8.1

In recent years the local public transport has failed to adequately support the strategic transport network. For example the local bus services have declined in terms of routes, service hours and frequency. Several bus services now do not run after 6pm and do not even reach the Chichester train station. For many shool, working and commuting people local public transport is now near useless. Your plan should address this.
The emphasis on private car use is misguided, for local transport.

Chapter 8 should make reference to the role of aviation in transportation. The NPPF (paragraph 106f) requires local planning policies to: “recognise the importance of maintaining a national network of general aviation airfields, and their need to adapt and change over time – taking into account their economic value in serving business, leisure, training and emergency service needs, and the Government’s General Aviation Strategy.”

Chapter 8 should make reference to the role of aviation in transportation. The NPPF (paragraph 106f) requires local planning policies to: “recognise the importance of maintaining a national network of general aviation airfields, and their need to adapt and change over time – taking into account their economic value in serving business, leisure, training and emergency service needs, and the Government’s General Aviation Strategy.” The plan does not make such references and is therefore not compliant with the NPPF and consequently is unsound.

Goodwood Aerodrome is a general aviation airfield.

Moreover, the plan should make provision for how aviation is likely to change in the future, with technological advances, not only in terms of being more accessible to the public for sport and recreation, but also the impact of STEM activities and their important role in future aviation and the advance of drone and similar technologies. Goodwood Airfield is closely and actively engaged with developers of such technology and this is likely to become an increasing sector of the Estate’s business.

General aviation airfields, such as Goodwood, frequently have sufficient land available for new aviation-related facilities (unlike constrained commercial airfields) and provide a major infrastructure resource. Unfortunately, this benefit is often overlooked in planning policies, and many airfields are subjected to threats of redevelopment – for reasons of viability fuelled by a high demand for housing land- and increasing resistance to developments supporting aerodrome business (such as potential noise and disturbance to adjoining residential areas)

Local political reaction to activities at many general aviation airfields has led to the introduction of restrictive planning policies, many related to noise and disturbance and a fear of expansion. Goodwood airfield is no exception, but it has worked with the local community over many years to reach an operational position that provides a balance between continued operation and protection of local amenities. Unfortunately in recent years, particularly as a result of an ill-founded strategic development allocation in the previous local plan, that operational balance is coming under further strain and cannot be further adjusted.

A position is fast approaching where operations at the airfield and motor circuit could be compromised unacceptably by the encroachment of new development, in particular housing development. This was ably demonstrated by the speculative housing proposal north of Madgwick Lane to which both the Estate and planning authority objected for reason, amongst many others, potential noise disturbance, safety concerns and operational constraints which contributed to an unacceptable ‘agent of change’ situation.

The proposal was subject to public inquiry and a finely balanced decision was granted in favour of development by the inspector for reason of the benefits of new housing outweighing the potential harm to Goodwood operations, on grounds that the (unproven) mitigation offered by the developer will be both provided and be effective, and we suggest, a misunderstanding of the true impacts of existing operations.

The Estate will continue to oppose the development for sound planning reasons that the mitigation offered and based on inaccurate evidence, will be inadequate and ineffective in addressing the concerns raise by the Estate and planning authority.

In order to remedy this issue regarding the Terminus Road Diversion, the County Council requests that feasibility work is undertaken prior to the examination to confirm deliverability of the proposed Terminus Road Diversion.

The comments included below from WSCC are Holding Objections. We will continue to work with Chichester District Council and as further work is completed will consider if objections can be withdrawn.

Transport Overview
The County Council has worked with Chichester District Council to develop the Chichester Local Plan and its supporting evidence base and will continue to do so. Although the overall direction of the Local Plan is supported, from a highways and transport perspective, there are three key issues remaining that need to be addressed in order to demonstrate that the Plan is sound:

1. There is insufficient evidence to demonstrate that key infrastructure (i.e. Terminus Road Diversion) will be deliverable;
2. The package of sustainable transport infrastructure and measures is not yet sufficiently well-developed to demonstrate that it is deliverable as part of the monitor and manage process; and
3. There is insufficient evidence to demonstrate that the capacity of the transport network can accommodate the scale of development proposed as part of the Southbourne Broad Location for Development.
The following sections explain; a) the reasons for these issues; b) why they affect the soundness of the Local Plan; and, c) what changes should be made to the Local Plan to remedy the issues.

