12) and at Church Norton Greenlease. We also note that the site of AL12 is sown this winter with winter wheat and that it is roped off to scare away Brent Geese, suggesting that it is a known site used by them in winter. We strongly oppose this site (or indeed any site on the east side of Selsey Road between Siddlesham and Selsey) being allocated for development. It is just too close to Pagham Harbour, and building on the east side of the road could directly affect the SPA.

If 250 houses are to built north of Selsey then we would much prefer to see them built on the west side of Selsey Road, as the busy Selsey Road does form a natural protective barrier around the western side of the SPA. This would alleviate any additional pressure being created on the Church Norton part of the Pagham Hbr SPA, which is already coming under pressure because of recent or planned housing developments at the northern end of Selsey.

Policy 30 Strategic wildlife corridors
6. We welcome the strategic approach of designating wildlife corridors between the Chichester Harbour SPA and the SDNP, and applaud Chichester DC on this initiative. However, we note that Policy 30 says that

Development proposals within, or in close proximity to, strategic wildlife corridors will be granted where (three things) can be demonstrated:

We have no problems with condition 3, and would reluctantly accept condition 2. However, we do have concerns with condition 1, namely
1. There are no sequentially available sites outside the wildlife corridor

For a start we have no idea what a "sequentially available site" is. And secondly we do not see how any circumstances can be permitted that allows any development to occur within a Strategic Wildlife Corridor (other than those that satisfy condition 3 of this policy) that would not result in the destruction of the corridor. It's only going to be acceptable to wildlife as a corridor if it is not built upon. And any process of actually building anything will particularly affect its ability to serve as a wildlife corridor during the building process.

7. The four western corridors look like realistic corridors - at least on the small-scale maps within the Local Plan. However, the absence of an ability to enlarge the on-line maps means that we are not able to comment on their suitability in detail. Moreover the Y-shaped eastern corridor (Map S30b) shows that this corridor is extraordinarily narrow in places, so much so that its effectiveness looks questionable. A link to your Strategic Wildlife Corridors background paper would have been helpful, but unless there is something in this document elaborating the detailed reasons for the precise boundaries of these corridors as shown on maps S30a and S30b, then our comment would be that the corridors in S30b look far too narrow in places to provide the "non-disturbance" security for wildlife required of an effective wildlife corridor.

4.4.2 and Table 3 4.6.4 , 4.7.3 Sustainability Appraisal 010

This Sustainability Appraisal is full of highly subjective notions which leads its impact assessments to be generally questionable ie on whether an option has a positive or negative impact on eg biodiversity.
In para 4.4.2 who were the "further discussions" with to cause scenario 1a to be added ?
Para 4.6.4. in trying to justify the allocation of 1250 dwellings to Southbourne, it talks of the "potential advantages" but does not mention the obvious disadvantages in almost doubling the population of this village. What provisions will the plan make eg to ensure that the Southbourne railway station is capable of handling possibly a doubling of passenger traffic.? The answer is that it can't because investment in the railway network is outside it's jurisdiction. I would only support an option that shares any new housing more evenly between settlements which is more likely to limit the obvious damage that is going to be caused to natural habitats by this Local Plan review.

What improvements or changes would you suggest?

As above.

003 Housing and Econ Devt

This document appears to rely for it's conclusion of new housing numbers on the unbridled continuation of economic growth levels through the Plan period to 2035[par a 1.17].I believe that this is an unsustainable model on which to plan the future for our children and grandchildren.
There is no attempt that I can see to apply some sort of sensitivity analysis to the single end figure of 609 dwellings per annum so that lower numbers could be chosen as a preferred option. There are many factors which could influence housing numbers over the long Plan period so it would seem sensible to start with lower numbers to try and reduce the inevitable negative impact on natural habitats that any increase in human numbers will cause.

What improvements or changes would you suggest? As stated above

5.5 in particular Strategic Wildlife Corridors Background Paper

Whilst supporting the concept of Wildlife Corridors in the Plan [why was this not done 20 years ago ?] I do object to the removal from the Plan Review of the Chidham/East of Nutbourne Wildlife Corridor. If the Southbourne Neighbourhood Plan Review [SNPR] wishes to give more priority to natural habitats then it can devise policies which avoid "the close proximity of...proposed development" cited in paragraph 5.5.
Glossary - Wildlife Corridors are not defined in the Glossary and should be included.

What improvements or changes would you suggest? As stated above.

All but especially sub-areas 82 and 83 Landscape Capacity Study - 007

Apart from it being a useful inventory of landscape types in Chichester District, this document appears to me a rather pointless exercise in Planning fudge. For example on page 496 in is saying that development could be accommodated etc etc at the same time as avoiding any "landscape or visual harm " This sort of language is found all over this document and givers too many opportunities for misunderstanding or misinterpretation.
It would have been helpful to have page numbers for the sub-areas. As it is the location of sections is prolonged.

What improvements or changes would you suggest?

Avoid attempts to give facile conclusions and recommendations.

Paras 5 and 7 various Natural Environment

Para 5.51 [Strategic Policies] suggests the Council will only object to development that causes "significant harm" to the function of the natural environment but there is no definition of this phrase
7.168 Is stating that "providing open space, sport and recreation is part of "protecting and enhancing the natural environment" This is not true as these are all man-made features designed for humans, not for nature.
Para 7.189 and others mention "priority habitats" but I can see nowhere in the Plan Review that identifies the 21 types of these habitats mapped in Sussex* either by list or on a map of the District.These important habitats are often overlooked when development applications are made [eg ref 16/03569/OUT] and this Plan is a good opportunity to draw the public's attention to those in their area.
Para 7.189 refers to a Map 5.1 but gives no easy reference to where this can be found ?
Note: *Sussex Biodiversity Record Centre records these as "Habitats of Principal Importance" - which designation is correct ?
Glossary issues: Priority Habitats are missing and should be included in the Glossary in the Plan Review.

4.4.2 and Table 3 4.6.4 , 4.7.3 Sustainability Appraisal 010

This Sustainability Appraisal is full of highly subjective notions which leads its impact assessments to be generally questionable ie on whether an option has a positive or negative impact on eg biodiversity.
In para 4.4.2 who were the "further discussions" with to cause scenario 1a to be added ?
Para 4.6.4. in trying to justify the allocation of 1250 dwellings to Southbourne, it talks of the "potential advantages" but does not mention the obvious disadvantages in almost doubling the population of this village. What provisions will the plan make eg to ensure that the Southbourne railway station is capable of handling possibly a doubling of passenger traffic.? The answer is that it can't because investment in the railway network is outside it's jurisdiction. I would only support an option that shares any new housing more evenly between settlements which is more likely to limit the obvious damage that is going to be caused to natural habitats by this Local Plan review.

What improvements or changes would you suggest?

As above.

003 Housing and Econ Devt

This document appears to rely for it's conclusion of new housing numbers on the unbridled continuation of economic growth levels through the Plan period to 2035[par a 1.17].I believe that this is an unsustainable model on which to plan the future for our children and grandchildren.
There is no attempt that I can see to apply some sort of sensitivity analysis to the single end figure of 609 dwellings per annum so that lower numbers could be chosen as a preferred option. There are many factors which could influence housing numbers over the long Plan period so it would seem sensible to start with lower numbers to try and reduce the inevitable negative impact on natural habitats that any increase in human numbers will cause.

What improvements or changes would you suggest? As stated above

5.5 in particular Strategic Wildlife Corridors Background Paper

Whilst supporting the concept of Wildlife Corridors in the Plan [why was this not done 20 years ago ?] I do object to the removal from the Plan Review of the Chidham/East of Nutbourne Wildlife Corridor. If the Southbourne Neighbourhood Plan Review [SNPR] wishes to give more priority to natural habitats then it can devise policies which avoid "the close proximity of...proposed development" cited in paragraph 5.5.
Glossary - Wildlife Corridors are not defined in the Glossary and should be included.

What improvements or changes would you suggest? As stated above.

All but especially sub-areas 82 and 83 Landscape Capacity Study - 007

Apart from it being a useful inventory of landscape types in Chichester District, this document appears to me a rather pointless exercise in Planning fudge. For example on page 496 in is saying that development could be accommodated etc etc at the same time as avoiding any "landscape or visual harm " This sort of language is found all over this document and givers too many opportunities for misunderstanding or misinterpretation.
It would have been helpful to have page numbers for the sub-areas. As it is the location of sections is prolonged.

What improvements or changes would you suggest?

Avoid attempts to give facile conclusions and recommendations.

Paras 5 and 7 various Natural Environment

Para 5.51 [Strategic Policies] suggests the Council will only object to development that causes "significant harm" to the function of the natural environment but there is no definition of this phrase
7.168 Is stating that "providing open space, sport and recreation is part of "protecting and enhancing the natural environment" This is not true as these are all man-made features designed for humans, not for nature.
Para 7.189 and others mention "priority habitats" but I can see nowhere in the Plan Review that identifies the 21 types of these habitats mapped in Sussex* either by list or on a map of the District.These important habitats are often overlooked when development applications are made [eg ref 16/03569/OUT] and this Plan is a good opportunity to draw the public's attention to those in their area.
Para 7.189 refers to a Map 5.1 but gives no easy reference to where this can be found ?
Note: *Sussex Biodiversity Record Centre records these as "Habitats of Principal Importance" - which designation is correct ?
Glossary issues: Priority Habitats are missing and should be included in the Glossary in the Plan Review.

West Sussex County Council Officer Level Response
Introduction
The Chichester Local Plan Review Preferred Approach sets out how the future development in the District will be shaped, excluding the area within the South Downs National Park, up to 2035. It includes the overall development strategy as well as relevant strategic policies to meet the future needs of the area and development management policies to help guide development over the plan period. The Local Plan helps to:
* choose where the development goes;
* protect the character and beauty of the area;
* provide job and housing opportunities so that children can continue to work and live locally;
* support and help to boost the local economy;
* help residents to maintain healthy and active lifestyles; and,
* make sure that there is adequate services, travel options and community facilities.

The Chichester Local Plan was adopted in July 2015. At that time, the Local Plan was approved, but the Government Inspector said that it had to be reviewed again within five years, to make sure that sufficient housing was planned to meet the needs of the area.

The first part of the review process was carried out in June 2017 with an Issues and Options consultation, in which comments were invited regarding the overall development strategy and possible development locations. The Local Plan Review: Preferred Approach is the second stage of the process. It sets out the proposed development strategy and policies for the area to meet future needs.


West Sussex County Council Officer Level Comments
This note sets out West Sussex County Council's (WSCC) officer response to the consultation on the draft Chichester Local Plan Review Preferred Approach. It highlights key issues and suggested changes to which Chichester District Council (CDC) is requested to give consideration. We will continue to work with CDC in preparation of the Local Plan Review and the Infrastructure Delivery Plan regarding WSCC service requirements in order to mitigate planned development.


Minerals and Waste
A steady and adequate supply of minerals and the achievement of sustainable waste management can help to achieve a District or Borough Council's goals in relation to the economy, housing, transport, communications, strategic infrastructure and the environment. Therefore, District and Borough Local Plans should recognise the importance of minerals and waste issues as relevant to the scope of their overall strategies.

We welcome the reference to the adopted Minerals and Waste Local Plans and safeguarding in the document and the requirements in policies where a site is located within a minerals safeguarding area, or near to a safeguarded waste site. There are some missing references to safeguarding of minerals and waste sites for some of the proposed allocations, set out below and request that these references are added. It is also requested that 'Joint' is added into the references for the Joint Minerals Local Plan through the document.

Policy W23 of the Waste Local Plan applies to all Districts & Boroughs, regarding waste management within development and should be referenced in the Chichester Local Plan Review.

AL3 East of Chichester
The site is to the north of the Fuel Depot site allocation in the Waste Local Plan (Policy W10) for a built waste facility as part of a comprehensive redevelopment of the site (including complimentary non-waste uses). The East of Chichester allocation is the land to the north, bisected by the railway line, of the Fuel Depot. Reference should be made to giving consideration to the allocation, and therefore its safeguarding.

AL4 Westhampnett/North East Chichester
Reference should be made to minerals safeguarding, for consistency with other allocations, as within the sharp sand and gravel safeguarding area.

AL5 Southern Gateway
Reference should be made to the mineral infrastructure safeguarding policy M10 as within 200m of the Chichester Railhead.

AL6 South-West of Chichester
Reference should be made to the mineral infrastructure safeguarding policy M10 as within 300m of the Chichester Railhead.

AL7 Highgrove Farm Bosham
Remove reference to minerals safeguarding as the site is not within the safeguarding or consultation area.

AL12 Park Farm Selsey
Reference should be made to minerals safeguarding as site is within the sharp sand and gravel safeguarding area.

Neighbourhood plan allocations
Sites are yet to be allocated though neighbourhood plans. It is considered that the Joint Minerals Local Plan and Waste Local Plan are referenced, particularly with regards to safeguarding policies (M9, M10 and W2) and these documents and policies are given detailed consideration when allocating sites. Development at, adjacent or proximal to existing waste or mineral sites / infrastructure should be the subject to consultation with WSCC.


Connectivity and Sustainable Travel
The County council has worked with the District Council on the preparation of the transport evidence base study undertaken by Peter Brett Associates for the District Council. The recommended transport mitigation strategy, as assessed using the Chichester Area Transport Model has been demonstrated to be capable in principle to prevent the development from resulting in severe residual cumulative impacts on the highways and transport network. However, the recommended strategy has several risks to deliverability and acceptability associated with it, which require further work to be undertaken to demonstrate that the strategy can be implemented in its current form to provide the forecasted mitigation to travel conditions.

There are three locations where new highway alignments are proposed outside of existing highways boundaries. Two of these may include significant earthworks or structures to be delivered, being Stockbridge Link Road and Terminus Road diversion. The cost of the mitigation strategy exceeds a figure which could reasonably be supported by the value of the proposed development developer contributions alone, therefore the delivery of the strategy will depend upon securing of external grant funding to top up developer contributions. WSCC will work with the District Council in supporting and or applying for funding, the District Council needing to secure Highways England to support funding applications for A27 improvements. The proposed junction designs for the A27 Stockbridge and Whyke roundabouts include bans to well used right turn movements off the Chichester A27 bypass which result in significant forecast changes to traffic flows on local roads in the south of Chichester and on the Manhood Peninsular.

There is a need to ensure the land outside the highway boundary is available and the plan should set out how this land will be acquired to deliver the measures, it may be that a commitment to use, if required, and therefore reference to CPO be made in the policy.

Funding for the mitigation strategy is uncertain. It is considered that the Plan should set out how it will deal with this uncertainty. This could include trigger points in the monitoring framework to trigger a change of approach or alternative options to deliver the required development.

These factors mean that feasibility work is necessary to be undertaken prior to Plan submission, to reduce as far as practicable risks to costs, land take, impacts and deliverability of the proposed transport strategy in order to show that the strategy can be implemented within the plan period and that the funding strategy will be sufficient to meet the design requirements. In particular the following will need to be addressed:

* Statutory undertakers equipment under the roads junctions to be impacted.
* Extent of earthworks required to create a vertical and horizontal alignment compliant with design standards. Design audit to identify any required departures from standard.
* Designing for drainage and flooding issues, including compliance with the WSCC LLFA Policy for the Management of Surface Water, November 2018.
* Designs for structures to cross watercourses - Stockbridge Link Road
* Design should include suitable provision for rights of way and footway crossings
* Scoping for whether and at what level further Environmental Impact Assessment will be required.
* Stage 1 Road safety Audit, designers response report and resulting amendments to designs.
* Land take required after feasibility level designs have been developed and availability of required land.
* Wophams Lane - impacts of forecast changes to flow patterns to take B2201 southbound traffic on requirements for highway width, alignment, footway provision and junctions with A286 Birdham Road and B2201 Selsey Road; design solution required.
* Quarry Lane, Kingsham Avenue /Road, Terminus Road; impacts of forecast flow changes on highway users, residential and commercial frontagers and measures to manage through traffic whilst maintaining local access

Sustainable transport measures will also be required to mitigate planned development. These will be identified through more detailed assessments of sites including pre-application consideration. Funding will need to be identified through development and other sources as well in some cases.

Public Rights of Way
There is support for the Local Plan Review's approach to Public Rights Of Way (PROW), not just for the potential to impact on existing public off-road access but also the opportunity it brings to enhance this access for the benefit of future residents, communities and visitors. PROW deliver benefits for personal health and wellbeing; sustainable transport; reduction of air pollution and road congestion; are able to support local economies; and they connect communities.
WSCC PROW welcomes several aspects of the Vision statement, which give support to the protection and enhancement of the PROW network, and provision of safe and convenient off-road access opportunities for residents and visitors:

* Pursue a healthy lifestyle and benefit from a sense of well-being supported by good access to education, health, leisure, open space and nature, sports and other essential facilities;
* Live in sustainable neighbourhoods supported by necessary infrastructure and facilities;
* Move around safely and conveniently with opportunities to choose alternatives to car travel.

The Local Plan Strategic Objectives offer further support to enhance off-road access, particularly to 'Encourage healthy and active lifestyles for all, developing accessible health and leisure facilities and linked green spaces'. However, the objective to 'Achieve a sustainable and integrated transport system through improved cycling networks and links to public transport' should recognise walking also as an important mode for many people; some strategic enhancements will significantly improve walkers' safety and convenience.

