8.10

The Parish Council wishes to stress that ALL documentation, data and studies which are relevant to Transport should be included as evidence to support the Plan.

Housing number should be further challenged on this basis.

CATM model calibrated and validated using 2014 data not taking account of developments such as Chichester Free School adjacent to A27 Whyke roundabout. Transport assessment states "all junctions on the A27 Bypass are over capacity in one or both modelled peak hours". Only 28% of traffic growth due to Local Plan development. Improvements only to Fishbourne and Bognor Roundabouts so over capacity issues still remain at other roundabouts. Plan does not effectively mitigate the impact of additional growth and is adding further demand.

Remove the proposal for the Apuldram link road

The wording of this policy appears contradictory to the wording in paragraph 8.8 and the need to achieve net zero green gas emissions by 2050.
The provision of new road infrastructure including the proposed new link between Apuldram Lane and Fishbourne roundabout is contrary to numerous Policies set out in other chapters,of this plan regarding sustainability, protecting habitat,reducing air pollution, light pollution , minimising flood risk, and maintaining the natural environment and visual amenities.

A development/transport strategy needs to be formulated which provides a pathway to ensuring that requisite road improvements to address existing problems and accommodate new development can actually be funded and delivered within an appropriate timescale. This is the stated objective of para 8.6 of this plan which is then negated by this and other provisions in this Chapter.

These comments relate to the adoption of the proposed ‘monitor and manage’ approach referred to in this paragraph.

As acknowledged in Paras 8.2, 8.3 and 8.4 of this Plan road congestion around the junctions of the A27 bypass is already a major concern for residents and business in the area. We are told in para 8.4 that in many parts of the area the road network is operating at or close to designated capacity.

The currently adopted Local Plan for the period 2014 – 2029 (paras 8.3 and 8.7) acknowledges this and envisages a package of improvements to upgrade six junctions on the A27 Chichester Bypass to mitigate the impacts of development.

The West Sussex Transport Plan (2022-2036) likewise acknowledges the need for significant improvements to the A27 to support this new local plan citing (inter alia) congestion on the A27 and A259 during peak periods (not limited to AM and PM peak hours) and rat-running on residential and rural routes to avoid congestion on the A27. (Transport Plan Paragraph 7.54 )

A27 junction mitigation issues are listed as a short -term priority (2022 – 2027) for the Chichester area (Transport Plan Paragraph 7.63).

Not justified – not an appropriate strategy:

Given that capacity on the road network is already at or approaching full capacity how can allowing further development under a ‘monitor and manage’ approach be justified? Further monitoring is not required to tell us about problems which are already widely acknowledged.

Not justified – lack of evidence gathered from local community:

This policy was not included in the 2108 Local Plan Public Consultation nor has it been publicised prior to its inclusion in this Plan. Evidence has not been gathered from the local community.

Not effective – improvements likely not deliverable during plan period through lack of funding:

There is no clear strategy set out to fund improvements identified by ‘monitor and manage’ so as to make this strategy deliverable (see comments on para 8.11 below).

Such an approach will exacerbate an already unacceptable situation which is damaging to the health and prosperity of the area.

We find it hard to believe that no funding can be found to ensure the A27 infrastructure gets the improvements it must have BEFORE MORE NEW HOMES ARE BUILT.

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.

See attachments.