Deliverability of Key Infrastructure

The recommended transport mitigation strategy, as assessed using the Chichester Area Transport Model for 2039 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, there are significant risks to deliverability of junction mitigation measures, which have required further work to be undertaken on developing a short to medium term strategy based on phased prioritisation of infrastructure and sustainable transport improvements, to be governed under a monitor and manage approach.

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 the likely value of developer contributions and additional funding has not yet been secured.

At the Regulation 18 consultation stage in December 2018 to January 2019 the County Council identified delivery risks with the Stockbridge Link Road and Terminus Road Diversion schemes due to the earthworks likely to be required and to confirm the extent of land take required for both schemes. The County Council stated that feasibility work would need to be undertaken for these improvements prior to Plan submission to confirm that the schemes are deliverable. A brief for such a feasibility study was agreed in 2019, but to date, this work has not been commissioned. It is the County Council’s view that Stockbridge Link Road (SLR) should be disregarded as a potential part of a long-term transport mitigation strategy for 2039 and beyond until such time as it can be demonstrated that the scheme is deliverable. Paragraph 8.14 of the Local Plan acknowledges that the SLR is not deliverable as part of the Local Plan mitigation package.

The Terminus Road Diversion is still identified as part of the highest priority in the Local Plan mitigation package (i.e. A27 Fishbourne Junction) which is expected to be delivered once sufficient funding is collected. The County Council considers that in the absence of this feasibility work, the deliverability of the Terminus Road Diversion cannot be confirmed. In particular, given the recent impacts of inflation in the construction industry, this work will need to robustly estimate the costs and confirm delivery arrangements. In the absence of this feasibility work, there is currently insufficient evidence to confirm that the Local Plan complies with Paragraphs 11 and 106 of the NPPF as key infrastructure does not appear to be deliverable.

In order to remedy this issue regarding the Terminus Road Diversion, the County Council requests that feasibility work is undertaken prior to the examination to confirm deliverability of the proposed Terminus Road Diversion.

Sustainable Transport Infrastructure & Measures

The transport study modelling for end of Plan period also includes some proposed highways mitigation schemes within Chichester City. The County Council has previously requested that these be replaced by sustainable transport improvements to comply with the West Sussex Transport Plan 2022-2036. However, only limited modification has been made to these proposed schemes, with a suggestion in text at paragraph 7.3.2 of the main transport study that the costs for these schemes can be reallocated to sustainable transport improvements which are not specified. Although this does help to explain how sustainable transport infrastructure schemes and measures can be at least partially funded, it is rare that schemes will be fully funded using developer contributions. Furthermore, funding is not the only issue that needs to be overcome to secure delivery of these schemes and measures.

The Infrastructure Delivery Plan (IDP) lists the proposed mitigation measures and in some cases provides information on the rationale, phasing, cost, funding and delivery arrangements. However, there are still many gaps in the information, probably because schemes are currently at an early conceptual stage. The County Council’s experience is that it is unlikely that schemes will be fully funded using developer contributions (because doing so would not be compliant with the CIL regulations) so delivery of these schemes will be partially dependent on securing funding from central Government or other sources. The IDP currently fails to identify the scheme-specific requirements for additional funding and the overall scale of additional funding required.

The County Council considers the level of information currently available on the sustainable transport package to be insufficient to demonstrate deliverability of a credible and coordinated sustainable transport package of improved infrastructure and services. Therefore, there is insufficient evidence to confirm that the Local Plan complies with Paragraphs 11 and 106 of the NPPF.

In order to remedy this issue, the County Council requests that further technical work is undertaken to develop the schemes and measures in the sustainable transport package prior to the examination. In particular, this should focus on the following schemes and measures and some cases, this will build on work that has already taken place:
1. St. Paul’s & Parklands cycle routes
2. Improving existing public transport services towards Madgwick Lane
3. Provision of improved bus services for the village serving the development areas of Southbourne Parish
4. Improving cycling connectivity to link the built-out areas of Shopwhyke Lakes with Tangmere and Oving etc

As not all the severely impacted A27 junctions have a reasonable prospect of being physically improved in the Plan period, more investigation into potential public transport enhancements is also required, particularly to strengthen routes that cross the bypass. This may require further amendments to the IDP.