It is considered that West of Chichester the A259 could act as a corridor for increased volumes of non-motorised access, particularly cycling. Improvement of the existing on-road facility and development of a various 'feeder' routes to connect with the many settlements, perhaps using quiet lanes in places, would encourage cycling particularly to be a natural alternative to vehicle use. Policy S18: Integrated Coastal Zone Management for the Manhood Peninsula, gives regard to such an ambition in stating it will 'Improve infrastructure to support sustainable modes of transport, especially cycle ways, bridleways and footpaths, including the National Coastal Footpath'.

The National Planning Policy Framework (NPPF) Open Space and Recreation, para 97b) states:
the loss resulting from the proposed development would be replaced by equivalent or better provision in terms of quantity and quality in a suitable location.
The NPPF para 98 also states:
Planning policies and decisions should protect and enhance public rights of way and access, including taking opportunities to provide better facilities for users, for example by adding links to existing rights of way networks including National Trails.'
There is support for Policy S20: Design, that recognises these requirements in stating development 'is well connected to provide safe and convenient ease of movement by all users, prioritising pedestrian and cycle movements both within the scheme and neighbouring areas and ensuring that the needs of vehicular traffic does not dominate at the expense of other modes of transport, or undermine the resulting quality of places' and 'incorporates and/or links to high quality Green Infrastructure and landscaping to enhance biodiversity and meet recreational needs, including public rights of way'.


Education
As the local education authority, WSCC has the statutory duty to ensure that there is a sufficient supply of suitable school places to meet statutory requirements for early years, primary, secondary and sixth form provision (including up to age 25 for those with special educational needs and/or disabilities). Education infrastructure, or contributions to provide infrastructure, will be required in order to mitigate proposed development. We will continue to work with CDC in preparation of the Local Plan Review and the Infrastructure Delivery Plan regarding education and other service requirements in order to mitigate planned development.

The table below sets out the primary, secondary school and sixth form requirements to mitigate proposed development. SEE ATTACHMENT FOR TABLE

AL1 Land West of Chichester

It should be noted that phase one of this development will provide the primary school with the core of the building being built to the specification for a 2 form entry (FE) school and 1FE teaching accommodation. Phase 2 as per 6.10 on page 93 should include expansion of the primary school for the further 1FE of teaching accommodation.

AL2 Land at Shopwhyke (Oving Parish)

No update to original response for this allocation is required.

AL3 Land East of Chichester - previously South of Shopwhyke

At the current time pupil place planning indicates that there is insufficient space within the primary schools that serve this proposed development. Further capacity would be required to accommodate the development. Land for a 1 FE expandable to 2FE and pro rata share of the build costs would be required.

If numbers were to increase on the east side of the city, education provision will need to be reviewed, potentially a further 1FE may be required including land provision, this could be in the form of an expansion or a new school being built capable of expansion to 3FE.

At the current time pupil place planning indicates that there would be expansion capacity to accommodate the child product from this proposed development for secondary aged pupils. Contributions would be required for expansion of secondary schools if feasible and required.

At the current time pupil place planning indicates that there would be expansion capacity to accommodate the child product from this proposed development for sixth form pupils. Contributions would be required for expansion of the provision if feasible and required.

AL4 Land at Westhampnett / North East Chichester

The remaining 200 dwellings will impact on the education provision in the area, financial contributions towards expansion of existing or pro rata costs towards the expansion of the school within AL3.

At the current time pupil place planning indicates that there would be expansion capacity to accommodate the child product from this proposed development for secondary aged pupils. Contributions would be required for expansion of secondary schools if feasible and required.

At the current time pupil place planning indicates that there would be expansion capacity to accommodate the child product from this proposed development for sixth form pupils. Contributions would be required for expansion of the provision if feasible and required.

AL5 Southern Gateway

At the current time pupil place planning indicates that there would be sufficient space or expansion capacity to accommodate the child product from the strategic allocation of 350 dwellings in the Southern Gateway. However, consideration should be given to the cumulative impact of housing in the area Land South West of Chichester (AL6) to allocate land within the area for a 1FE expandable to 2FE primary school. Pro rata financial contributions towards the build costs would be sought from developers to mitigate their impact.

At the current time pupil place planning indicates that there would be expansion capacity to accommodate the child product from this proposed development for secondary aged pupils. Contributions would be required for expansion of secondary schools if feasible and required.

At the current time pupil place planning indicates that there would be expansion capacity to accommodate the child product from this proposed development for sixth form pupils. Contributions would be required for expansion of the provision if feasible and required.

AL6 Land South West of Chichester (Apuldram & Donnington Parishes)

It should be noted that the primary education provision in this area is either in Chichester City Centre which means crossing the main A27 or by travelling south towards the peninsula. Consideration should be given to the cumulative impact of further housing in the area along with the Southern Gateway allocation (AL5) to allocate land within the strategic allocation site for a 1FE expandable to 2FE primary school. Pro rata financial contributions towards the build costs would be sought from developers to mitigate their impact.

At the current time pupil place planning indicates that there would be expansion capacity to accommodate the child product from this proposed development for secondary aged pupils. Contributions would be required for expansion of secondary schools if feasible and required.

At the current time pupil place planning indicates that there would be expansion capacity to accommodate the child product from this proposed development for sixth form pupils. Contributions would be required for expansion of the provision if feasible and required.

AL7 Bosham

The current primary provision serving the area is at capacity, expansion of the school on its existing site is not possible. As part of the strategic allocation, it is proposed that land for a 2FE primary school be provided. The strategic allocation of 250 dwellings in isolation does not require a new school to be built. Certainty over the land allocation and sufficient funding will be key drivers in realising this proposal.

AL7, AL10 and AL13 are all within the same school planning area, the cumulative total of the strategic allocations brings forward a requirement for c3 forms of entry additional school places. The Local Plan, as currently drafted, indicates an oversupply of school places which could affect the viability of all the schools in the planning area.

Expansion of the secondary school may be possible. Contributions would be required for expansion of secondary schools if feasible and required.

AL9 Fishbourne

The primary school serving the area is currently at capacity, expansion of the school may be possible, feasibility / options appraisals would need to be undertaken.

At the current time pupil place planning indicates that there would be sufficient space or expansion capacity to accommodate the child product from this proposed development for secondary aged pupils. Contributions would be required for expansion of primary and secondary schools and sixth form if feasible and required.

AL8 East Wittering

At the current time pupil place planning indicates that there would be sufficient space or expansion capacity to accommodate the child product from this proposed development.

Contributions would be required for expansion of primary and secondary schools if feasible and required.

AL10 Chidham and Hambrook area

The current primary provision serving the area is at capacity, expansion of the school on its existing site is not possible. As part of the strategic allocation, it is proposed that land for a 2FE primary school be provided. Certainty over the land allocation and sufficient funding will be key drivers in realising this proposal.

AL7, AL10 and AL13 are all within the same school planning area, the cumulative total of the strategic allocations brings forward a requirement for c3 forms of entry additional school places. The Local Plan, as currently drafted, indicates an oversupply of school places which could affect the viability of all the schools in the planning area.

Expansion of the secondary school may be possible. Contributions would be required for expansion of secondary schools if feasible and required.

AL11 Hunston

Any development within this area cannot currently be accommodated in the existing primary school at North Mundham. Further capacity would be required to accommodate the development, CDC will need to work with WSCC to determine how additional capacity in the area could be accommodated if land is to be allocated.

At the current time pupil place planning indicates that there would be sufficient space or expansion capacity to accommodate the child product from this proposed development for secondary aged pupils. Contributions would be required for expansion of secondary schools and sixth form if feasible and required.

AL12 Selsey

Further capacity would be required to accommodate the development. Contributions (and possibly land if required) would be sought to meet the pupil product from the development in the most appropriate form once this can be clarified.

At the current time pupil place planning indicates that there would be sufficient space to accommodate the child product from this proposed development for secondary aged pupils. Contributions would be required for expansion of secondary schools if feasible and required.

AL13 Southbourne

At the current time pupil place planning indicates that there is insufficient space within the primary schools that serve this proposed development. Further capacity would be required to accommodate the development. Land for a 2form entry expandable to 3FE primary school and pro rata share of the build costs would be required.

AL7, AL10 and AL13 are all within the same school planning area, the cumulative total of the strategic allocations brings forward a requirement for c3 forms of entry additional school places. The Local Plan, as currently drafted, indicates an oversupply of school places which could affect the viability of all the schools in the planning area.

Expansion of the secondary school may be possible. Contributions would be required for expansion of secondary schools if feasible and required.

AL14 Tangmere

The current allocation of 1,300 dwellings will bring forward the requirement for land for a 1FE expandable to 2FE and financial contributions would be sought to meet the pupil product from the development in the most appropriate form once this can be clarified.

At the current time pupil place planning indicates that there would be sufficient space or expansion capacity to accommodate the child product from this proposed development for secondary aged pupils. Contributions would be required for expansion of secondary schools and sixth form if feasible and required.

Footnote: - if all of the proposed sites were to come forward the secondary school and sixth form provision would be full in the Chichester Planning Area. Expansion of the secondary schools in the Chichester Planning Area to cater for the increased demand would need to be sought from the academy sponsors, where appropriate and the Local Authority.


Lead Local Flood Authority
The Lead Local Flood Authority (LLFA) is concerned about the approach being taken with regard to ensuring potential wastewater treatment for proposed new sustainable development.

Paragraph 8 of the NPPF states:
8. Achieving sustainable development means that the planning system has three overarching objectives, which are interdependent and need to be pursued in mutually supportive ways (so that opportunities can be taken to secure net gains across each of the different objectives):

a) An economic objective - to help build a strong, responsive and competitive
economy, by ensuring that sufficient land of the right types is available in the
right places and at the right time to support growth, innovation and improved
productivity; and by identifying and coordinating the provision of infrastructure;

Paragraph 20 of the NPPF states:
20. Strategic policies should set out an overall strategy for the pattern, scale and quality of development, and make sufficient provision for:
a) housing (including affordable housing), employment, retail, leisure and other commercial development;
b) infrastructure for transport, telecommunications, security, waste management, water supply, wastewater, flood risk and coastal change management, and the provision of minerals and energy (including heat);

In the LLFAs view, the Local Plan Review is not setting out an overall strategy for the pattern, scale and quality of development in relation to arrangements for wastewater management. The LLFA considers that CDC needs to go further in incorporating within the Local Plan Review how this provision is being made.


Additional Policy Comments

Policy S12: Infrastructure Provision
Support the requirement that all development must provide or fund new infrastructure, facilities and services required, both on and off-site (including full fibre communications infrastructure) as a consequence of the proposal. The explicit reference to full fibre communications infrastructure is supported as this will provide gigabit-capable and future-proofed services to all development, existing and new. The reference to provision of facilities and services on and off-site is also supported as in the case of broadband for example, all development will be adequately equipped with the necessary infrastructure installed for the purposes of connecting to full fibre gigabit-capable broadband services. This policy supports the County Council's aim for increased digital infrastructure that will provide for gigabit-capable broadband and future technologies such as 5G.

Support the reference to safeguarding educational facilities under section 3 of the policy.

The policy includes the requirement to 'Facilitate accessibility to facilities and services by a range of transport modes'. PROW can offer vital access means for walkers and cyclists, such as for employment land use (e.g. commuting by bicycle) and in support of the high street, both for employees and customers. IT is considered that this Policy, also Policy S13: Chichester City Development Principles, should aim to encourage such access to be the natural and preferred modes of access, thereby helping achieve the benefits previously described. It is noted Policy S14: Chichester City Transport Strategy, does acknowledge cycling and walking and lends support to their improvement.

The supporting text, paragraph 4.81 makes reference to the Strategic Infrastructure Package (SIP). It is requested that this wording is removed and replaced with West Sussex County Council identifies service infrastructure requirements necessary to support new and existing communities, where strategic development and growth is proposed in Local Plans. These are required to deliver the County Council's statutory responsibilities, strategic objectives and current policy and feed into the preparation of the Infrastructure Delivery Plan.


Policy S13: Chichester City Development Principles
This policy, like policy S12, it is considered should aim to encourage such access to be the natural and preferred modes of access, thereby helping achieve the benefits previously described. It is noted Policy S14: Chichester City Transport Strategy, does acknowledge cycling and walking and lends support to their improvement.


Policy S23: Transport and Accessibility
The policy and supporting text paragraphs 5.15 - 5.33 refer to Transport Infrastructure. Understandably much consideration is given to the A27 around Chichester; however, in addition to seeking new infrastructure from new development, it is recommended support in principle is given to maximising the value of existing infrastructure so as to facilitate off-road user modes accessing either side of the A27.


S24: Countryside
Supporting text paragraphs 5.34 - 5.43, acknowledges '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'. It is recognised in para 7.205, supporting text to policy SM35 Equestrian Development, the high numbers of liveried and stabled horses. A considerable network of businesses are supported by such a high equine population, and in addition to financial value within the local community there is considerable benefit in terms of health and wellbeing of individuals. It is suggested that Policy S24: Countryside, could recognise this specifically.


S27: Flood Risk Management
Supporting text paragraph 5.54, requested amendments underlined - as a consequence of the rise in sea levels and storm surges, parts of the plan area will be at increased risk from coastal erosion, groundwater, fluvial and/or tidal flooding. Hard defences may not be possible to maintain in the long term, therefore development needs to be strongly restricted in areas at risk to flooding and erosion, whilst ensuring that existing towns and villages are protected by sustainable means that make space for water in suitable areas. Development must take account of the policies of the relevant shoreline management plan

Supporting text paragraph 5.58, requested amendments underlined - Built development can lead to increased surface water run-off; therefore new
development is encouraged to incorporate mitigation techniques in its design, such as permeable surfaces and Sustainable Drainage Systems (SuDS). Where appropriate, SuDS should be used as part of the linked green infrastructure network to provide multiple functions and benefits to landscape quality, recreation and biodiversity. This can be achieved through habitat creation, new open spaces and good design. SuDS should be designed to help cope with intense rainfall events and to overcome any deterioration in water quality status. In determining the suitability of SuDS for individual development sites, developers should refer to guidance published by the Lead Local Flood Authority (LLFA): West Sussex LLFA Policy for the Management of Surface Water: https://www.westsussex.gov.uk/media/12230/ws_llfa_policy_for_management_of_surface_water.pdf and, if necessary, seek further advice from the Lead Local Flood Authority LLFA.

S27 policy text requested amendments underlined for section 1 - a. through a sequential approach, taking into consideration all forms of flooding, it is located in the lowest appropriate flood risk location in accordance with the NPPF and the Chichester Strategic Flood Risk Assessment (SFRA); and

S27 policy text requested amendments underlined for section 2. Sustainable drainage systems (SuDS) will be required on major developments (10 or more dwellings or equivalent) and encouraged for smaller schemes. SUDS should be designed into the landscape of all new development and should be included as part of a District wide approach to improve water quality and provide flood mitigation. A site-specific Flood Risk Assessment will be required for sites within or adjacent to areas at risk of surface water flooding as identified in the SFRA. There should be no increase in either the volume or rate of surface water runoff leaving the site.

S27 policy text requested additional bullet point as number 4 - Clear management arrangements and funding for their ongoing maintenance over the lifetime of the development should be proposed. Planning conditions and / or obligations will be used to secure these arrangements.

S27 policy text requested amendments underlined for section 2, but would be section 5 - Development should not result in any property or highway, on or off site, being at greater risk of flooding than the 1 in 100 year storm return period, including an allowance for climate change.


Policy S29: Green Infrastructure
The Green Infrastructure policy is welcomed, including provision of new Green Infrastructure as an integral part of the development at Strategic Development Locations. It is recommended that measures are put in place to secure the long term management of such Green Infrastructure.


Policy S30: Strategic Wildlife Corridors
The identification of Strategic Wildlife Corridors and inclusion of a policy to safeguard them from development is welcomed. It is recommended that CDC promotes positive conservation management within these corridors to maximise their contribution to maintaining and enhancing biodiversity. As stated in Section 5.66, 'These corridors do not stop at the plan area boundaries.' Thus, it is recommended that CDC works in partnership with Chichester Harbour Conservancy and The South Downs National Park Authority to ensure that these Strategic Wildlife Corridors continue to provide effective corridors and connectivity across the wider landscape.

Section 5.66 refers to four Strategic Wildlife Corridors connecting Chichester Harbour with the South Downs National Park but it is noted that there is no mention of the Strategic Wildlife Corridors to the east of Chichester which connect Pagham Harbour with the South Downs National Park (as seen in Policy Map S30b). It is also noted that the maps referred to in Section 5.66, Maps 5.1 & 5.2 are missing.

WSCC and CDC promoted a Mitigated Northern Route for the A27 at Chichester as the preferred option, subject to the inclusion of important mitigation measures that are needed to make the scheme acceptable in environmental terms and the 'full southern route' as a reasonable alternative. Both routes could impact on the identified Strategic Wildlife Corridors. As currently drafted, Policy S30 would seem to prevent a mitigated northern route from coming forward in the future. Therefore, the District Council should consider whether the policy is overly restrictive (for example should it refer to 'significant adverse impacts' or 'unacceptable adverse impacts'?) and how it would be applied if a northern route for A27 were to come forward in the future.


Policy S31: Wastewater Management and Water Quality
S27 policy text requested amendments underlined for section 3, this - Where appropriate, development should contribute to the delivery of identified actions to deliver infiltration reduction across the catchment. Where appropriate development should contribute to the delivery of identified actions to deliver a reduction in the level of infiltration of groundwater into the sewer system.