This work should aim to identify options for sustainable transport schemes that can be a priority for investment, provide information to enable safeguarding of routes (e.g. cycle routes) from development and provide a basis for applications for third party funding to support their delivery. The relative priority of such measures would need to be considered under the monitor and manage approach by the proposed Traffic and Infrastructure Management Group for implementation in addition to the proposed improvement at the A27/A259 Fishbourne junction.

To address this issue and support delivery of the sustainable transport package, the County Council also recommends the following minor amendments to Policy T1: Transport Infrastructure:

At bullet point .7 change “other small-scale junction improvements” to read “other sustainable transport and safety focused improvements, including at junctions” and change “These will increase road capacity, reduce traffic congestion, improve safety and air quality, and improve access to Chichester city from surrounding areas” to “These will increase road capacity on strategic roads, and on both strategic and local roads reduce traffic congestion, improve safety and air quality, and improve access to Chichester city from surrounding areas notably by encouraging and prioritising sustainable modes.”

Southbourne Broad Location for Development

The scale of development that can be accommodated at the Southbourne Broad Location will be, at least partially, dependent on the capacity of the transport network to accommodate the associated traffic movements. As the Broad Location spans the railway line, many of these traffic movements would need to cross the railway line. The County Council is concerned that there is currently insufficient capacity of the existing level crossings, notably at Stein Road, to accommodate the additional traffic movements. This could mean that the cumulative impact of development on the traffic network is severe, which is not consistent with Paragraph 111 of the NPPF.

The transport evidence base does not yet provide sufficient assurance that the proposed scale of development can be accommodated. This is because the base level of traffic flow has not been compared to local traffic counts, either in the initial validation of the strategic model or through a new count which the County Council has previously requested, and the assumptions about level crossing downtimes have not been validated against observed data. The County Council is concerned that the assessment of capacity of the local road network to accommodate the quantum of dwellings proposed for the Broad Location may be overoptimistic by underestimating existing flow levels and the duration of level crossing downtime. As a consequence, the proposed quantum may not be deliverable without unacceptable impacts to the conditions on Stein Road and to the level of traffic seeking to use rural lanes to the north of the village to avoid the level crossing.

In order to remedy this issue, the County Council requests that either additional transport evidence is provided prior to the examination to demonstrate that the proposed scale of development is deliverable, or that Policy A13 is changed to remove the proposed scale of development until such evidence is provided.

The following comments from education, minerals and waste, Adults Services and Health, highways & transport and public rights of way, do not affect the soundness of the Plan. However, Chichester District Council should take these into account and, where possible, make minor amendments to the Local Plan and/or evidence base studies before submission of the Local Plan for examination. Officers are happy to meet and discuss any of these comments, and proposed minor amendments to address these comments, ahead of submission:

1) Education

Land West of Chichester

Previous comments have been made requesting that the policy refers to ‘Phase 2 should include expansion of the primary school for the further 1FE of teaching accommodation with nursery and SEND provision’. While it is recognised that reference is made to this in the IDP this is a supporting document to the Local Plan and should not be solely relied on. It is requested that paragraph 10.19 is amended to read: ‘a local centre with retail, community and employment uses (minimum of approximately 2500 sqm E(g)(i) Use Class), two form entry (2FE) primary school and one form entry (1FE) teaching accommodation with nursery and SEND, informal and formal open space (including a country park), allotments,…’

This should also be included in the 3rd bullet point of Policy A6 or the wording of the policy should be drafted to reflect more recent policy requirements i.e. Provide for infrastructure and community facilities in accordance with the most recent Infrastructure Delivery Plan.

There are some inconsistencies with the wording of the strategic policies, not every policy includes the criterion ‘Provide for infrastructure and community facilities in accordance with the most recent Infrastructure Delivery Plan.’ While this may be due to some policies being carried through from the adopted local plan it is inconsistent.

Policy A8 Land East of Chichester

As an education authority WSCC do not request 1FE schools in line with government guidance. As per our earlier comments and discussions we requested a 2 FE primary school for the site.

3rd bullet point of Policy A8 should be amended to read: ‘A neighbourhood centre incorporating local shops, a community centre, flexible space for employment/ small-scale leisure uses and a one-form (expandable to two-form) two form entry primary school with provision for early years/ childcare and special educational needs and disability…’

2) Minerals and Waste

The references to safeguarding minerals is inconsistent and it is suggested that the wording in the email sent to CDC (attached) in relation to Policy AL3 should be used in the policies for the other sites for consistency. Reference to safeguarding minerals and waste infrastructure should also be included in some other policies as previously indicated:

• Policy A2 – needs to include reference to safeguarding minerals and waste infrastructure.
• Policy A7 – needs to include reference to safeguarding waste infrastructure.
• Policy A15 (Loxwood) – needs to include reference to minerals safeguarding as within the clay MSA.
• Policy A21 – needs to include reference to minerals safeguarding.

Also, the reference to the safeguarding guidance needs to be checked to ensure that it is worded correctly as ‘Minerals and Waste Safeguarding Guidance’.

3) Older Person Housing

It is noted that the plan refers to older person housing as specialist housing. WSCC strategy supports the provision of ‘extra care housing’ while this might be similar development it enables younger people to access the accommodation for whatever medical reason i.e. MS, strokes rather than limiting it to a certain age group. Officers are happy to meet and discuss this further.

4) Highways and Transport

Public Transport Priority Infrastructure

The Public Transport section of the main transport study report starting at paragraph 6.2.7 requires revisiting. There is reference to “an expansion of the bus priority lane system within Chichester City Centre” which does not match the existing bus provision in the City which does not provide bus priority lanes on street. It does have restrictions on motor traffic in the adjoining parts of South Street and West Street which provide for bus and cycle only access in both directions of travel plus access for essential goods vehicle loading in the westbound direction only. In addition, the suggestion in the following paragraph for “a time-based system where certain routes are restricted to public transport only during specific times” is not evidenced or developed and as such considered unlikely to be practical and enforceable at most locations used by bus routes in the City. More developed proposals for additional bus priority, improvements to bus passenger facilities or testing of specific locations for bus-only access would be welcomed as part of developing a costed sustainable transport mitigation package.

Park and Ride

The discussion of possible park and ride facilities for the City at paragraphs 6.2.9 to 6.2.16 of the main transport study should also acknowledge. An important part of making park and ride well used by motorists is increasing the price of city centre parking to provide a financial incentive to take up significantly cheaper park and ride charges for parking and travel. However, if park and ride sites are not provided accessible to all major approach routes to the city, such a charging strategy would not be seen to be equitable, whereas only a single site is proposed in the District Council’s emerging parking strategy and the report acknowledges at 6.2.11 that “locations for potential park and ride sites are also deemed to be limited”. The bullet at 6.2.15 “Cost of schemes compared to benefit are likely to be initially lower than highway schemes” may have been incorrectly worded given that this is listed as an issue rather than a benefit. The text may have been intended to say that the ratio of benefit to cost for park and ride schemes may be lower than for conventional highway schemes?

A286 New Park Road / A286 St Pancras Road (Junction 7)
This junction scheme includes pedestrian crossing facilities which are welcomed and also includes a length of advisory cycle lane starting in the middle of the junction for cyclists remaining on St Pancras. However, the approach to the junction on St Pancras from Eastgate Square remains intimidating to cyclists, so further measures would need to be added to make the layout cycle-friendly or the cycle facility is likely to be of limited benefit. This could include decreasing traffic speeds. Until this is done the conclusion at 8.4.4 of the main transport study; “The mitigation scheme includes improvements for pedestrians and cyclists which will lead to increased use of active travel modes and reduce the need for physical mitigation here” is only supported for pedestrians, not for cyclists.

A259 Via Ravenna / A259 Cathedral Way Roundabout (Junction 8)
It is stated at 7.3.8 of the main transport study that “the mitigation may be required to avoid queuing back towards the A27, as well as for capacity issues”. In light of this potential safety issue for the previous junction on Cathedral Way and for the A27 Fishbourne junction, the proposal at 7.3.6 that the scheme delivery should be tied to the monitor and manage regime to see if and when it is required is accepted. This is different to the approach for other junctions in the City because of the potential safety issue. This monitoring approach would be likely to follow after the A259 Cathedral Way / Fishbourne Road East / Terminus Road (as diverted) (Junction 10) improvement, which is to be brought forward as an integral part of the A27 Fishbourne roundabout mitigation scheme, but may allow for increased eastbound flows on Cathedral Way.