Policy AL1: Land West of Chichester
AL1 policy text requested additional bullet point as number 8 - Increase capacity to attenuate surface water on site, thereby reducing the discharge flows off the site below current rates and reducing the risk of flooding to residential areas downstream.

AL1 policy text requested additional bullet point under 15 as 15 b- Provide mitigation for any loss of watercourse habitat resulting from culverting for highway provision in the development;

AL1 policy text in supporting 'improved cycle and pedestrian routes linking the site with the city, Fishbourne and the South Downs National Park', a new key link for cycling will be to Salthill Road, thereby enabling cyclists to benefit from the existing bridge crossing of the A27 for journeys to and from the west.


AL2: Land at Shopwyke (Oving Parish)
The policy acknowledges need 'for foot/cycle bridge across A27 to Coach Road'. There is also need for equestrian users to cross the A27 and WSCC PROW has received several enquiries seeking support for such infrastructure. Consideration could be given to the proposed bridge providing for all three modes.


AL3: East of Chichester (Oving Parish)
AL3 supporting text requested amendments underlined for paragraph 6.22 - The site is identified for 600 dwellings, however, there may be potential to deliver a large strategic development of 1000 dwellings, subject to further evidence, including the testing of additional growth on the local highway network and capacity of the site to provide flood risk attenuation for the increased housing density. The site should be master planned as a whole, and delivered through a phased development over a ten year period. Although the site is physically separated from the city by the A27 Chichester Bypass, the development should form a planned extension to the city, forming a new neighbourhood. This will involve opportunities to provide new facilities to serve the wider local community with good off-site access, particularly by walking and cycling to existing local facilities and facilities in the city.

AL3 policy requires exploring integrated green infrastructure with other strategic sites to the north east of the city, Tangmere and the wider countryside. It is considered that future residents will have expectations for provision of safe and convenient links towards Oving and also across the railway to link to the A259 cycle path and PROW south of the A259. It is considered that the policy should be strengthened to ensure such provision.


Policy AL4: Land at Westhampnett/North East Chichester
AL4 policy text requested amendments underlined for section 3 - Open space and green infrastructure, including a linear greenspace with public access along the Lavant Valley.

Taking into account the site-specific requirements, proposals for the site should satisfy the following requirements:

Policy AL4 policy, it is welcomed that 'provision should be made for green links to the South Downs National Park and Chichester City.' Safe and convenient walking and cycling to Lavant, from where people will access the South Downs, will provide for sustainable transport use.


Policy AL5 Southern Gateway
AL5 supporting text requested amendments underlined for paragraph 6.38 - The area has been identified as suitable for comprehensive regeneration with the aim being to make it a more attractive and welcoming gateway for the city, providing new housing, business and retail space and leisure and tourism facilities. Opportunities will be identified to improve transport links with a focus on cycling, walking and public transport and the removal of non-essential traffic from the area. There is also scope for significant public space enhancements and new landscaping incorporating blue / green infrastructure delivering multi-functional benefits.

AL5 policy text requested amendments underlined for section 5 - Provision of open space that:
* Is in accordance with Policy DM34, including retention of the existing playing pitch unless suitable re-provision is provided;
* Reinforces / enhances green and blue infrastructure consistent with Policy S29 and fully exploits the opportunities for sustainable drainage.


AL5 policy text requested amendments underlined for section 8 - Provision of both a surface and waste water management plan which demonstrates no net increase in flow to Apuldram Waste Water Treatment Works would result from this development, unless suitable alternative provision is agreed;


Policy AL6: Land South-West of Chichester (Apuldram and Donnington Parishes)
The LLFA has concerns regarding the lack of reference to flood risk constraints of the site in Policy AL6. There is reference to flood risk in paragraph 6.47. However, the policy itself makes no reference to these constraints.
The constraints arise from a combination of the following:

* Current tidal /fluvial flood risk extending from Chichester harbour to the west and up the River Lavant floodplain; (Map 1)
* Future tidal /fluvial flood risk associated with climate change; (Map 1)
* Constraints on infiltration of surface water run off because of high seasonal groundwater levels (<0.025m below the surface) (Map 2); and
* Constraints on gravity outfalls because of the low relief and long-term reduction in tidal window for discharge.

The above limits the options for how the site can be effectively drained without a step change from typically employed methods to embrace more innovative and currently expensive options e.g. blue roofs and rainwater harvesting.

The LLFA recommends that the policy sets out both the above constraints and the type of innovative drainage that will be required to achieve the development objectives for the site.



Key: Projected medium projection extent of SLR based upon 4m contour

AL6 extent

Current Flood Zone 3 extent.

Current Areas of high (1:30) surface water flood risk

Map 1 Existing and projected Tidal and surface water flood risk for AL6.

Consistent with paragraph 3.2 of the SFRA, given the high risk of flooding both now and into the future for this site, it is recommended that CDC gives consideration to the climate change maps to understand how the flood zones are predicted to change over the lifetime of the development.


Key:
AL6 boundary.

Groundwater levels are either at very near (within 0.025m of) the ground surface.

Groundwater levels are between 0.025m and 0.5m below the ground surface

Map 2 Groundwater flood risk JBA

Policy AL6 WSCC PROW considers 'necessary highway improvements to adequately mitigate the likely impacts on the highway network' to include a bridge crossing of the A27 for convenient walking and cycling access to the Terminus Road industrial estate and the city. There is an existing public footpath but, as this crosses the A27 at-grade, this will not provide the safest facility and not encourage people to minimise use of vehicles for local access. Provision of a bridge and access through the site could also establish a valuable link to the popular Salterns Way walking and cycle path. An additional link to Salterns Way should also be provided off the A286 for the benefit of Stockbridge residents as a safer alternative to the A286.


AL 7 Highgrove Farm, Bosham
The LLFA notes that the above site has the potential for a moderate risk of groundwater flooding. It is likely that this is perched groundwater draining from higher ground / springs to the north that lies in the superficial mixed sediments underlain by Lambeth Clay.


Policy AL8: East Wittering Parish
Due to no information on where housing is going to be located so the LLFA is not in a position to comment on proposed housing allocation sites at this stage.

The policy requires 'Opportunities ... for the expansion and provision of green infrastructure into the wider countryside including between settlements and facilities'. Existing and future residents and the local visitor economy would benefit by delivery of an off-road route for walkers, cyclists and horse riders to and from the Medmerry development and towards Selsey. It is considered that Policy AL8 should aim to deliver this enhancement specifically.


Policy AL9: Fishbourne Parish
Due to no information on where housing is going to be located so the LLFA is not in a position to comment on proposed housing allocation sites at this stage.

It is considered that off-road cycling links to land West of Chichester (off Salthill Road) and to Bosham (off Park Lane) would benefit this community with enhanced sustainable connectivity.


Policy AL10: Chidham and Hambrook Parish
Due to no information on where housing is going to be located so the LLFA is not in a position to comment on proposed housing allocation sites at this stage.

The policy requires 'opportunities' to develop green infrastructure and links to other communities. An opportunity, in conjunction with Highways England, exists to maximise the value of existing infrastructure by creating a new bridleway (for walkers, cyclists and horse riders) on a path using an existing A27 overbridge.


Policy AL11: Hunston Parish
Due to no information on where housing is going to be located so the LLFA is not in a position to comment on proposed housing allocation sites at this stage.

The village is already well connected for walkers to access the surrounding countryside but there are presently no local cycling or horse riding facilities on the PROW network. A bridleway link to South Mundham (with the potential for future cycle links to Pagham and towards Bognor Regis) and to Sidlesham via the golf course and Brimfast Lane would provide residents and visitors with improved access to the countryside and services.


Policy AL12: Land North of Park Farm, Selsey
It is unclear why the policy map shows the proposed strategic allocation lies outside of the Neighbourhood Plan proposed settlement boundary. Some explanation for this anomaly would be helpful in the text.


Groundwater flood risk as depicted by JBA mapping (Brown = seasonal groundwater level lies between 0.025 and 0.5m below the surface).

The principle concern that the LLFA wishes to highlight is the need to ensure that the necessary foul sewerage infrastructure to support development is in place. It is the LLFA understanding that the Siddlesham WWTW experiences capacity issues currently, in part exacerbated by groundwater infiltration. While Policy AL12 states: Development proposals will need to demonstrate that sufficient capacity will be available within the sewer network, including waste water treatment works, to accommodate the proposed development in accordance with Policy S31.

The policy proposes only to provide 'pedestrian links between the site and new development south of Park Lane'. It is considered that cycling links should also be provided.


Policy DM8: Transport, Accessibility and Parking
The PROW network can provide vital means for communities to interact and encourage sustainable local access. The policy requirement to create 'links between new development and existing pedestrian, cycle and public transport networks' is welcomed. However, establishing links into surrounding existing development should not be overlooked also - the greater the permeability, the greater the use.


Policy DM10: New Employment Sites
Whilst mentioned earlier in the Plan in respect of a number of specific sites, this policy should specifically aim to provide, as a matter of course, suitable walking and cycling infrastructure to encourage local sustainable access. This infrastructure may need to extend outside a site boundary so as to provide safe and convenient connection to existing infrastructure. This principle should apply also to Policy DM13: Built Tourist and Leisure Development and Policy DM14: Caravan and Camping Sites.


Policy DM32: Green Infrastructure
Whilst it is recognised the policy proposes support subject to not 'dissect[ing] ... the linear network of cycle ways, public rights of way, bridleways ...', the policy could lend support to establishing new routes as part of the Green Infrastructure network itself.


Policy DM35: Equestrian Development
It is appreciated why the Plan would wish to require future equine development to be 'well related to or has improved links to the existing bridleway network'. However, this will add to the pressure of use on the existing bridleway network, which is not extensive outside of the South Downs, so will increase degradation of paths. Future developments must, therefore, accept to contribute in some way, acceptable to the local highway authority, to mitigate the additional impact to be created so all lawful users are not disadvantaged.


Policy DM29: Biodiversity
The measures to safeguard and enhance the biodiversity value of development sites are welcomed, including seeking net biodiversity gain.


Schedule of proposed changes to the policies map
S30a West of City Corridors -suggest title should be West of City Strategic Wildlife Corridors (to match S30b: East of City Strategic Wildlife Corridors. The Strategic Wildlife Corridors are depicted in different colour patterns on the two plans which is somewhat confusing.


Strategic Wildlife Corridors Local Plan Review Background Paper
Proposed Hermitage to Westbourne Strategic Wildlife Corridor
A large area depicted as Biodiversity Opportunity Area (BOA) in Fig. 1 (immediately to the south of the Rivers Ems & Meadows Local Wildlife Site, Westbourne) is in fact housing and forms part of the settlement of Westbourne. You should consider if this land should be included as having potential for biodiversity enhancement.


Glossary
Includes Sites of Nature Conservation Importance (SNCIs) but not Local Wildlife Sites (LWSs). SNCIs are now known as LWSs.

S16 Goodwood buffer and adjoining land to be made a strategic site for employment space as not affected by noise pollution and will not contribute further to noise pollution.

S30a & S30b are draft corridors as the biodiversity study is incomplete at the time of this consultation and will need to be re-consulted on.
Al 1 is incomplete as presented. The settlement boundary should extend to include sites to the North to accommodate the unmet housing need as an exemption site for affordable homes 100% within 5 miles of the need as required in statute (unless the unmet housing need is returned to SDNP as it should be).
AL4 the land proposed for removal should not be removed as a strategic employment site and should be included in the plan as any development will not be affected by the noise buffer and will not contribute to further light and other pollution not currently present at this commercial site. The settlement to the north should be extended as per statements in AL1
AL 6 is wholly inappropriate for development:
It affects the AONB on its border including the following:
There will be increased light pollution and noise pollution, waste water issues and habitat risk.
The only view of cathedral from the sea will be lost.
This is a flood plain and is therefore totally unsuitable for residential property.
Green buffer between Chichester and Manhood-
If the proposed link road goes ahead, the views of cathedral framed by South Downs will be lost.
Traffic congestion onto the Fishbourne roundabout moves pollution and provides absolutely no purpose and is a ruse to get option 2 delivered with no evidence of being supported by HE as there is no indication of a consultation.

Whilst there is a movement away from car use and getting both adults and children to use bicycles for transport and fitness the important, safe and tourist attracting cycle path of Salterns Way will be lost.
Requirement for infrastructure (schools) which can be met with development in North with 100% exception site to meet unmet housing need of SDNP.
The employment space is in a flood plain

This Policy is insufficiently developed to be meaningful. There is nothing in the Evidence Base (as at the last afternoon for public consultation) in relation to "the forthcoming Chichester Vision - Transport Feasibility Study", which means that no-one taking part in this consultation can be expected to know what this Policy S14 means!
This Policy is crucial to the Plan's Strategic Objectives, including for "safe, clean" communities and Health and Well-Being, as well as Environment. I strongly object to it being brought forward for consultation without adequate detail. This aspect of the Plan should be re-opened for public consultation when CDC can evidence the aforementioned Transport Feasibility Study and respondents are able to consider the full picture. SB1 map should include an employment space and residential strategic site as an exception site for the SDNP unmet housing need. South and east of Goodwood is an ideal site for employment space and then the areas South of Lavant outside the SDNP to be inserted as a strategic site for 100% affordable homes (exception) to meet the unmet need from SDNP.

The decisions on Chichester's housing, roads, employment areas and the infrastructure to support all of these cannot be done piecemeal. The various proposed housing developments, green living and areas such as Southern gate will all be affected by the roads, these issues all need to be discussed and formed as one overall, if longterm, development plan.

Thank you for the consultation on the above document. We have reviewed the document and have the following comments to make in response.

Summary
Overall we are pleased to see that the Plan provides a framework to ensure that new
development will take place in a considered manner to address environmental constraints as well as provide policy hooks for the delivery of environmental enhancements. However, to ensure that the Plan is as effective as possible and meets necessary policy and legislative requirements we have made some recommendations for improvements. These are set out in detail below. Where we support a policy we have also highlighted this below.

We have highlighted concerns with policy AL6 - Land SW of Chichester and have made recommendations for more significant changes to policies in relation to flood risk management (both strategic and development management) and wastewater management and water quality.

As a general comment we note that a significant proportion of the housing numbers
proposed through the Local Plan will be delivered by Neighbourhood Plans. We have
highlighted key criteria for individual locations that we would wish to see considered by those Plans when allocating sites. Where possible we would wish to see these included within the Local Plan policy but as you will be aware we have produced a checklist for Neighbourhood Plan groups in your District which will guide the identification of sites and other key issues and opportunities to be addressed in their Plans.
We would be happy to meet with you to discuss further any of our comments and support the rewording of the policies prior to the production of a pre-submission Plan.

Specific comments

Strategic policies
Policy S12 - Infrastructure
Overall we support the policy. We would recommend that paragraph 3 be amended to
include reference to flood risk management infrastructure.

Policy S17 - Thorney Island
We are currently exploring opportunities for habitat creation in an area on Thorney Island. This is part of our Habitat Creation Programme which seeks to create new habitat to offset losses elsewhere as a result of sea level rise and implementation of coastal and flood risk management infrastructure.
Whilst the policy as drafted, along with other policies in the Plan, would not restrict this opportunity we would like you to consider whether further wording could be included to provide specific support for habitat creation.

Policy S18 - Integrated Coastal Zone Management
We support the continued inclusion of this policy and the specific references to key Plans.
We also support the intention that financial contributions should be sought to deliver both flood risk management infrastructure as well as improvements to the quality of watercourses in the area.

Policy S20 - Design
We support the specific requirements of this policy in point 5 and 8 with regard to green infrastructure and enhancing biodiversity and climate change resilience.

Policy S23 - Transport and Accessibility
The policy includes a new road connecting Birdham Road to the A27 Fishbourne
roundabout. The site includes areas within flood zones 2 and 3 and will cross a number of watercourse. It is essential that the requirements of the NPPF paras 157-8 are satisfied prior to the allocation. We have made detailed comments on this in relation to policy AL6 - Land South West of Chichester.

Policy S25 - The Coast
We are pleased to see the support in this policy for future habitat creation as well as the delivery of flood defences and adaptation to climate change. This supports principles of net environmental gain advocated through the NPPF and the 25 Year Environmental Plan as well as providing necessary policy hooks to support our future plans through our Habitat Creation Programme.
As we highlighted through the Issues and Options consultation this Programme was set up to deliver the compensatory habitat required to address the losses in habitat that would take place as a result of the flood and coastal risk management measures identified in the Shoreline Management Plans. There are specific locations within Chichester District which offer opportunities to provide saltmarsh and coastal grazing marsh in the medium to longer term. These locations include areas in Fishbourne, Chidham and Hambrook and on Thorney Island.

Policy S26 - Natural Environment
We would recommend that the policy wording be extended to say "protect and enhance biodiversity". This is consistent with the NPPF requirements in para 170 regarding net gain and current Government proposals to mandate biodiversity net gain for all new developments.