A286 Northgate Gyratory
An additional mitigation scheme is proposed at paragraph 7.3.134 of the main transport study for the A286 Northgate Gyratory along its southern arm from Oaklands Way to Orchard Street. The proposal to add traffic signals is welcomed in concept as it can help to control traffic speeds making the junction more friendly for cyclists and pedestrians. However, the layout shown at figure 7-8 does not maximise the opportunity to improve convenience and safety for pedestrians by providing a priority link to reach the central island, which contains employment space and the fire station, nor to assist crossing the exit towards Orchard Street. The scheme would benefit from further development to prioritise active travel movements and should also be fitted with transponders for bus priority.

Fishbourne Road West / Appledram Lane South (Junction 11)
At paragraphs 7.4.1 to 7.4.2 of the main transport study, the junction of Fishbourne Road West / Appledram Lane South (Junction 11) is considered. The proposal to mitigate impacts at this junction through delivery of the Stockbridge Link Road scheme is not considered deliverable, so the approach at this location requires re-thinking. The County Council would not support measures to increase capacity for through traffic on Appledram Lane South, the approach should be to reduce severance and improve safety and comfort for active travel on Appledram Lane by reducing vehicle speeds and as far as possible volume. This should consider the needs of pedestrians and cyclists both for local access and for users of the Salterns Way leisure cycling route.

TEMPro Background Traffic Growth Comparisons
At section 10.2 of the main transport study a comparison is made of the TEMPro 7.2 growth rates used in the study for external traffic with new TEMPro 8.0 growth rates since released by the Department for Transport, which notes that the TEMPro 8.0 rates are significantly lower, if these rates were used then the level of transport impacts could be lower. Unfortunately, a number of highways authorities in the Transport for the South East (TfSE) area including the County Council and Hampshire County Council have concerns that the planning assumptions used in TEMPro v8 core growth scenario underestimate the numbers of additional households forecasted compared to targets in adopted Local Plans for delivering new dwellings. TfSE are currently raising these collective concerns with DfT with a view to obtaining an early update to TEMPro 8 planning assumptions. Although for the purposes of this study TEMPro is not applied to trips produced in Chichester District, from the County Council’s analysis TEMPRo v8 core underestimates the increase in households per year in Arun District by over 50% and in Horsham District by 30% when compared with adopted development plans. On this basis it may be useful to instead compare TEMPro 7.2 with TEMPro 8.0 high growth scenario.

North of District Spatial Scenarios Testing
For the Northern Spatial Scenarios Test provided as an appendix to the main transport study, this had not been updated for the final preferred spatial strategy or in light of the County Council’s previous comments on the March 2022 issue to the District Council. The spatial strategy now is similar but not identical to the Scenario 4: Significant Growth 1 option in the reported tests, totalling 370 dwellings across the four northern parishes, compared to 410 in the test. In both cases the largest allocation is at Loxwood; 220 dwellings were proposed in the Scenario 4 as compared to 200 in this test. Some other tests proposed higher numbers.
The testing in the northern part of the district had used the same trip generation rates per dwelling as in the South of the District, but the County Council considers that in practice private motor vehicle trip generation per dwelling is likely to be higher due to the rural nature of the area, including a lack of local facilities and shops within walking distance of development, a very low level of public transport services and lack of surfaced cycle routes.
The level of development proposed is not at the level capable of delivering transformative transport improvements to match the trip making patterns around Chichester and the A259 corridor to Bosham and Southbourne. This may be offset in part by the lower total amount of development compared to the tested scenario 4. Nonetheless, it would be helpful to adjust the scenario for the spatial strategy now proposed and to provide information on additional traffic movements per peak hour from these parishes using the A272 at junctions at Wisborough Green and reaching the A272/A29 junction at Billingshurst and the A272/A283 junction at the north of Petworth.

Neutral Month and Summer Month Comparison Technical Note
The Neutral Month and Summer Month Comparison Technical Note in the main transport study treats July as a neutral month rather than a summer month. Paragraph 1.3.1 states “The flows were analysed by looking at traffic data for August 2019 this being considered to represent summer traffic. This was compared against traffic data from the neutral months of June, July, September and October also from 2019.” The County Council does not accept this methodology as school summer holidays start part way through July and education traffic is also affected by the formal exam period, whilst there is typically a high level of seasonal leisure traffic including summer outdoor events in this month. It is acceptable to use August alone as the summer comparator month. However, July traffic should be removed from the neutral months analysis and should be substituted with May traffic data from the same year of 2019, provided that sufficient data is available from that month.

5) Public Rights of Way (PRoW)

It is a positive step to see PRoW acknowledged as valued by communities and as part of the area’s green infrastructure. Whilst Policy P14 (Green Infrastructure) states that development proposals should not be detrimental to the network of public rights of way and bridleways (please note bridleways are Public Rights of Way), a more proactively positive approach that seeks enhancements to the network as mitigation, would be welcomed. The improvement, upgrading of existing PRoW and creation of new PRoW where possible, to allow for a greater number of users to access the network would be beneficial. This is somewhat addressed in Policy T1 which refers only to routes identified in the Local Transport Plan, Local Cycling and Walking Infrastructure Plan (LCWIP) and the Infrastructure Delivery Plan. Opportunities to these, should not be limited if they arise elsewhere.
It is surprising to see there is no mention of PRoW within Chapter 8 under Active Travel – Walking and Cycling. The PRoW network provides extensive walking and cycling opportunities, often off-road, and important links between places and non-PRoW routes.

Executive Summary

The Local Plan as written lacks ambition and vision, and will be detrimental to the landscape within which the district lies. It is a plan borne out of a need to produce a legal document which will satisfy the regulatory authorities. In terms of Urban Planning it fails “To meet the needs of the present without compromising the ability of future generations to meet their own needs” (NPPF).

The development that will consequentially arise from the deployment of such a made Local Plan is not sustainable. It will adversely affect the Character, Amenity and Safety of the built environment, throughout our district.

In particular, the Local Plan is inadequate for the needs of the people in the district both at present and in the future because –

1. It has been written in advance of the District having a properly formed and agreed Climate Emergency Action Plan. It is inconceivable that such a key document will not shape our Local Plan. It is this Action Plan that is needed first in order to provide the long-term strategic view as to how and what the District will look like in the future; this, in turn, will help form and shape the policies outlined in any prospective, Local Plan. The Plan as proposed is moribund, as a result of “cart before the horse” thinking.

2. The Local Plan as written does not adequately address how infrastructure, transport and services are going to be materially and strategically improved to meet the predicted growth and shift to a significantly ageing population. There is presently insufficient capacity to supply services and to have adequate people and environmentally friendly connectivity, as a direct result of decades of neglect towards investing in infrastructure and services to meet the needs of the District’s population. We are led to believe that developers through increased levies in order to gain permission to build will fulfil this need, but all that this will result in is an uncoordinated, dysfunctional mess completely lacking in any future-proof master planning approach. We contend that this will do nothing for the quality of life of Chichester District residents and it will create a vacuum whereby few if indeed any can be held accountable or indeed found liable for shortcomings in the future.

3. The Local Plan as written does not state how it will go about addressing the need to create affordable homes. The District Council’s record on this matter since the last made plan has been inadequate and now the creation of affordable homes has become urgent as political/economic/social factors drive an ever increasing rate of change within the District.

4. Flood risks assessments used in forming the Plan are out of date (last completed in 2018) and any decision to allocate sites is contrary to Environment Agency policy. Additionally, since March 2021 Natural England established a position in relationship to ‘Hold the Line’ vs. ‘Managed Retreat’ in environmentally sensitive areas, of which the Chichester Harbour AONB is a significant example. CDC have failed to set out an appropriate policy within the proposed Local Plan that addresses this requirement.

5. The A27 needs significant investment in order to yield significant benefits for those travelling through the East-West corridor; this is unfunded. Essential improvements to the A27 are key to the success of any Local Plan particularly as the city’s ambitions are to expand significantly in the next two decades. But any ambitions will fall flat if the A27 is not improved before such plans are implemented.. The A259 is an increasingly dangerous so-called ‘resilient road’ with a significant increase in accidents and fatalities in recent years. In 2011, the BBC named the road as the “most crash prone A road” in the UK. There is nothing in the Local Plan that addresses this issue. There is no capacity within the strategic road network serving our district to accommodate the increase in housing planned, and the Local Plan does not guarantee it.