Policy S27 - Flood Risk Management
We support the intention of the policy, however, we would wish to see changes made to ensure the policy is as clear as possible. We would also recommend you consider what a strategic policy on flood risk management is seeking to achieve in addition to the development management policy. As drafted there are some duplications and/or inconsistencies between the two policies.
It may be more prudent to have a shorter overarching policy that seeks to ensure that flood risk will be taken account of at all stages in the planning process in order to avoid inappropriate development in areas at current or future risk (taking into account climate change) and to direct development away from areas of highest risk. Reference could and should be made to the Strategic Flood Risk Assessment to enable this. We would also support a requirement here for development to seek to achieve a reduction in flood risk for existing communities on and off site.
The principle of point 3 is supported but again should be considered whether it sits best within the development management policy.
We would recommend removing point 4. It is not clear entirely what the rationale behind this is but as drafted it suggests that development within areas with a certain level of flood risk would be approved. This should only be the case when the sequential and exception test have been satisfied in accordance with the NPPF paragraph 157- 8. I would be happy to discuss this further if the intention behind the statement is different.

Policy S29 - Green Infrastructure
We support the policy and are pleased to see specific reference to "blue" infrastructure.

Policy S30 - Strategic Wildlife Corridors
We are supportive of this policy and believe it provides a strong framework for the protection and enhancement of biodiversity within the Plan Area. In particular we support the corridors along watercourses and the links with Biodiversity Opportunity Areas.
As previously highlighted in our Issues and Options response to the Local Plan the
Environment Agency are looking to deliver more natural flood management (NFM) measures to complement and support traditionally engineered flood defenses. This is about working with natural processes in whole catchments and has the potential to help us manage and reduce flood risk in a more efficient, cost effective and sustainable way whilst securing wider environmental benefits. We would be interested to discuss whether the Strategic Wildlife Corridors Background Paper could be expanded upon to consider these opportunities.
A nationally consistent set of opportunity maps to indicate potential for natural flood
management have been produced and I have attached a briefing not which shows how you can access this screening information. The identification and safeguarding of wildlife corridors could support our further work on NFM in the Chichester District and we would welcome the opportunity to discuss this further. In particular we would be interested to discuss whether the Strategic Wildlife Corridors Background Paper could be expanded upon to consider these opportunities.

Policy S31 - Wastewater Management and Water Quality
We support the intention of this policy, however, we recommend that the policy is amended to ensure that specific issues associated with the Apuldram WwTW catchment are addressed and that wider opportunities for the necessary protection and enhancements of water quality in the catchments across the Plan area are taken forward through development. As drafted the supporting text to the policy talks primarily around wastewater treatment capacity and impacts on water quality. However, we would recommend that this is expanded to discuss wider water quality and water resources issues within the Plan area.
This should include reference to the Water Framework Directive and the South East River Basin Management Plan, for which the Council has an obligation to support their delivery.
We would wish to see the Plan include a policy that will ensure that the design and location of development will both protect and enhance water bodies, both surface and groundwater.
We are aware of a few adopted policies regarding water quality that you may wish to review ahead of the further iteration of your Plan. These include policy W DM1 - Water supply and quality in the Arun Local Plan and Policy 31 - Integrated Water Management and the water cycle in the Cambridge Local Plan. The Policy in the Arun Local Plan is subdivided in to 3 sections to cover issues of water supply, water quality and catchment specific measures.
This approach or layout may be useful for you to consider here.
You may also wish to consider whether there are elements of this policy that would be better situated in a development management policy to direct decision making on individual sites.
I would be happy to work with you further to develop this policy, however, to support this the following identifies some key wording that could be included:
"All new development must demonstrate:
* That it has no adverse impact on the quality of water bodies and groundwater, or will prevent future attainment of good status;
* That development contributes positively to the water environment and its ecology and does not adversely affect surface and ground water quality"
This will reflect that impacts on water quality will not solely relate to wastewater infrastructure but can include diffuse pollution as well as physical changes to watercourses.
With regard to the specific requirements for the Apuldram WwTW the policy as drafted broadly reflects the current adopted Plan policy. Would there be an opportunity here for the policy to reflect elements of the recently endorsed Position Statement between the Environment Agency and Southern Water in terms of managing development in the catchment?
The policy makes reference to the higher building regulations standard of 110 l per person per day. We support this standard but would recommend you consider whether this detail is needed in this strategic policy as well as development management policy DM16 - Sustainable Design and Construction.

Site Allocations
Please note we have no additional comments to make on the sites that are being taken forward from the current adopted Local Plan as we consider that the key policy criteria we sought at that stage has been transposed across. We continue to support these requirements.

Policy S32 - Design Strategies for Strategic and Major Development Proposals
We support this policy and specifically requirements for issues such as green infrastructure and SuDS to be fully considered through a Masterplan. Without this overarching vision for larger sites it is often difficult to provide a comprehensive scheme to address key environmental constraints and opportunities.

Policy AL13 - Land East of Chichester
There is a small area within the site located in Flood Zone 2, along with an additional surface water body (lake). We would recommend that the masterplan for this site fully considers these constraints in designing the site including the adopting the sequential approach. We would wish to see built development located solely within Flood Zone 1.

Policy AL 5 - Southern Gateway
We have previously made comments on the proposals for the Southern Gateway through the adopted masterplan for the site. As highlighted there are a number of constraints to development in this area, however, we are pleased to see specific criteria in the policy toensure that these key constraints to the site within our remit are fully considered.
These are:
- Bullet 8 which requires the provision of a wastewater management plan which
demonstrates no net increase in flow to the Apuldram WwTW. This is in line with the
Surface Water and Foul Drainage SPD and the Position Statement on managing new
housing development in the Apuldram (Chichester) Wastewater Treatment Works
Catchment agreed between the Environment Agency and Southern Water.
- Bullet 10 which sets out the requirement for a Flood Risk Assessment to address the
specific flood risk issues on the site. We would recommend that this policy criteria
could be expanded upon to require the sequential approach within the site and to
ensure that more vulnerable uses such as housing be located in the lowest areas of
flood risk.

Policy AL6 - Land SW of Chichester
At this stage we do not support the inclusion of this site within the Plan.
The allocation is composed of housing, employment and a road scheme. Large areas of the allocation falls within flood zones 2 and 3 and we would wish to see further evidence to support this allocation. This may be as part of a Level 2 Strategic Flood Risk Assessment for this site which would then inform a Sequential and if necessary an Exceptions Test. The assessment would need to consider how the proposals could be delivered and identify any mitigation and/or compensation measures that may be necessary to ensure that the development is safe and that there is no increase in flood risk to third parties.
Whilst we note that there are areas outside of the flood plain within the allocation and that some of the development could avoid these areas it is anticipated that the road would cross the flood plain and therefore further detailed understanding of this risk and how it would be managed should be provided.
As drafted the policy makes no reference to flood risk and we would wish to see this
amended.
With regard to housing development we would wish to ensure that all development be located in Flood Zone 1 and that the policy criteria would reflect this.
Other issues include the crossing of watercourses and impacts on biodiversity and water quality. This should be referenced within the policy criteria with requirements for any watercourse crossings to be clear span in design. This will ensure that flood water conveyance is not impeded and protect the habitat associated with those watercourses.
In addition to flood risk we also have concerns with regard to where the sites wastewater would drain to. In line with our Position Statement on managing new housing development in Apuldram (Chichester) Wastewater Treatment Works Catchment allocations within the Local Plan should not drain to the Apuldram WwTW but be directed to alternative WwTW catchments, notably Tangmere WwTW via the new sewer pipeline connection once operational.
It is difficult to understand how this site would connect to an alternative WwTW and therefore would question whether the site would be deliverable.

Policy AL9 - Fishbourne
Fishbourne parish falls within the Apuldram WwTW catchment and we would recommend that the policy makes specific reference to the issues that the Neighbourhood Plan group should consider when identifying sites for their Local Plan.
We would also recommend that specific reference is made to the Source Protection Zone that covers part of the parish in order to ensure that the groundwater, and in turn the drinkingwater supply, is protected.

Policy AL11 - Hunston
There are parts of Hunston that fall within flood zones 2 and 3. We would recommend that if possible the policy makes reference to the fact that built development should be located solely in Flood Zone 1. If this is not possible some reference would need to be made to flood risk and the requirement for the Neighbourhood Plan group to fully consider this through their site allocation process. If sites were to be allocated in flood zone 2 or 3 it is likely that the Plan would need to be supported by a Level 2 SFRA or equivalent.

Policy AL13 - Southbourne Parish
Point 16 identifies the need to ensure that sufficient capacity is available at the relevant Wastewater Treatment Works prior to the delivery of development. This could be expanded to include sewer network capacity. Liaison with Southern Water regarding any necessary phasing of development would be encouraged.

Development Management Policies

Policy DM5 - Accommodation for GTTTS
We support the specific criteria in this policy to ensure that GTTS sites are not located in areas at risk of flooding.

Policy DM14 - Caravan and Camping Sites
We support the particular reference to restricting the occupancy of these sites in flood risk areas. However, there is no specific mention that flood risk areas should be avoided where possible. We would recommend that this should be included within the policy criteria.

Policy DM15 - Horticultural Development
We are pleased to see specific reference to the need to demonstrate adequate water
resources are available and/or water efficiency measures.

Policy DM16 - Sustainable Design and Construction
We support the requirement for new development to achieve a water usage of a maximum of 110litres per head per day.
For completeness we recommend that point 5 should be expanded to include compensation as well as make reference to net gain. This is in line with NPPF para 170.
We support the requirement in point 8 with regard to measures to adapt to climate change.

Policy DM18 - Flood Risk and Water Management
para. 7.115 - reference to the Environment Agency should be removed from this sentence.
The responsibility for surface water drainage and consideration of SuDS sits with West Sussex County Council as the Lead Local Flood Authority for this area.
para. 7.116 - vulnerability - it should be noted that not all development types would be appropriate in all flood zones. Basement dwellings would not be supported in flood zone 3. This paragraph should be amended to reflect this.
We would recommend that you review this policy alongside the strategic policy on flood risk to ensure that they are complementary. Whilst the intention of the policy is good some further clarity could be provided to ensure that all sources of flood risk are considered through decision making.
As drafted there is no reference to the Sequential Test which is a key step in decision
making with regard to proposals in a flood zone. It appears that a number of the criteria included in policy 42 of the current adopted Local Plan have been stripped out. We would recommend further consideration of this for the next iteration of the Plan.
We note that the policy also makes reference to wider water management and does refer tothe South East River Basin Management Plan, however, as per our comments on policy S31 we would wish to see a specific policy that provides for the protection and enhancement of water quality. It may be prudent to consider whether an overarching strategic policy to address flood risk and water management would be best with separate detailed development management policies for each topic.
We would be happy to work with you regarding this detail.

Policy DM20 - Development around the coast
We support this policy and the requirement to safeguard a strip of land behind existing or proposed sea defence or coastal works. Please note that the Environment Agency would seek a 16 metre buffer behind any of our tidal defences.
We support the specific requirement to ensure that development for boat or marine use would not be detrimental to water quality.

Policy DM24 - Air Quality
We are pleased to see that this policy recognises that new development may be located near to existing uses that may be potentially polluting to housing. It is important that the onus should be on the developer/applicant to manage any impact to ensure that they don't leave the existing user affected, e.g. by complaints.

Policy DM26 - Contaminated Land
We support this policy as drafted.

Policy DM29 - Biodiversity
We support this policy as drafted and are pleased to see that specific reference has been
provided to ensure that net gain in biodiversity is actively pursued. Consideration should be
given to the current Government consultation on mandating biodiversity net gain in all new
development and whether this may require further strengthening of the policy wording.
Policy DM32 - Green Infrastructure
We support policy.

See reps

The principal objection is to Policy AL10, with reference to the following policies: S1, S3, S26, S29, S30, D3, DM32 and the evidence of the Sustainable Appraisal and the current HELAA study.

Objection to Policy AL10: The allocation of housing for Hambrook, part of the Council's Local Plan preferred option, is disproportionate, and contrary to its policies and inconsistent with its evidence. The CDC preferred option housing allocation of 500 homes is not consistent with the sustainability evidence. CDC may have underestimated the land required in the parish to meet the Local Plan preferred option housing allocation. CDC has not fully considered the impact on local character of the parish, the landscape and wildlife corridors.

A quote from the 'Sustainability Appraisal for the Chichester Local Plan Review - Preferred Approach' referring to the proposal for Chidham & Hambrook:
"The scale of the development will completely alter the existing development.
There would be significant impact to the existing historic village"

1 Sustainability Appraisal - the evidence and decision making
The Local Plan review has failed to make a proper distribution of housing in the district. In particular its evidence and decision making process for arriving at its allocation of housing to Hambrook is flawed.

The distribution strategy.
How carefully has the Council arrived at the housing allocation for Hambrook? When comparing Hambrook with other nearby parishes the number of houses CDC estimated that could be accommodated in Hambrook on its HELAA study preferred sites is not consistent with the study evidence. Meeting the allocation may require the parish to propose development of previously rejected sites.

The Council considered alternative numbers for housing in the parish
In comparing different housing allocation scenarios, the Council looked at different numbers of houses for the various parishes. In many cases these varied significantly.
eg
Southbourne Min 250 Max 1250
East Wittering Min 0 Max 750
Selsey Min 0 Max 750
Fishbourne Min 250 Max 1000
Bosham Min 250 Max 700
Hunston Min 0 Max 1000

Hambrook Min 500 Max 750

Unlike other parishes, it did not consider scenarios requiring fewer than 500 houses in Hambrook, setting it apart from these other parishes.

Sustainability - the evidence
In considering the proposed parish allocation, the evidence of the Council's Sustainability Assessment says
"The scale of the development will completely alter the existing development.
There would be significant impact to the existing historic village"

This is a substantial change of policy from the previous Local Plan where 25 homes was the indicative housing number for Hambrook. This policy change came very much out of the blue. In fact Chidham & Hambrook accommodated 130 homes under the previous local plan despite the Local Plan indicative number, mainly because the delayed Local Plan allowed developers unfettered rights to develop (before the Local Plan and NP were adopted).
How suitable is Hambrook?
The distance to the nearest town centre (Emsworth or Chichester) is further for Hambrook residents than for other nearby parishes.

Of 31 categories of sustainability,
Hambrook is judged inferior for development compared with Fishbourne (for example) in 7 categories

The categories where Hambrook is less suitable for development than Fishbourne are
"Does the option..."
reduce levels of water pollution?
reduce the need to travel?
improve networks for cyclists and pedestrians?
meet local housing needs?
provide access to services and facilities?
ensure that economic opportunities are accessible to all?
avoid the loss of the Best and Most Versatile agricultural land?

and superior in only one category -
Does the option require new waste water treatment capacity? (It is not clear how this distinction has been made. On the face of it the judgement could well be neutral.)

In the Council's preferred option:
Fishbourne is asked to supply 250 homes, compared to Hambrook which is asked to supply 500.

2 Other sustainability issues -

Landscape. Policy S26 refers

The views of the Downs from the area of the Bus stop on the A259 near Broad Rd looking northeast past Flat Farm have been omitted from the Landscape Capacity Study 2018, East West Corridor, Fig 84 (p507)


The views of the Downs from the area of the Bus stop on the A259 near Broad Rd looking northeast

However the area is judged to have Medium/Low capacity for Landscape change. The view northwards from between Broad Road and towards Drift lane towards the South Downs makes a considerable contribution to the local landscape, but in the HELAA study this is land considered to be suitable for development.
Wildlife Corridor Policy S29, S30, DM 32 refer
Located between the SDNP and the Chidham peninsula and Chichester Harbour, the wildlife corridor through Hambrook linking important Green Infrastrucure, is of special sensitivity.
A variety of species commute or forage between the harbour area and the SDNP including mammals, both deer, and bats of which 10 or more species have been recorded. Badgers, while not normally found on the peninsula, have been seen. Smaller species like Hedgehogs, stoats, weasel, moles, and small prey species, and slowworms, toads and frogs use the corridors to extend their access to foraging habitat. Birds including tawny and barn owls, grey heron and migrant species such as Fieldfare and Redwing use these corridors. Development in Hambrook should be constrained by proximity to the wildlife corridor identified by CDC.
Furthermore there is an important wildlife corridor on the west side of Hambrook, running north south, following the Ham stream.
By comparison, the Wildlife corridor in Fishbourne is away from the development area.


3 The Capacity of Preferred Sites The current HELAA study and Policy DM3 refer

CDC may have underestimated the land required to meet the parish housing allocation.
The proposed allocation of 500 houses is linked to the HELAA study which shows preferred sites in the parish of 15 hectares with a capacity for 565 houses.
However this capacity calculation is based on developer estimates.

The Local Plan Preferred Option policy DM3 indicates a density benchmark of 35 houses/hectare but with exceptions eg
"locations adjacent to sensitive locations (i.e. nationally designated areas of landscape, historic environment or nature conservation protection) where a lower density may be appropriate."

A lower density is appropriate in Chidham & Hambrook because of its semi-rural character, the existing low density nature of development in the parish, the desire to provide green space and landscape views, the perceived need for Bungalows for the ageing population, and the proximity of the Chichester Harbour AONB.
The CDC benchmarks mentioned in the HELAA study (a 'living document') which identifies available sites are:
housing densities (30/ha) and developable areas (80%)
This would mean the preferred sites identified would be adequate for 360 houses. That is, the preferred sites identified by the Council are inadequate to provide the parish allocation of houses.
It is not clear how much land the Council anticipate will be required to meet the allocation of 500 homes, or how, or on what basis this figure was finalised.

If this allocation stands, preferred sites (15Ha) will be inadequate. A further 6 Ha of sites, rejected in the HELAA study, may have to be developed. So the impact on Chidham and Hambrook will be greater than envisaged in the Local Plan preferred option.

4 Conclusion
The allocation of 500 homes for Hambrook is excessive, and is not supported by the Council's Sustainability Appraisal. The low provision of amenities, the proximity of the AONB and Wildlife Corridors, limits the development capacity of the land. The HELAA report suggests there is land suitable for development, but the report appears to have misjudged the suitability and capacity of the preferred sites. We are confronted with choosing not just all the preferred sites but in addition, some unsuitable sites and unsuitable housing densities to provide for the houses required by the plan.

From experience we know that housing development comes at the front end of the plan development period, making absorption of these numbers especially problematic. Equally we know that promised amenities frequently do not materialise as envisaged, if at all.
If we build 500 homes in Hambrook, the number of homes in the village since 2010 will have effectively doubled, reducing the openness of the landscape increasing congestion of local roads and schools, and putting pressure on biodiversity and the green spaces that we do have, with little benefit for residents.

"The scale of the development will completely alter the existing development. There would be significant impact to the existing historic village"

Submission in support of policy S30
Biodiversity is essential to the AONB, and the SDNP. Without it they are diminished, as are we. The enjoyment of wildlife is an important part of the life of many residents, and on many levels vital to our wellbeing.
Biodiversity requires suitable habitat, either of a suitable size, or connected to other areas of habitat by a corridor of suitable width that allows wildlife to move from one area to another either to forage or to breed. With the continuous pressure on land, corridors are vital. Habitat that is cut off, and too small by itself to support the natural diversity of life will die. If it is connected to another patch of habitat allowing movement between the two, the habitat may be large enough to support the natural diversity and genetic diversity which is vital to species survival.
Similarly corridors between the SDNP and the Harbour AONB are similarly important for creatures that need to move further as part of their natural cycle of life or in order to forage or breed.

The combination of distant views, landscape, wildlife and biodiversity, habitat, and corridors is vital to our mental and physical wellbeing. It is also vital to the economy of the region. It is why people come to live here. It is why visitors come.

Chichester District is home to a wide variety of wildlife and habitats. To maintain healthy and vibrant wildlife, we need robust corridors so species can utilise them to travel between their habitats.
A particular example is the rare bats that we are blessed with. They need established corridors to move from roosts to foraging areas. Roosts and foraging areas change with the seasons. Bats flying in the dark need established navigational corridors such as hedgerows. They need darkness. If these corridors are disrupted by development we will lose our rare bats. A corridor can be broken by grubbing up part of a hedgerow, or by the proximity of bright lights, or by reducing its width.

Policy S30 must be supported. It is vital that it is enforced robustly. It is not adequate to assume that we need only worry about the identified corridors. There are more corridors than have been identified so far, and every development should be designed to allow it to act as a corridor, as far as possible.

I urge the planners to ensure the proposed Wildlife Corridors are given the due protection, and importance they deserve, and proper consideration to strengthening the policy by identifying additional corridors.

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

The SDNPA and all relevant authorities are required to have regard to the purposes of the South Downs National Park (SDNP) as set out in Section 62 of the Evironment Act 1995. The purposes are 'to conserve and enhance the natural beauty, wildlife and cultural heritage of the area' and 'to promote opportunities for the understanding and enjoyment of the special qualities of the national park by the public.' The Authority would appreciate reference to Section 62 being added to
paragraph 1.31 of the draft Plan.

Duty to Cooperate

As set out in our previous response, the SDNPA has a set of six strategic cross-boundary priorities.
I would like to take the opportunity to again highlight these which provide a framework for ongoing Duty to Cooperate discussions:
* Conserving and enhancing the natural beauty of the area.
* Conserving and enhancing the region's biodiversity (including green infrastructure issues).
* The delivery of new homes, including affordable homes and pitches for Gypsies, Travellers and Travelling Showpeople.
* The promotion of sustainable tourism.
* Development of the local economy.
* Improving the efficiency of transport networks by enhancing the proportion of travel by sustainable modes and promoting policies which reduce the need to travel.

Conserving and enhancing the natural beauty

We welcome the requirement in policies S26 (Natural Environment) and DM28 (Natural Environment) to ensure that development proposals have no adverse impact on the openness of views and setting of the SDNP. It is noted that a substantial amount of new homes are proposed on the A259 corridor between Emsworth and Chichester. This is a sensitive stretch of land in the coastal
plain between the coast, the south coast railway and the A27. This corridor provides the connection, including intervisibility, between the protected landscapes of the South Downs National Park and Chichester Harbour AONB, for example views of the channels within the Harbour from the Trundle and Stoke Clump.
We note the intention of identifying settlement gaps and look forward to seeing the evidence base and the proposed gaps in the Regulation 19 iteration of Chichester Local Plan Review 2035, particularly as to how they will contribute to safeguarding the relationship between the SDNP and Chichester Harbour AONB. We would welcome the opportunity to work with CDC on this matter.

Locations identified for development

Development in the CDC Local Plan Review 2035, particularly along the A259 (policies AL7 Highgrove Farm Bosham, AL9 Fishbourne Parish, AL10 Chidham and Hambrook Parish, AL13 Southbourne Parish) corridor, have the potential to deliver a significant cumulative adverse impact on the setting of the National Park and its important relationship with the Chichester Harbour AONB.
We consider that the policy wording for the A259 corridor Strategic Site Allocations could be more robust and proactive with regard to conserving and enhancing the National Park. In particular, it could provide more active direction to applicants in order to ensure adverse impacts are minimised locally, and in relation to the National Park. For example, with regard to green infrastructure, each of the
A259 Strategic Site Allocation policies (AL7, AL9, AL10 and AL13) include a criteria requiring the provision of green infrastructure, and we would suggest this could be re-worded as follows: 'Identify opportunities are taken for and secure the expansion and provision of multifunctional green infrastructure into the wider countryside and protected landscapes of the South Downs National Park, and Chichester Harbour AONB, including between settlements and facilities.'

Reference to considering and minimising impact on the SDNP in each of the A259 Strategic Site Allocation policies (AL7, AL9, AL10 and AL13) is welcomed, for example criterion 5 of policy AL9:
Fishbourne Parish. However, this could be usefully re-worded to ensure that developers do not create a scheme and only consider the impact afterwards. Wording to direct people to 'respect and respond to the National Park landscape, its setting and purposes prior to development design' avoids the risk of relying upon ill-informed and inappropriate mitigation measures This matter could also be usefully
addressed in relevant Strategic and Development Management policies elsewhere in the Local Plan concerning design, landscape, and the South Downs National Park. We would be happy to work with CDC on this matter.

We note Strategic Policy S32, which requires proposals for housing allocations and major development sites to be accompanied by a site-wide design strategy. We would strongly encourage masterplans and development briefs for each allocation (or settlement where the sites are to be allocated through a Neighbourhood Plan) to come ahead of applications and demonstrate positive design interventions which respond directly to landscape/SDNP sensitivities. We would be happy to be involved in shaping these as consultees in order to achieve the best quality scheme. These interventions could be written in to the policy wording.

There is an opportunity for allocation policies to seek to deliver the joining up of existing, and/or improvements to, the network of RoW (Equestrians, Cyclists and Pedestrians) to enable and encourage access into the National Park in accordance with the National Park's Second Purpose.
Further comments on specific allocations:
* Policy AL1 (Land West of Chichester) - We welcome the consideration of the Centurion Way in criteria 10. However, we would ask for stronger policy wording to explicitly state that development must not adversely affect, and preferably enhance usability of, Centurion Way connecting Chichester with the SDNP.
* We note that Policy AL4 (Land at Westhampnett/NE Chichester) still refers to Lavant Valley greenspace but we query if this is likely to be secured now based on planning applications submitted. We would suggest that criteria 12, last sentence, could also refer to securing offsite improvements/upgrades for cycleway links
* Policy AL6 (Land South-West of Chichester (Apuldram and Donnington Parishes)) should address the important opportunity to secure a safe off-road connection between the Centurion Way and Salterns Way as the two flagship and largely safe off-road multi-user trails linking Chichester with (respectively) SDNP and Chichester Harbour AONB. We would welcome the opportunity for further dialogue and joint working on this matter with CDC.
* We welcome criterion 5 of policy AL14 (Land West of Tangmere). It is a sensitive site due to the impact on clear views of the site from important locations in the SDNP such as the Trundle and Halnaker Hill. We therefore ask that criterion 5 is expanded to emphasise and address the sensitivity of the site
Specific wording comments on other policies/paragraphs:

We have the following comments on the following specific paragraphs:
* Para 2.29 (challenges and opportunities facing the Plan Area): We suggest that the 7th bullet point should say 'Protect and enhance the character of the area including the Chichester Harbour AONB and the setting of the SDNP'.
* Policy S20 (Design): As mentioned above regarding the A259 Strategic Site Allocation policies, we consider that the wording of this policy could be more proactive by including wording to direct people to 'respect and respond to the National Park landscape, its setting and purposes prior to development design'.
* Policy S25 (The Coast): Paragraph 5.44: We suggest adding 'serves to provide important scenic views from the water across to the SDNP which should be conserved'.
* Policy S26 (Natural Environment): We suggest deleting reference to 'openness' and to include reference to views from and to the National Park.
* Policy S32 (Design Strategies for Strategic and Major Development Sites): We suggest that the policy requires such design strategies to be informed by landscape character and the sites landscape context. We also suggest that criteria h. includes a requirement to state maximum building heights.
* Policy DM17 (Stand-alone Renewable Energy): The policy requirement for demonstrating no significant adverse impact upon landscape or townscape character is welcomed. We request reference is also made specifically of views of the SDNP.
* Policy DM19 (Chichester Harbour AONB): We request criterion three also identifies the relationship by way of intervisibility between the AONB and SDNP.
* Policy DM22 (Development in the Countryside): Further to comments on the A259 Strategic Site Allocation policies and S20 (Design), we consider that the wording of this policy could be more proactive by including wording to direct people to 'respect and respond to the National Park landscape, its setting and purposes prior to development design'.
* Policy DM23 (Lighting): The reference to the South Downs International Dark Skies Reserve is welcomed. However, proposals that aren't immediately adjacent to the Reserve may have significant adverse impact, for example due to the site's particular visibility within the landscape or sky glow; we suggest that wording is amended to reflect this.
* Policy DM32 (Green Infrastructure): We suggest that this policy could benefit from specifically citing that green infrastructure should be 'multifunctional'. We also recommend reference to opportunities to make better green infrastructure connections in line with Lawton Principles of 'bigger, better, more joined up', to ensure these spaces can function and therefore deliver benefits.

Conserving and enhancing the region's biodiversity (including green infrastructure).

The SDNPA welcomes the approach taken by CDC to identify green infrastructure and habitats networks as cross boundary issues in paragraph 1.26 of the Plan. The SDNPA looks forward to continuing to work with CDC on green infrastructure matters particularly as your Plan is progressed to pre-submission.

We note that an open space study has been prepared and this could be linked up with other work into a wider green infrastructure approach incorporating the identified strategic wildlife corridors, areas for natural flood management, PROW and connections between the settlements, protected landscapes and the stations, landscape views/settlement gaps and some land management guidelines
for these really important areas. This would be particularly useful to inform development proposals in the A259 corridor.

Policy SD30 - Strategic wildlife corridors

The SDNPA very much welcomes and supports the inclusion into policy of wildlife corridors which traverse the district connecting the two protected landscapes of the Chichester Harbour AONB and the SDNPA.

It is important to note that there is no corresponding policy within South Downs Local Plan, currently at examination, to continue protection of the wildlife corridors within the SDNP. We have concerns that it is unlikely to be sufficient for the corridors just to reach the SDNP boundary. We also note that several of the corridors appear to be quite narrow, especially to the east of the City, and we query whether they are substantial enough to perform the intended function.

We note the detailed evidence outlined in the background paper and the SDNPA would like to work with CDC on the continued development of the strategic wildlife corridors, in particular with regard to their connection points with the National Park and how we can work together on robustly delivering this strategic cross boundary objective.

Ebernoe Common, The Mens, and Singleton & Cocking Special Areas of Conservation

The SDNPA has been working together on technical advice to facilitate sustainable development within proximity Ebernoe Common, The Mens, and Singleton & Cocking Special Areas of Conservation, which are designated for their populations of Bechstein and barbastelle bats. The draft Sussex Bat Special Area of Conservation Planning and Landscape Scale Enhancement Protocol was published in 2018 in the Core Document Library as part of the South Downs Local Plan Examination. The Protocol is based on published data which identifies key impact zones, one of 6.5km and one of 12km, around each of the three SACs. It also sets out avoidance, mitigation, compensation and enhancement measures to inform and be addressed by development proposals. Parts of the Chichester District Local Plan area are within these key impact zones. These zones have been incorporated into policy SD10 of the South Downs Local Plan and the policy has not been modified by the Inspector as a result of the examination in public. The SDNPA would welcome the opportunity for further discuss with CDC and Natural England on this work.
Solent Recreation Mitigation Partnership

Both CDC and the SDNPA are members of the Solent Recreation Mitigation Partnership (SRMP) (also known as Bird Aware Solent) which has provided a strategic mitigation solution to address potential harm to the protected habitat at Chichester Harbour and ensuring compliance with the Habitats Regulations. We note that the SRMP mitigation solution is reflected in Policy DM30 and we look forward to continuing to work with CDC and other members of the SRMP on this matter.
With regard to paragraph 7.185 we suggest reference to the Medmerry Realignment be a new bullet point: 'Medmerry realignment, which is intertidal habitat created in 2013 to compensate for historic losses across the Solent to SSSI and Natura 2000 sites'.
We also suggest the following wording amendment to paragraph 7.187: '...This is particularly relevant to Chichester and Langstone Harbour and Pagham Harbour and the impact of recreational pressure on the birds that use these Special Protection Areas. Any negative impacts that the development may have should will be weighed against the benefits of the proposal. This may include looking at whether the assets are surplus to requirements, if the proposal impacts on a small area or corridor or if a wider need exists for the development and there is no alternative location....'

The delivery of new homes, including affordable homes and pitches for Gypsies,
Travellers and Travelling Showpeople

Policy S4: Meeting Housing Needs
The SDNPA welcomes the uplift to the housing target to address unmet need arising in that part of the SDNP within Chichester District (estimated at 44 dpa at the time the last Statement of Common Ground was agreed in April 2018). The provision of 41 dpa broadly meets this need.
We note that the Objectively Assessed Need is calculated only for the area outside the SDNP using the 'capping' method set out in the Government's standard methodology (the currently adopted target of 435 dwellings per annum plus 40% = 609) - this is helpful as it makes a clear distinction between the assessed need for Chichester District Local Plan area and that for the SDNPA, notwithstanding
the Duty to Cooperate.

Policy S5: Parish Housing Requirements 2016-35
We support identification of parish specific housing requirements providing certainty to local communities. This is the same approach as we have taken in the South Downs Local Plan.

Affordable housing
We note that there is a need for 285 affordable homes per annum (source: HEDNA) which underlines the need for a strong policy which seeks to maximise affordable housing delivery. This high level of need is common to the wider sub-region and is an issue relevant to the wider housing market area.
The SDNPA supports CDC's approach of taking opportunities arising from new residential development to contribute to the supply of affordable housing, to meet local needs in terms of type and tenure (paragraph 4.35). In this respect, it is important that the whole plan viability testing currently being undertaken should fully reflect Planning Practice Guidance on viability, such that as high as possible a percentage of affordable housing is sought. We also support the positive approach to Community Land Trusts (CLTs) as a mechanism for delivering affordable housing (paragraph 4.45). Chichester District Council may also wish to note that SDNPA has, subject to main modifications consultation, received the go-ahead from its Local Plan Inspector for unmodified inclusion of Strategic Policy SD28: Affordable Housing in the South Downs Local Plan. This includes a lower threshold than that advised in Government policy, and also seeks on-site affordable housing from small sites below the 11 threshold stipulated in Government policy.

Policy S7: Meeting Gypsies, Travellers, Travelling Showpeoples' Needs
The SDNPA supports the principle of the policy and whilst noting the significant need arising. It is not clear whether the intention is to allocate sites to meet the need in a separate DPD. Paragraph 4.49
refers to 'the forthcoming DPD' and policy S7 to sites being allocated in a Site Allocation DPD 'where there is a shortfall in provision'. Has this work already been triggered by the scale of need? The policy and associated text could be clearer on this matter.
We would like to highlight that there is limited capacity within the National Park to allocate sites for Gypsies and Travellers through DtC, given significant landscape constraints. We suggest that the coastal authorities and SDNPA continue to work closely with regards addressing the need.

Improving the efficiency of transport networks by enhancing the proportion of travel by sustainable modes and promoting policies which reduce the need to travel
The SDNPA supports in principle Policy S23 (Transport and Accessibility). In particular, we support emphasis on encouragement of use of sustainable modes. We suggest explicit support in the text for improving links into the National Park, particularly by sustainable and active transport modes.
Allocation policies should also should seek to deliver the joining up of existing, and/or improvements to, the network of Public Rights of Way.