6. There is insufficient wastewater treatment capacity in the District to support the current houses let alone more. The tankering of wastewater from recent developments that Southern Water has not been able to connect to their network and in recent months the required emergency use of tankers to pump out overflowing sewers within our City/District reflects the gross weakness of short-termism dominated thinking at its worst and is an indictment of how broken our water system is. The provision of wastewater treatment is absolutely critical and essential to the well-being of all our residents and the long-term safety of our built environment. The abdication by those in authority, whether that be nationally, regionally or locally, is causing serious harm to the people to whom those in power owe a duty of care and their lack of urgency in dealing properly with this issue is seriously jeopardizing the environment in which we and all wildlife co-exist.

7. Settlement Boundaries should be left to the determination of Parish Councils to make and nobody else. The proposed policy outlined in the Local Plan to allow development on plots of land adjacent to existing settlement boundaries is ill-conceived and will lead to coalescence which is in contradiction of Policy NE3.

8. All the sites allocated in the Strategic Area Based Policies appear to be in the majority of cases Greenfield Sites. The plan makes little, if any reference to the development of Brownfield sites. In fact, there is not a Policy that relates to this source of land within the Local Plan as proposed. Whilst in the 2021 HELAA Report sites identified as being suitable for development in the District as being Brownfield sites were predicted to yield over 4000 new dwellings. Why would our Local Plan not seek to develop these sites ahead of Greenfield sites?

9. The Local Plan does not define the minimum size that a wildlife corridor should be in width. What does close proximity to a wildlife corridor mean? How can you have a policy (NE 4) that suggests you can have development within a wildlife corridor? These exceptions need to have clear measures and accountability for providing evidence of no adverse impact on the wildlife corridor where a development is proposed. Our view is quite clear. Wildlife and indeed nature in the UK is under serious and in the case of far too many species, potentially terminal threat. Natural England has suggested that a Wildlife Corridor should not be less than 100metres wide. The proposed Wildlife Corridors agreed to by CDC must be enlarged and fully protected from any development. This is essential and urgent for those Wildlife Corridors which allow wildlife to achieve essential connectivity between the Chichester Harbour AONB and the South Downs National Park.

10. Biodiversity Policy NE5 - This is an absolute nonsense. If biodiversity is going to be harmed there should be no ability to mitigate or for developers to be able to buy their way out of this situation. This mindset is exactly why we are seeing a significant decline in biodiversity in the District which should be a rich in biodiversity area and why the World Economic Forum Report (2023) cites the UK as one of the worst countries in the world for destroying its biodiversity.

11. In many cases as set out in the Policies the strategic requirements lack being SMART in nature – particularly the M Measurable. These need to be explicit and clear: “you get what you measure”.

12. 65% of the perimeter of the District of Chichester south of the SDNP is coastal in nature. The remainder being land-facing. Policy NE11 does not sufficiently address the impact of building property in close proximity to the area surrounding the harbour, something acknowledged by the Harbour Conservancy in a published report in 2018 reflecting upon how surrounding the harbour with housing was detrimental to it long-term health. And here we are 5 years on and all of the organizations that CDC are saying that they are working in collaboration with, to remedy the decline in the harbour’s condition, are failing to implement the actions necessary in a reasonable timescale. CDC are following when they should be actually taking the lead on the issue. Being followers rather than leaders makes it easy to abdicate responsibility. There must be full and transparent accountability.

13. The very significant space constraints for the plan area must be taken into account. The standard methodology need no longer apply where there are exceptional circumstances and we are certain that our District should be treated as a special case because of the developable land area is severely reduced by the South Downs National Park (SDNP) to the north and the unique marine AONB of Chichester Harbour to the south. A target of 535dpa is way too high. This number should be reduced to reflect the fact that only 30% of the area can be developed and much of that is rural/semi-rural land which provides essential connectivity for wildlife via a number of wildlife corridors running between the SDNP and the AONB. Excessive housebuilding will do irretrievable damage to the environment and lead to a significant deterioration in quality of life for all who reside within the East / West corridor.

14. Many of the sites identified in the Strategic & Area Based Policies could result in Grade 1 ^ 2 farmland being built upon. The UK is not self-sufficient in our food security. It is short-sighted to expect the world to return to what we have come to expect. Our good quality agricultural land should not all be covered with non-environmentally friendly designed homes.