SDNPA notes reference in the policy to a coordinated package of improvements to the A27 Chichester Bypass, as well as to a new road from the Fishbourne roundabout. The SDNPA would urge that any such schemes be fully assessed, including streetlighting, for potential adverse impacts on landscape where there is a relationship with the National Park and its setting. Any such impact will
need to be mitigated, and opportunities taken to enhance green infrastructure networks and public rights of way networks. CDC may wish to consider whether the Policy S23 should include additional wording to reflect these principles.

Centurion Way
The SDNPA supports the reference to Centurion Way in paragraph 7.185 in relation to Green Infrastructure & resistance to dissection of green movement corridors. There are opportunities to improve these links, for example, suggest explicit reference to protecting and enhancing the Centurion Way. The reference to Salterns Way is also supported. Centurion Way and Salterns Way are two flagship off-road routes for the SDNP and AONB respectively and do not currently benefit
from safe off-road connection. The SDNPA would strongly support policy to secure this connection and would welcome opportunities to discuss this further and work jointly with CDC on this strategic issue.

With regard to Strategic Policy S14 (Chichester City Transport Strategy) we request that the SDNP is included in the penultimate bullet point as a destination for strategic cycle routes.

Transport evidence
We would highlight that the transport assessment carried out to inform the South Downs Local Plan.
This indicated a potential severe impact on the Petersfield Road / Bepton Road / Rumbolds Hill junction in Midhurst of additional development in the town, in the context of junctions already becoming overcapacity due to background traffic growth, for example, . arising from strategic development in neighbouring planning authorities.
A review of the CDC Transport Study of Strategic Development indicates significant traffic growth arising from Scenario 1 (the preferred strategy). It is not clear from the study how this will impact on the A286 towards Midhurst, which in turn could have a critical impact on junction capacity at Midhurst.
SDNPA may seek further assurance that such potential impacts have been looked at, and appropriate mitigation sought.
Other comments
Page 16 - Local Plan area map: Request clarification whether the Local Plan area includes the following two properties, as not clear from the Local Plan Area map: Stedlands Farm, and The Stable/Little Stedlands, Haslemere GU273DJ
We would like to wish you well in the progression of your Local Plan and would welcome further discussion and joint working on the strategic cross boundary matters raised.

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

RESPONSE FROM FISHBOURNE NEIGHBOURHOOD PLAN REVIEW GROUP


INTRODUCTION
Our group was established by Fishbourne Parish Council to advise the Council on how it might produce a Revised Neighbourhood Plan which would be "aspirational but deliverable" (NPPF, para 16 b).

To reach the "aspirational" requirement, we will examine every source of land supply with the possibility of sustainable development. We will do this through:
* A re-examination of the "red" sites rejected in the HELAA Report
* The Issue of a call for sites in case there are any landowners/developers who missed the HELAA call;
* Initial contact meeting with individual developers;
* Consideration of small sites for first five years of FNP 2020-2035;
* Consideration of Clay Lane developments (with possible need to amend when decisions are reached about Wildlife Corridor);
* Comparison of the total potential of the above sites and the allocation to Fishbourne in the submission report so that any alterations can be made.

We are aware of the requirement for revised Neighbourhood Plans to have made good progress by June 2019 in order to demonstrate that the Local Plan Review Strategy can be delivered.

Our work, however, is hindered by the unacceptable process by which the allocation of 250 additional homes for Fishbourne was made and the resultant confusion and traffic issues... Our principal concerns centre on five aspects:

1.The lack of any declared criteria for what otherwise seems a purely arbitrary allocation taking no account of the local situation — a flagrant flouting of the spirit of Neighbourhood Planning as envisaged by the Secretary of State, James Brokenshire: "The number of new homes we build won't be based on what a developer thinks they can sell but on the real needs of local communities."

In order to gain approval, our revised Plan would be required to meet a target allocation of new building which has been set arbitrarily at 250 (five times the allocation in our original plan) and despite repeated requests little information has been released about the criteria used to calculate the parish allocations. Such information as we have suggests that "land availability" was a factor but there seems to have been:
* no discrimination between productive top quality farmland and scrubland;.
* no allowance being made for the difficulty in finding sustainable land because of Fishbourne's regular expansion since the 1970s.

When the Fishbourne Neighbourhood Plan 2014-2029 was approved, the allocation of 50 new homes was considered appropriate because of the size of the village and its proximity to Chichester. Four years later, this has changed to an additional 250 new homes with the only apparent reason (para 6.63) being that, as Fishbourne has been classified as a "service village', it must need growth of population to promote its vitality and to sustain its local facilities including the school and the community centre. This may be true of some rural villages but it is totally untrue about Fishbourne.

Indeed, not only has CDC failed to make out a case for its arbitrary allocation of 250 homes to Fishbourne, it has failed to make out a case for any additional housing since the lack of vitality is not an issue.
* Development has already reached the Northern, Southern and part of the Eastern boundaries of the village,
* The primary school is full with children exclusively from its catchment area
* Families moving into Fishbourne are having to seek places in schools several miles away which not only increases travel and pollution but means the children have no school-friends in their own community.
* The Fishbourne Centre frequently works at full capacity.
* St. Peters Place, a new Church and community facility, is also already working at near capacity.
* Fishbourne has a proactive Parish Council which had a couple of Village Plans before its Neighbourhood Plan 2014-29 (which has already met its allocation)
* The much used facilities on Fishbourne Playing Field (football —junior and adult; cricket, tennis, bowls, croquet, outdoor gym equipment and a secure children's play area) are fully used and the envy of local parishes!
* Fishbourne has a strong community spirit, the latest example of which, the Fishbourne Companions, have just celebrated their first birthday

Since the only land that might be classified as sustainable could produce only 200 homes, meeting the target allocation of 250 for Fishbourne would have to include some land from Bethwines. This would remove from the community their right to choose where building should take place. More important, too, is that this enforced breaking of the Parish Council's policy would lead inevitably to the whole farm being used to provide 1,000 homes regardless of:
* the top quality productive farmland,
* the valued views between the Harbour and the South Downs,
* the destructive effect on wildlife and birds especially at nesting time;
* the gridlock that would result on inadequate roads;
* an unacceptable health risk caused by the rise in air pollution.


The case for a need for growth in Fishbourne in order to sustain the vitality in the village and to help to sustain the school and other services has clearly NOT been made. What proportion of the justification for the allocation of 250 was based on this false data?



2. The impact of the proposed Wildlife Corridor on land in the Eastern part of the village (Clay Lane).

In the view of professional conservationists, the designated strategic wildlife corridors proposed in the local plan do little good, are too narrow to support the wildlife and do not go far enough in their coverage. They recommend that a single much wider corridor, which would provide wildlife with the natural space in which to move about relatively undisturbed. Therefore their positioning in this plan needs to be removed, rethought and reduced to one single, much wider area - for which Bethwines Farm is ideal!

Until the last minute imposition of the Wildlife Corridor, this site was the only site where an aspirational approach might have produced 160 of the 250 allocation. Failing a relocation of the corridor, we strongly recommend that the allocation for Fishbourne should be reduced by the number of homes the parish council has been prevented from offering on the Clay Lane site as a result of the decision taken by CDC since it is not equitable for the negative impact of a District Council initiative to fall on one parish.


3.Policy on Bethwines Farm.

"National policies and regulations aim to protect the best and most versatile (BMV) agricultural land and soils in England from significant, inappropriate or unsustainable development proposals." (Natural England, 2018).
"The Local Plan helps us to:
* shape where development goes;
* protect the character and beauty of the area" (Chichester District
Council,2018)
The intention to build on Bethwines Farm is not compliant with either of these statements. There needs to be more openness, clarity and consistency about the District Council's view on Bethwines Farm. This seems to shift from regarding it as :
* not being suitable for sustainable development (current Local Plan);
* suitable for 81 homes in HELAA with the remainder being unsuitable;
* suitable for 200+ if the Wildlife Corridor is not relocated from Clay Lane;
* (almost inevitably in the next Five Year Review) suitable for the remainder of the Farm leading to a total build of 1,000 homes, thereby doubling the
population of Fishbourne, causing unsustainable traffic congestion and
unacceptable levels of pollution and causing irreparable damage to, rather
than protecting "the character and beauty of the area".

Against this inconsistency, we support the Parish Council's consistent stance which is compliant with the 2018 revision of the National Planning Policy Framework, the existing Fishbourne Neighbourhood Plan - and even some of the Policies in the District Council's own Local Plan Consultation Document, with which the proposed practices are not compliant!

We will continue to plan on the assumption that CDC will note all the implications of building on Bethwines and will come to realise that building on Bethwines would not be appropriate but would "cause unnecessary, irreparable damage and would have an adverse impact that would demonstrably outweigh the advantages."

4. Conflict between policies and practice (infrastructure and transport)
CDC Local Plan Review Policy DM8 is a classic example. It states that any development must minimize and not create or add to problems of highway safety, congestion, air pollution or other damage. (The policy omits sound and light pollution which should be added).
It is our considered opinion that this is unachievable.
The A27 does not serve communities west of Chichester unless they use the A259 as a feeder road and there are no major employers in Fishbourne which makes travel to work a necessity.
Fishbourne is designated as a service village. The definition is that the village can provide a reasonable range of basic facilities, or have reasonable access to nearby facilities. We have no shops, no banks, no doctor, no facilities, in fact only two pubs and the Fishbourne Centre. Reasonable access - not possible due to distance and huge traffic problems. The 700 bus service that runs along the A259 is excellent, but it is nationally accepted that unless a bus stop is within 400 metres of the house, residents will not use it. The 56 bus only runs in the morning at 0815, 0943 and 1143hrs as a very limited service into the City but will again still be out of reach of potential Bethwines residents. The railway provision is a halt, not a station, and only has one train an hour in each direction, and again is out of reach of Bethwines development. Public transport is therefore not a viable option for any development on Bethwines Farm.
The 'transport corridor' is not effective now let alone with the 2250 houses scheduled to be built along the corridor between Chichester and Southbourne. A study of the 97 house Flavian Fields development in north Fishbourne revealed that 65% work and have to travel to employment outside of the village. This will apply equally to Chidham and Bosham. This figure also takes no account of the fact that parents will transport their children to school by car. These schools will be outside of the village due to Fishbourne and Bosham Schools being already full and the only secondary school at Southbourne being further away than Chichester schools. It has been established that Fishbourne already has the highest car dependency in Chichester District.
The CDC review team has used a national statistic of 50 cars per 100 households, but that is seriously flawed based upon local evidence that, from the Flavian Fields survey, places the figure at 200 cars per 100 households.
Specifically, the huge growth of 1000 houses in Fishbourne, Bosham and Chidham, amounts to a minimum of 1000 additional cars travelling during peak times. We would anticipate that these villages will use Chichester for employment, schools and facilities. The 1250 houses in Southbourne will further complicate the numbers, but a considerable number will probably travel westbound,
The average length of a family car is now 4.8 metres. Allowing for about a one metre+ gap between them, 1000 cars need a stationary road space of about 6000 metres or Chidham to the Fishbourne Roundabout.
The A27 roundabout at Fishbourne is a huge blockage to any increase of traffic. There is already a peak time queue every morning of half a mile along the A259, and six miles of standing traffic on the A27. That is the current situation, but the projected figures are much worse. The roundabout will be used by the following additional traffic attempting to access the A27:
* 1600 additional houses at Whitehouse Farm via Cathedral Way
* 1000 houses at Fishbourne, Bosham and Chidham via A259
* Terminus Road traffic via Cathedral Way
* Link road to development south of A27
* Manhood Peninsula traffic diverted west of Stockbridge.
The plans for a hamburger roundabout cannot deal with this size of traffic flow, and we can only deduce that incomplete data has been fed into the computer model to establish this junction method. The eastbound queue of stop-go traffic as a result of the traffic lights will just move up to Stockbridge blocking Fishbourne: the same would be true for westbound traffic. Where some of these roundabouts have been installed they have not been a success in handling traffic better.
The projected traffic queues will further add to the destructive effects of pollution if we have miles of standing traffic in Fishbourne. There are already 4 Air Quality Management Areas (AQMA) in Chichester, the most of any area in West Sussex. Is Fishbourne to become the 5th? Simon Ballard, CDC Senior Environmental Protection Officer has publicly attributed 4.1% of Chichester's being due to PM2.5, just one pollutant of the many pollutants from vehicle emissions.

This issue with air quality pollution does not stand alone, Fishbourne residents will suffer increased noise pollution and light pollution from the proposed raised Stockbridge Link Road, its slip road will impinge by 7,000m2 into The Fishbourne Meadows Conservation Area, further restricting Fishbourne residents from exiting the A259.
We would seek the opportunity to see the traffic flow data used for the junction analysis in order that we may use it for an independent study using road traffic simulation software. The timescale you have set for consultation does make a challenge very difficult and the CDC should be cognizant of and sympathetic to our inputs.
There is no doubt that the traffic presumptions made in the plan are seriously flawed, and that, if the true figures were used, the traffic plans would have to be substantially up- rated. This needs to be examined by the Planning Team.
5. Uncertainty about the A27
Peter Brett's traffic mitigation study in CDC's Local Plan has a clear dependency on Government's funding of the A27 improvements in Road Investment Strategy 2. The mitigation described in their study will mean that Chichester District Council will violate air quality levels throughout the plan period. Add to this the congestion and air pollution due to construction and the spread of pollution during works for diversionary routes.

One reason to abandon the A27 Northern upgrade was marginal and set against spend, even though the cost equates to a maximum of 2% of the £25 billion budget announced by the Chancellor in his Autumn statement. The other reason given is the conflict with National Policy, at some point will be tested for the first time, probably at Arundel. Where the requirements of the policy will have to be balanced against the good to the public (air quality, and accident reduction, support for economic growth locally and regionally).
The two reasons given by Highways England to abandon the A27 upgrade are all marginal, and set against spending on other parts of the country the financial argument does not hold water given the acknowledged congestion and accident figures of the A27.
The key to any resolution of the A259 and Fishbourne roundabout traffic problem is whether Highways England will take the Chichester District and BABA27's advice and take the A 27 flow away from Fishbourne Roundabout via a northern by pass. If the A27 is moved, this would still leave flows from the current bypass and Manhood peninsular etc. to be negotiated at Fishbourne roundabout when a hamburger roundabout would probably suffice.

SUMMARY OF MAIN RECOMMENDATIONS


Our recommendations to the CDC for the way forward to an aspirational but deliverable allocation for Fishbourne:

(1) Reassess the allocation for Fishbourne using accurate local evidence to base the allocation on need and taking into account the limited space available after an increase in population of 33% since 2001 on top of a doubling of the population over the previous four decades.
Correct other errors such as describing the AONB as being south of
the village: in fact the AONB stretches up to the A259
Insert vital information such as a map showing the potential sites: consultees
cannot comment adequately without this information and this makes the
consultation process unsafe.

(2) Take into account the views of the community in the village survey where:

* maintaining "Best and most versatile agricultural land";
* enhancing highly valued landscapes with views between Chichester Harbour AONB and the South Downs National Park;
* creating strategic gaps to retain the geographical identity of individual villages

all scored over 90% support (and are all compliant with NPPF).

(3) Given the flaws in the traffic presumptions, provide Fishbourne Parish Council with traffic-flow data so that an independent study can be conducted.

(4) Develop an open and consistent policy for Bethwines Farm

(5) Avoid causing irreparable harm. In many cases, it is possible to offer compensatory strategies to offset the original damage to amenities affected by new housing development. However, this is not possible where "best and most versatile agricultural land" is used for building.

(6) . Provide confirmation and proof that appropriate research has been conducted on air quality,particulate concentration and pollution expectations resulting from the increased traffic at Fishbourne Roundabout, including that expected to result from standing traffic on the approaches to Fishbourne roundabout from A259 westwards and the new proposed Donnington / Apuldram junction from the south into Fishbourne Roundabout.

Fishbourne Roundabout / A259 is already exceeding the EU air quality regulations and any 'improvements' planned for this roundabout will need to show substantial air quality improvements.

(7) Provide confirmation and proof that the expectations for increased sewage and waste water / run-off water from new building along A259 and in Fishbourne have been taken into account with regard to flood risk at the harbour and the approaching ditches in and around the Fishbourne area and that Southern Water have been involved regarding their capacity for these extra homes requirements.


(8) If the Wildlife Barrier is not relocated, reduce the Fishbourne allocation accordingly.









CONCLUSION

We repeat our intention to construct a revised Neighbourhood Plan that is aspirational but deliverable. However, before progress can be made we need a resolution of the problems raised in this report. - and, given the exceptionally tight timetable for the preparation of revised Neighbourhood Plans, there is an urgent need for these issues to be addressed and resolved.


Contact for queries or further discussion: Geoff Hand
Councillor.hand@fishbourne-pc.gov.uk

January 2019


FISHBOURNE NEIGHBOURHOOD PLAN STEERING GROUP
Geoff Hand Chairman, Fishbourne Parish Council; Editor FNP (2014-29)
Lucy Wright (Administrator) Clerk, FPC
Cllr. Louise Goldsmith County Councillor, Chichester West Division
Cllr. Adrian Moss District Councillor, Fishbourne Ward
Cllr. Adam Porter FPC & Flavian Fields Residents Association
Cllr. Ruth Keeley FPC & Mosse Gardens Residents Association
Cllr. Lynda Hunter FPC & Fishbourne Companions
Cllr. Mike Lander Vice-Chairman, FPC
Julian Snell Former Chairman FPC
Andy Relf Resident; formerly Sussex Police & Home Office
Maggie Borsberry Fishbourne W.I.
Trina Miliam Fishbourne Evening W.I.
Naomi Day Headteacher, Fishbourne Primary School
Rev. Canon Moira Wickens Rector
Vicky Blamire Fishbourne Pre-school
Libby Alexander Resident & CPRE
Zoe-Elizabeth Neal Save our South Coast
Edwin Scarterfield Resident, Employer and Fishbourne & Parklands Flood Protection Group
Roger Gould Resident Roman Way
Rita Lowry Resident, Bethwines Close
Pat Lowry Resident, Bethwines Close

See attachment

Characteristics of the Plan Area: a spatial portrait
The term East-West Corridor used with in regard to west of the City of Chichester is ill defined and the use of this term 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 AONB and Chichester
Harbour AONB

Policy S2 Settlement Hierarchy
Object
Chidham & Hambrook, among the other Bourne villages, is characterised as a 'service village' with no definition or explanation of what this means. This term does not reflect the special and unique character of any of these areas, it designates them as no more than utilitarian dormitory communities.
"The largest level of growth is expected in the service villages and settlement hubs, able to accommodate higher levels of growth without adversely impacting the character of the settlement". An increase in growth of housing stock by 55% will undoubtedly negatively impact Chidham & Hambrook.

Policy S3 development Strategy
We believe the rationale for how the number of 500 dwellings for Chidham & Hambrook was arrived at to be wanting and the supplementary evidence to be inconsistent and contradictory. Figures in the 2018 HELAA report suggest that there is available land from achievable sites for 565 new dwellings. This is a completely unrealistic expectation. If these are assessed against the suggested CDC figure of 30- 35 per hectare and 80% developable this gives a total of 360 - 420. The figures seem to be almost entirely based on projections put forward by promoters. Consequently, we were told to put a call out for additional sites. Several of those that have come forward are on sites previously rejected by CDC on the grounds of impact on the AONB, significant access constraints, adverse impact on the landscape and detachment from the settlement boundary.
The Sustainability Appraisal sets out to select numbers in the Potential Distribution Strategies. Assuming a figure of 650 pa, across Chichester District, the predicted numbers for Chidham & Hambrook stay within a narrow range of 500-750, whereas other Parishes fluctuate widely eg Fishbourne 250-1000, Hunston 0-1000.Unlike other parishes, it did not consider a figure of less than 500 for Hambrook.
The Strategic Development Location Assessments seek to assess each district against sustainability criteria. Chidham & Hambrook has been scored with 11 negative and 7 neutral with only 12 positive.
We agree with your judgements with the following additions:
1a in addition to the bat population North of Priors Leaze Lane the Ham Brook is home to water voles.
4b This is a significant constraint. Without adequate public transport and no local facilities or services this will put considerable strain on both the A259 and A27 at both Emsworth and Fishbourne.
5a There is considerable risk of surface water flooding on a number of identified sites.
6a This should be a negative score. To speculate that Southern Rail might increase the service is no justification for assuming a shift to sustainable transport. The hourly service east and west is not adequate for commuters.
9 This should be a negative. There are no local shops apart from a very small and poorly stocked Post Office, which has erratic opening hours, and a charity shop. This doesn't constitute some shops. There are no medical facilities, sports facilities or recreation ground.
10a-12b There are extremely limited employment opportunities in Chidham & Hambrook so difficult to see how any of these would apply.
13a The Local Plan diminishes our rural economy by taking farmland and nurseries for development
13b We have high quality Grade 1 and Grade 2 agricultural land .
We believe these judgements demonstrate that Chidham & Hambrook is less suitable for large scale housing numbers than other areas.


Policy S12 Infrastructure Provision
Infrastructure Delivery Plan
This gives us no confidence that the development of 500 homes in Chidham & Hambrook will give us the infrastructure we need at the time it is required.
Despite the rapid growth in housing numbers over the last five years there has been little infrastructure development. We have no medical centre, local convenience store, employment opportunities, early years or child care provision ,sports or recreational facilities.
Transport: there is no mention of any upgrades to any of the roads or junctions serving the Parish to alleviate congestion and to improve safety. There is no mention of cycling routes and walking provision to provide safe routes. This will be exacerbated by the 1,110+ homes proposed in the Southbourne Parish which will have a coalescent impact on Chidham & Hambrook, particularly Priors Lease Lane and Broad Road.
Education: the suggestion here is that Chidham & Hambrook will be contributing funding to a new school in Southbourne rather than a replacement school in Policy AL10. This represents yet another contradiction. It is unclear where or at which development Early Years and Child Care places would be accommodated.
Health: The nearest provision would be Southbourne

Policy S8 Employment
Object
7.1 Part Two Development Management states " place housing in locations which are accessible by public transport to jobs, shopping, leisure, education and health facilities."
There are limited employment opportunities in Chidham & Hambrook and it appears there is no demand for commercial premises in the area. Industrial units built by Taylor Wimpey on the Lion Park development were not taken up and consequently converted to housing. In the last few years three employment opportunities have closed down to be replaced by housing - two garages which sold, serviced and repaired vehicles, one of which sold petrol and a small stock of essentials, and a plant nursery. This will put an added pressure on traffic as more people drive to their areas of employment west or east using the A259. Public transport is limited and expensive.





Policy S23 Transport /DM8
Object
In Chidham & Hambrook the vast majority (80%) of the proposed new dwellings would be built off Broad Road and some sited on the adjoining Main Road, the A259. There is no provision for the road infrastructure impact of 2250 new homes along this road between Southbourne and Fishbourne. And this will impact the travel survey.
Currently Broad Road has significant safety issues for pedestrians, drivers and cyclists. There is limited visibility due to lack of off-road parking facilities for current residents which has resulted in a number of near accidents. Where it meets the A 259 there is a staggered junction with Cot Lane which, even at present, is difficult to negotiate. The combination of new housing leading to increased traffic in Broad Road and the potential significant volume of increased traffic coming from the 1100+ new dwellings in Southbourne will make this junction dangerous and untenable.
To the North of the Parish there will be increased traffic on the Common Road to Funtington and then the B2178 as a route into the city. Opportunities for any access to housing developments without using Broad Road or Main Road are extremely limited. All other roads in the Parish are essentially lanes, mostly restricted to single lane traffic and could not be used as access to developments.
Pedestrian access in Broad Road is very poor with footways in places too narrow to accommodate buggies, wheel chairs or motorised disabled scooters. As a consequence residents are heavily reliant on cars.

The added volume of traffic will cause significant congestion and decreased air quality. Accessing the A27 at Fishbourne will be further exacerbated by the lack of plans to introduce an additional junction and slip roads onto the A27 between Emsworth and Fishbourne, and for no right turns from the Stockbridge and Whyke roundabouts. The only suggested mitigation is to create a hamburger junction. The increased commuter traffic combined with beach traffic in good weather, will cause gridlock at this roundabout at every junction.
We object to the proposal to build a link road to Birdham which would go straight through a flood plain and a site of environmental significance and would have a negative impact on the views from the coast to the City and SDNP.
Public transport is limited to one bus service along the A259 and an hourly train in either direction from Nutbourne station. The bus is very expensive and the vast majority of passengers are those with bus passes. There is no bus service south to north. The train frequency is too limited as a viable alternative to car travel. We would like to see a more robust policy focussing on public transport links.

We support the 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 and be coordinated with WSCC with the goal of introducing high quality and separated cycle links between the villages along the A259 and Chichester.

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 along the A259 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 potential traffic problems





Policy S6 Affordable Housing
Support
There is a disproportionate number of detached and 4 bed houses currently in our housing stock. We would like to see a commitment for Social Housing in addition to Affordable Housing, which many local people cannot afford to rent or buy. This means many young people leave the area. There is too much flexibility given to developers here in delivering the housing need for the area. They must deliver their "affordable" requirement if sufficient housing to meet local needs is to be provided.

Policy DM 2 Housing Mix
Support
As above we have a high number of 4+ bed and detached homes. Young, low income and single households are being priced out of their neighbourhoods.

Policy DM3 Housing Density
Support
Specialist housing and housing for the elderly will require a lower density as it will be single story. It is essential that there are robust measures that will enable high quality homes to be built to enable elderly people to remain in their community should they need to move into adapted housing more appropriate to their needs. Similarly, life long homes for those with a disability who need specialist housing.

Policy S26 / DM19 Natural Environment
Object
The Spatial Vision and Strategic Objectives 3.6 states that any development west of the city will
" conserve and enhance the local distinctiveness, character and cohesion of existing settlements".
The Sustainability Appraisal states, in relation to Chidham and Hambrook " The scale of the development will completely alter the existing development and there will be significant impact to the existing historic village" These two statements are contradictory .
The magnitude of an additional 500 homes {growth of 55%) will patently alter the local distinctiveness and character of Chidham & Hambrook and risk coalescence with Southbourne. The landscape is characterised by extensive arable land with some nurseries and pasture. Hedges, bushes, orchards and groups of trees contribute to the landscape, as do streams which pass through the Parish. The South Downs National Park is to the North and the AONB of Chichester Harbour to the South.
The CDC Landscape Capability Study reinforces the detrimental effect development will have on the landscape and character in all areas within the Parish
Nutbourne East - Ham Brook Mosaic
Potential development is said to impact on:
valued views, visual corridor for views from Nutbourne Channel towards the SDNP, separation of Southbourne, Hambrook, Nutbourne East, the rural landscape setting, existing pattern of low density settlement.
It will also contribute to the loss of:
Pasture, arable fields, hedgerows, trees, woodland (ancient and semi natural) copses. The area is constrained by its remaining rural character.
Nutbourne West-Nutbourne East Coastal Plain
Potential development will impact on:
valued views, characteristics views to the harbour and the SDNP, views from the AONB and nearby peninsulas: wider separation between Nutbourne West and Nutbourne East, the rural landscape setting,of the AONB, the existing pattern of low density settlement, the well treed landscape setting.
It will also contribute to the loss of:
Pasture, arable fields, hedgerows, trees, woodland copses, characteristic landscape field patterns. The area is constrained by its rural and treed character which contributes to the open setting and character of the AONB.
Upper Chidham Coastal Plain
Potential development will impact on:
Valued views- to the harbour, hills of the SDNP, Bosham Church, setting of Nutbourne Channel and Bosham Harbour, setting of listed buildings, strong rural and tranquil character, views from the SDNP.
Contribute to the loss of:
Arable and paddock fields, hedgerows, trees, tree belts, patches of coastal grassland and wetland, characteristic landscape field patterns.
The area is constrained by its rural and tranquil character, the visually sensitive open large scale fields, its contribution to the open, rural setting of the settlements of Chidham, Nutbourne East and West and their wider separation and its contribution to the wider AONB landscape, including the setting of Nutbourne Channel and Bosham.
Nutbourne East North - Eastern Coastal Plain
Potential development will impact on:
Valued views, rural character, separation between Hambrook and Nutbourne East, semi enclosed and more open character,
Contribute to the loss of: pasture and arable fields, hedgerows, trees, and characteristic field patterns
Nutbourne East Nurseries
Potential development will impact on:
Valued views, characteristic views to the Harbour and SDNP, rural character, separation between Bosham and Nutbourne East, semi enclosed and more open character, the pockets of orchards and small copses.
Contribute to the loss of: pasture and arable fields, hedgerows, trees, and characteristic field patterns

There are clearly significant constraints on the landscape and character if large scale development were to take place in Chidham & Hambrook. The principles in the AONB Management Plan must be rigorously applied to any new developments.

Policy S29, S30, DM 32 Wildlife Corridor
Support
We welcome a specific Policy on wild life corridors located between the SDNP, the Chidham peninsula and Chichester Harbour. The Chidham / East Nutbourne wild life corridor linking important Green Infrastructure, is of special sensitivity.
A variety of species commute or forage between the harbour area and the SDNP including mammals, both deer and bats, of which 10 or more species have been recorded. Badgers, while not normally found on the peninsula, have been seen. Smaller species like Hedgehogs, stoats, weasel, moles, and small prey species, including tawny and barn owls, grey heron and migrant species such as Fieldfare and Redwing use these corridors .
The Ham Brook follows a natural environmental course from the AONB to the SDNP. This natural water course is home to water voles (seen by CDC Wildlife Officer and local environmental volunteers as recently
as January 2019) and the land north of Priors Leaze Lane is a Barn Owl Habitat.There is ancient woodland either side of the railway line next to the trout farm and this is a dormouse habitat too. Development in this area should be constrained by proximity to the wildlife corridor identified by CDC.




AL10/SA10 Chidham & Hambrook
Object
In 2014 at the last iteration of the Neighbourhood Plan there were 850 households in the Parish of Chidham and Hambrook. By the time the new Local Plan is published there will have been an increase in the number of properties in the region of 150 to a total of 1003 in the Parish, an 18% increase. The previous Local Plan had set a target increase of 25 houses. Whilst absorbing this number of properties there have been no changes to the infrastructure and services in the area to support the additional population apart from a charity shop and expansion of the Primary School which is now at capacity and has been for the last year. The new Local Plan requires us to accept a further minimum of 500 properties. This will increase our local housing stock by 50% and will undoubtedly increase the population area by a greater percentage given the age demographic of the area.
6.68 states that" opportunities to relocate and expand the school to two form entry will be sought.". We note that there are similar plans for a relocated and expanded school in Bosham with a site allocated for that purpose, in addition to a new school in Southbourne. Discussions with WSCC have made it clear they would not support the creation of two new schools in such close proximity. It is therefore nonsensical to suggest these two schools could be realised. WSCC data does not support it. Their calculations for schools are based on 210 Primary children for 1000 homes so patently 750 homes would not meet support for two 2 form entry schools. However, the current school is at capacity and cannot on its current site be expanded. If a school project is not forwarded in Chidham & Hambrook the additional children coming from 500 homes would need to travel to Bosham or Southbourne to attend school, along with children from 1100+ homes proposed in Southbourne. There needs to be some clarity and certainty on which of these proposed schools can be achieved and how they would be funded. We find it extraordinary that there is no policy statement on Education.


The Parish Council fully acknowledges that it has a responsibility to contribute to the need for more new housing in the District. However, in view of the above, and having carefully scrutinised the evidence, we believe that 500 homes for Chidham & Hambrook is excessive and is not supported by the documentation. The low provision of amenities, the absence of planned sustainable transport, the proximity of the AONB, the sensitive nature of the landscape and the density of housing proposed, limits the development capacity of the land.
For the reasons given we would like this number significantly reduced by at least 50% in line with Bosham and Fishbourne.

We fully support Policy 30, but object to the omission of a Wildlife Corridor directly along the route of the Ham Brook in Southbourne Parish. This would be in addition to the corridor identified east of Hambrook village. The evidence set out in the Council's own paper (Strategic Wildlife Corridors, Local Plan Review Background Paper, December 2018) demonstrates the importance of this additional area, including reference to identified water vole and bat networks, a considerable number of rare species sightings, and barn owl habitat. It has both over and under access across the A27 to the north and clear access beyond to the National Park. It meets Chichester Harbour at the Nutbourne Marshes Local Nature Reserve and adjoins the Nutbourne Mill Pond (SSSI) at its southern end, where we believe a Harbour Conservancy Management Programme is underway and a considerable number of rare species have been recorded. It meets all the criteria set out in paragraph 4.7 of the Background Paper and can be seen to provide at least as much wildlife habitat, if not more, as the selected "corridors".


This area is described as "West of Nutbourne" in the Background Paper. It was considered as an alternative to the "Proposed Chidham/East of Nutbourne Strategic Wildlife Corridor", and rejected (paragraph 5.5). The case for these corridors is well argued in the Paper and the fact that they will probably provide the only places where wildlife can pass safely from the National Park to Chichester and Pagham Harbours shows their importance. There are few places left where "corridors" can be identified and the opportunity to recognise the potential of the Ham Brook corridor and protect it should not be lost while we still have the chance.


Three reasons were given for its rejection in the background paper :-

1 The first was the proximity of residential areas. We dispute this because the survey material published in the Background Paper shows that despite proximity a significant number of wildlife sightings have been recorded sufficient for this are to be a candidate corridor.

2 The second is "proposed development". We can find no evidence that current building is a problem. The "Meadow View" housing site at Nutbourne is underway (HELAA - HSB0008). It provides considerable open space around the site including a buffer area alongside the Ham Brook. The developer has been made aware of the likely presence of water voles in the adjoining watercourse, and he has delayed management works until an ecologist can attend to supervise. "Proposed development" could refer to future development sites identified in Neighbourhood Plans. There are three other HELAA sites within this "corridor" area (HSB0012, HSB0009, and HSB0001) but it is far too early to suggest that any of them might be identified for development as a result of the review of the Southbourne Parish Neighbourhood Plan (SPNP). Even if any of them were, it would be possible to require the retention and management of appropriate gaps or buffers within such sites.

3 The last reason was that the "corridor" would be too narrow to act as a "suitable functional strategic corridor". There is no evidence to suggest that this is currently the case, nor likely to be in future.


We consider that none of these reasons are sufficient to justify the omission of the Ham Brook. It is one of the more significant watercourses in the area between Lumley and Fishbourne. All the other major watercourses in this area flowing from the Downs to the Harbour form the basis of a proposed wildlife corridor and it is inconsistent to exclude the Ham Brook.

INTRODUCTION - strategic and local importance of A27 improvement

The PC is concerned that the strategic context of the Plan, whilst making reference to the importance of the A27 trunk road, fails to realise the impact of the lack of the implementation of a scheme has on the future sustainability of new development proposed, let alone the completion of those proposed under the current plan.

Reliance on S106 and CIL contributions to mitigate, for instance increased traffic, will have little impact on alleviating the problem that the current A27 represents to communications and, importantly, the city of Chichester's future economic viability.

The plan makes little attempt to future proof Chichester and its hinterland with its continued reliance on relatively low paid employment in tourism, horticulture and areas such as retail.
The Coastal West Sussex and Gt Brighton Local Strategic Statement makes strong reference to the
Inter-relationship between the Bognor Regis northern bypass on the A259, the Arundel bypass and the A27 improvement at Chichester - the impact of these two schemes on Chichester, already apparent at the Bognor roundabout, could be catastrophic congestion.

Comments on Main policies.

S4 Meeting housing need

The Manhood Peninsula is expected to deliver 1993 units during the Plan period. Of this figure, 600 are in Selsey, East Wittering and Hunston, 175 as parish housing requirement in Birdham and North
Mundham. It is not clear what proportion of the residual 1208 fall into the category planning permissions, committed or made as of 2017 and what are expected to be small windfall sites.
Without this breakdown the potential impact on parishes such as Sidlesham, that are deemed unsustainable for housing, cannot be assessed. This is particularly important in Sidlesham where, due to prior consent approvals through the conversion of agricultural / horticultural buildings there is potential for 100 plus new units. This potential that would appear to be categorised as "windfall" obviously does not fit the definition, especially as to date (32 approvals in Sidlesham and Earnley), none are social housing but all are full market and some, costing £600k, are beyond any prospect of meeting the needs of first time buyers. The parish considers the majority of the conversions inappropriate and the potential scale of the number of conversions challenges the District's sustainability definition that is well founded for the parish. Whilst the Parish Council appreciates that the guiding legislation stands outside the local plan process, the potential distortion the developments, which are essentially on the ex Land Settlement Estate, needs to be specifically addressed in the local plan. Additionally, there are implications for policies S11 and DM15.

S6 Affordable Housing, DM4 Affordable Housing Exception Sites (S12 Infrastructure Provision)

The policy and supporting text gives too great a flexibility to developer, especially in terms of the economic viability of development. The renegotiation by developers of the proportion of social housing post original consent appears to have characterised many developments arising from the existing plan and consents that were granted prior to its approval. The fact that the plan seeks to control the artificial sub division of sites to avoid the social housing "trigger" gives a strong indication of many volume builders' reluctance to truly engage in meeting the true scope of overall housing demand. Whilst the hybrid of shared ownership meets a particular aspect of overall demand, it fails to address the increasing necessity of proper social housing. The true economic viability of sites needs rigorous independent assessment and, if not viable as market led development, the appropriateness of the site for development should be reassessed or its consideration for acquisition by, for instance, a community land trust scheme or compulsory purchase to provide social housing should be considered.

Policy S12 is welcomed, but the range of provision to be supported, especially if whole life costs are to be met will place great demands on funding streams such as S106, CIL and other funding streams and there must be doubt as to whether your council's Infrastructure Development Plan can be fully met.

S7 Gypsy and Travellers and Travelling Show People, DM5 Accommodation for Gypsies

It is noted that separate provision is required in the 5yr housing supply for this category. The eligibility for inclusion is that the individual still has an itinerant life style, ie travelling from place to place. Many of the gypsy families/individuals that seem to qualify under this category patently do not exhibit this form of life style. Local experience fully supports this position with gypsy communities simply using their caravan homes as a base to engage in trade, with the site often becoming the builders' type yard for the storage of materials or the waste from their trade. This form of occupation does not distinguish the use from any other individual living in an area and consequently should not qualify for any special recognition; in fact, in many cases such use under normal planning powers would be contrary to policy.

This "special treatment" causes a great deal of resentment in local communities especially where there is a social housing need - that is most areas - and where school places are under pressure.
The qualifying criteria must be fully investigated and a change in status over time reviewed as many sites, originally for itinerate use, simply become settled locations and do not therefore meet the criteria. It seems that the process from itinerant to settled status is a common progression and has the result of the "need" for new pitches continually increasing.

The substantial increase from the 2015 plan requirement to the 90 plus gypsy pitches now identified illustrates how the process is being used to bypass Planning that would restrict the provision of such "housing" if it were built development and that areas become favoured by gypsy communities as other gypsies are already located there and a sub community established. The criteria for assessment of eligibility must be reviewed together with the transition to settled status and additionally the degree to which concentrations of gypsy and other travellers are occurring in specific areas - this is considered to be the case in Sidlesham.

DM6 Accommodation for Agricultural Workers

The reintroduction of this qualifying criteria is welcomed. However, there is a major issue with enforcement and the policy needs to be strengthened to ensure the occupant continues to be employed in agriculture or horticulture. The change away from agricultural/horticultural occupation is often not declared and after the requisite elapse of time, ELD status is applied for. The need to register agricultural/horticultural occupation on an expiry time basis that would exclude qualification under ELD should be considered in the policy and/or the surrounding text. The subdivision of land and the separation of the original accommodation from the land is an increasing aspect of land holding in areas such as Sidlesham. On many sites an agricultural viability assessment is made as to whether a subdivided holding is viable and whether a constant presence on site is required to maintain the use and therefore accommodation required. However, this potential position should be a consideration at the original point of separation and a condition made that the subdivided land should not benefit from a subsequent consent for another house/residential caravan. This subdivision has and continues to be a trait on the ex LSA estate and, particularly within the HDA's, undermines their priority for horticultural production. At least in the HDA's the approval of agricultural worker accommodation should be restricted and perhaps limited to a residential caravan on a temporary consent and not lead to a progression to a permanent building as currently happens.

S11 Horticultural Need, DM15 Horticulture

There appears to be a weakening of the distinction between what in the 2015 Plan were termed
"hub" sites at Runcton and Tangmere and the other HDA sites in Sidlesham and Almodington.
Para 7.92 is particularly troubling ". It is not expected that large scale glasshouse development
(228,000 sq m required) will occur in Sidlesham and Almodington HDA's to the same extent as at
Runcton and Tangmere. The statement introduces doubt over the distinction between large scale industrial type of production and what is termed "market garden" horticulture expected at Sidlesham and Almodington.

The statement about "land adjacent to an HDA" previously related to Runcton and Tangmere. Its extension to Sidlesham and Almodington again introduces doubt over your council's true intentions about the scale of the industry envisaged outside the old hub sites and undermines the strong position it took on large scale such the Madestien proposal in Almodington. Your council stresses the importance of the HDA but continues to allow the break-up of the land within the smaller ones through conversion of buildings to residential and the take of land for gardens under "prior consent" as mentioned above. This approach is contrary to the proposed policy and will lead to further fragmentation and inefficient use of the land that remains. This approach could lead to requests for land outside the current smaller HDA's and bring glasshouse development into conflict with the overall environment. Many of the largest glasshouse developments are outside the HDA's but in established glasshouse areas and lead to the possibility that the HDA's need review and at least two new areas established based on the Fletchers Estate and Jakes Nursery and on Street End Lane. These area are equal or probably exceed production in many parts of the two HDA's.

S23 Transport and Accessibility

The strategic need for a solution to the A27 has already been mentioned but the impact locally cannot be overstressed in respect of the Manhood Peninsula. The high levels of out commuting for employment and many services are all dependent on a functioning A27 and further development in reality can only aggravate a non-functioning situation.

The cul-de-sac position of Selsey presents major problems for the town - the second largest in the district - in terms of emergency services and, for instance, the levels of congestion when heavy domestic traffic flows are combined with the summer tourist traffic that swells the population to approaching four to five times its winter levels. The sustainability of this situation in terms of environmental impact, the economic viability and overall acceptability must be doubtful. This is apparent to the road users but increasingly the areas that the road passes through, such as
Sidlesham, suffer pollution from exhaust emissions, noise, unacceptable delay in access from adjoining roads and properties, just simply crossing the road by pedestrians is made almost impossible as traffic is so often two way with no gaps. This situation cannot be ignored and just allow the road to be loaded with more traffic. The carrying capacity of the B2145 must be seen as a limiting factor in any future development in Selsey. This situation is mirrored on the A286 with The Witterings and Bracklesham.

It will be important that development in Selsey contributes to traffic management on the B2145 and that the whole of the road is eligible for any S106 and CIL contributions and not just the immediate locality of Selsey. The overall intention should be to improve safety, ensure speed is observed and allow safe road crossing. These factors will be considered within the Sidlesham Neighbourhood Plan.

Pollution is an increasing concern and in line with the Plan's policy objectives for greening of the environment, structural tree planting will be proposed within the B2145 corridor. The plan makes reference to sustainable transport but there are no specific proposals. It is suggested that for the Manhood Peninsula the proposed Greenway Selsey to Chichester is part of a specific policy that seeks to protect the adopted route and that Neighbourhood Plans for Hunston, Sidlesham and Selsey then adopt the route into their plans.

S24 Countryside, DM22 Development in the countryside, DM31 Trees, hedgerow and
woodland, DM29 Biodiversity

These policies and accompanying text is supported and will form the basis of Sidlesham's Neighbourhood Plan. Para 5.39 indicates conversions of existing buildings will be favourably considered where they lead to uses needed to support the rural economy and create 'rural affordable housing'. Currently, many conversions do not meet these criteria, especially the latter where often large upper market houses are developed way out of the range of meeting any local social need. The policy needs to reflect this problem with more specific criteria covering what is acceptable within the scope of any conversion.

The identity of the rural areas is an important consideration in maintaining their character if they are not to become just the spaces between larger settlements. This is particularly important on the
Manhood Peninsula and in the countryside associated with the transport corridors of the A286 and
B2145. The open countryside along these routes with their small settlements are in danger of encroachment by development and urbanisation. A specific policy is suggested to protect such areas and enhance their character by schemes of tree planting, improvement to the roadside environment and strong traffic management. Again, this approach will feature in the Neighbourhood Plan.
Whilst it is appreciated that agriculture is currently in a state of uncertainty, a policy that seeks to promote the balance between agricultural production, the environment and amenity would be welcome as a basis for whatever system of agricultural subsidy eventually is formulated. Particular emphasis should be placed on the protection of high grade agricultural land (grade 1 - 3a), biodiversity , and for instance structural tree planting for drainage and co2 reduction. A positive approach to recreational access in support of green tourism should also form part of a strengthened countryside policies.

S25 The Coast, S30 Strategic Wildlife Corridors

The policy makes reference to Chichester Harbour Management Plan but should also make reference to the Pagham Harbour Management Plan - although this currently only covers the period to 2018, the RSPB can be expected to bring forward a new plan for the next 5-10yr period.
The significant changes to the Pagham Spit over a relatively short period of time could have significant impact on the drainage of the harbour and particularly the surrounding land and including the R. Lavant flood relief channel. The importance of the Harbour's drainage function should be reflected in a specific policy that balances the significance of the habitat with the land drainage issues.

The Medmerry Scheme has created a significant change in the coastal geography creating a significant new coastal habitat extending westward from the margins of Pagham Harbour to within a short distance of the edge of Chichester Harbour AONB. An important corridor for wildlife is developing over the short distance between the two and should be considered as a designated area under policy S30.

S27 Flood Risk Management

The plan makes reference to flood risk but does not fully realise its significance to the Manhood
Peninsula and the constraints it places on development, the future of its economy and the resilience of its communities.

Whilst SUDS has its uses in localised drainage it often simply drains an area into a downstream network that has to cope with the additional run off. The Peninsula has an extremely high water table for the majority of the year that makes most soakaway drainage ineffective. An integrated network utilising the existing ditch system and augmenting this with attenuation areas with good clear outlets to the sea must be developed and maintained.

Many new housing developments rely on SUDS but simply only cover the development site. Developers have to be responsible for the water they produce from the point of generation to its disposal to the sea or main river. This should form a requirement of any planning agreement and a policy within the plan should reflect and formalise this responsibility. Realisation of the true infrastructure cost of drainage should be fully reflected in the site evaluation process and its economic viability. The development of many coastal locations or those on flood plain may be proven uneconomic if the real cost for drainage were realised and not the passing on of the problem
downstream as currently occurs.

Reference is made to Surface Water Management Plans. It is the responsibility of the lead strategic flood authority (in this case WSCC) to produce and maintain these plans. As a material consideration there should be policy and text to ensure the plans are kept up to date and that priorities identified in plans are brought forward for action and funding such as CIL directed to their implementation.

S31 Wastewater Management and Water Quality

Southern Water needs to have information on future demand foul drainage - detailed discussions with SW have shown that the levels of development known to them, especially in respect of
Sidlesham Waste Water Treatment Works, do not appear to reflect the development levels and question the capacity of the facility. Additionally, the size and overall functioning of the pipe network is very troublesome, for example, the "trunk main" from the Witterings. It would appear that calculations are primarily based on dry flow rates where much of the pre 1960's housing on the
Peninsula has mixed drainage and the foul system suffers from ground water inundation. The Parish requests that a clear reappraisal of the wastewater capacity of SWWTW and of the network is made and the infrastructure costs of a system that has the required headroom and a network that will support existing and any new development is made and factored into the plan.

DM35 Equestrian Development

The parish is concerned about the high level of horse related development that is occurring on the
Peninsula, especially on the settlement boundary margins, within the ex LSA estates, and associated with gypsy sites. Much of this development is often deemed as "agricultural use" when it is really a "change of use" as the livestock are not supported by grazing of the land. The use for "horse culture" often removes high quality land form agricultural/ horticultural use, despoils the land creating a strong visual intrusion often close to residential areas. The Plan policy should ensure that the change of use is properly applied and enforced. Clarity should also be sought as to the true recreational nature of much of the horse keeping and as there is no bridleway network on the Peninsula how often large numbers of horses kept on a small acreage might be exercised.

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.

The trustees of the Friends of Pagham Harbour (a registered charity) met yesterday to discuss the Chichester Local Plan. We wish to make the following points:

* We support to proposal for wildlife corridors. We have been strong proponents of the Pagham Rife wildlife corridor which stretches from Pagham Harbour to Chichester.
* We are concerned about the impacts additional housing will have on existing infrastructure, particularly the sewage system. During the winter months Pagham Harbour suffers several sewage spills per week into the Pagham Rife due to storm surges and this will only increase should further housing be built. Furthermore, other seage treatment plants that discharge into rifes which flow into Pagham Harbour will be similarly affected.
* We are struggling to understand why the buffer zone around Pagham Harbour is smaller than that around Chichester Harbour.
* We are concerned about the increased traffic on the Chichester-Selsey road (B2145). This road has to be crossed by those walking or cycling from Pagham Harbour to Medmerry and expect more accidents will happen unless better crossing facilities are provided.

The Chichester Wildfowlers' Association supports the proposal for a policy on Strategic Wildlife Corridors.

http://www.chichester.gov.uk/CHttpHandler.ashx?id=31016

A number of our members work on the land and have observed the wildlife potential of these areas. Much of the success of these areas is due to farming practices. The continuing success of these wildlife corridors will depend on working with farmers, landowners, the Environment Agency, users and other stakeholders to ensure sympathetic and acceptable management.

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

Stockbridge Level Crossing
LPC rejects the proposal as outlined simply because it lacks any substance. The issue is outlined in section 4.95 and 5.19. We find the proposed solution as detailed in section 7 of policy AL5 "......, restrict vehicular traffic using the Stockbridge Road level crossing" as insufficient, lacking in any detail to give it any credence. This is a wish, not a policy.

A27.
1. LPC is deeply disappointed that the only improvements envisaged for the A27 are to mitigate the increased traffic from new developments.
2. Given the regrettable loss of the HE 2b proposal, this limited in scope (compared with what was on offer), proposal as outlined in S23 is supported in full.
3. The lack of clarity on costs and source of funds is regrettable. LPC understands that the proposal will cost at least £60Million, sourced from developer contributions. This represents a threefold increase, from the original £20Million from WSCC & CDC in the HE 2b proposal. Clearly other important infrastructure projects will have to be abandoned, how many schools, Doctors' surgeries, elderly people facilities etc will not be built? This has to be made clear, if the community is to support this level self-funding for the roads.

Southern Gateway
The proposal as outlined is a 20th century concept; we live in the 21st Century. High Street retail is in retreat, any proposed increase in retail floor space will be very difficult to fund, and even harder to let. Major chains are in retreat, all predictions are for a major contraction of High Street retailers. This is a flawed plan and must be re-thought as it is simply is undeliverable.

DM8
We would wish to emphasise the importance of established cycle routes, especially
Centurion Way, and the absolute necessity of their upkeep and development in accordance
with NICE guidelines.

NB The overall local transport plan requires a greater focus on increased public transport
plus pedestrian and cycle routes.

S23

In relation to bullet points 8 and 9, we would wish to reiterate the importance of established
cycle routes, especially Centurion Way and the Canal route, and the absolute necessity of
their upkeep and development in accordance with NICE guidelines, and would urge further
development of networked cycle routes

S30

We endorse the overall thrust of the policy but the absolute necessity of applying the
guidelines at 5.67 cannot be stated too often and too strongly.

S22
Heritage assets should also include all historic routes be they pedestrian, cycle, or
vehicular (eg Stane Street, Centurion Way, and 'twittens').

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