8.12

CDC must coordinate with WSCC to have the A286 South of Chichester included in the Major Roads Network funding pipeline.

The statement 'no additional funding sources have been identified.' implies all reasonable efforts have been made to identify those resources. No significant attempt has been made to secure funding from the DfT's Major Roads Network fund.

If central government will not fund A27 improvements the proposed south of the A27 should not proceed unless there is a workable strategy to shift traffic onto mass public transport

Much of the traffic on the A27 "strategic Route" is not local. It is unreasonable for local residential low rise developments to fund substantial junction improvements to speed up strategic traffic.

The plan should be amended as follows:
8.12 The sustainability appraisal stated that capacity on the A27 is a major issue and there is a need to minimise A27 traffic as far as possible (para 5.2.23-5.2.24). It also stated that here is a clear and significant concern with higher growth scenarios, given the risk of an objection from National Highways on the grounds that the proposed 'monitor and manage' strategy could be insufficient to avoid severe traffic congestion on the A27. In order to avoid this objection the council will retain its existing approach to 'predict and provide' which forecasts the predicted growth in traffic and provides mitigation based on the forecast growth and will enhance this by identifying a package of potential highway improvements (including enhanced walking, cycling and public transport) which alongside schemes identified through the development management process, may be implemented. Given the significant increase in road congestion that would be created by building new homes in Tangmere before the introduction of necessary strategic infrastructure (e.g. a rail stop serving Tangmere and Oving) and significant investment to relieve congestion on the A27 which would be required to meet the NPPF requirements for sustainable development. Therefore the masterplan for the land to the west of Tangmere will be suspended until approvals and funding sources have been identified from public expenditure and developer contributions to provide this infrastructure in line with policy Tl. Fishbourne Roundabout with the Terminus Road Link is estimated at between E9.5 and E12.9 million, and Bognor Road Roundabout with the Vinnetrow Road Link is estimated at between El 9.4 and E30.4 million.

There is much to commend in this document and the supporting technical documents that accompany it, and I have listed in the appendix to this letter 26 such paragraphs and policies. I am happy for my support to be registered against these sections of your consultation document. There is also much upon which I must represent a concern, so I attach representations relating to 22 paragraphs or policies.

I am happy to participate in a hearing session, and I would flag at this stage that the common theme that links all of these representations is the need to safeguard the natural and built environment in and around Saxon Meadow, Tangmere from the risks of unsustainable development, I consider that the independent examiner should focus their review on the aspects of the local plan that relate to this matter.

Appendix 1: list of policies that I support
1. P14, 1.23, 1.24: Duty to cooperate
2. P24, para 2.30 "the council declared a climate emergency in July 2019"
3. P24, para 2.32 — "all proposal for new development should be considered in the context of a climate emergencV'
4, P30: Objective 2: natural environment: "development will achieve net gains in biodiversity'
5. P43, 4.1 "National policy promotes increasing energy efficiency, the minimisation of energy consumption and the development of renewable energy sources"
6. P43, 4.3: "Some renewable energy projects provide significant opportunities to enhance biodiversitV'
7. P53, Policy NE5: Biodiversity and Biodiversity Net Gain
8. P62, Para 4.42: Hedgerows and some types of woodlands are identified as a priority habitat
9, P62, Policy NE8: Proposals should have a minimum buffer zone of 15 metres from the boundary of ancient woodland or veteran trees to avoid rood damage (known as the root protection area)
10. P68, Policy NEIO: Criteria for Development in the Countryside - Does not prejudice viable agricultural operations or other viable uses
11. P80, Para 4.91: There are serious concerns about the impact of flooding, both in respect of current properties at risk but also the long-term management of the area.
12. 4.92: any development in the plan area must therefore have regard to flood and erosion risk.
13. 4.94: built development can lead to increased surface water run-off; therefore, new development should include SuDS to help cope with intense rainfall events
14. P81, Para 4.96: Environment Agency consent is required for any works within 16 m of tidal waters and 8m of fluvial watercourses in line with the Environmental Permitting Regulations 2016. This strip is required for access. The policy includes a setback requirement to ensure this access strip is not obstructed.
15. P80, 4.92, Any development in the plan area must therefore have regard to flood and erosion risk, now and in the future, by way of location and specific measures, such as additional flood alleviation, which will protect people, properties and vulnerable habitats from flooding. Recent changes to national guidance highlight the importance of considering flood risk from all sources, and this is particularly significant for the plan area as large parts of it are at risk from groundwater flooding, which needs to be recognised in development decisions alongside the well-established risks in relation to tidal, fluvial and surface water flooding. Appropriate mapping of all sources of flood risks is still evolving, and is likely to develop further over the plan period
16. P93, Policy NE20 Pollution: Development proposals must be designed to protect, and where possible, improve upon the amenities of existing and future residents, occupiers of buildings and the environment generally. Development proposals will need to address the criteria contained in, but not limited to, the policies concerning water quality; flood risk and water management; nutrient mitigation; lighting; air quality; noise; and contaminated land. Where development is likely to generate significant adverse impacts by reason of pollution, the council will require that the impacts are minimised and/or mitigated to an acceptable level within appropriate local/national standards, guidance, legislation and/or objectives.
17, P94, 4.127, Light pollution caused by excessive brightness can lead to annoyance, disturbance and impact wildlife, notably nocturnal animals. The design of lighting schemes should be carefully considered in development proposals to prevent light spillage and glare.
18. P94, 4.128, Dark skies are important for the conservation of natural habitats, cultural heritage and astronomy. The plan area includes three 'Dark Sky Discovery Site' designations, all located within the Chichester Harbour AONB; Eames Farm on Thorney Island, Maybush Copse in Chidham; and north of the John Q Davis footpath in West Itchenor. Development within or directly impacting these areas will be subject to particular scrutiny in terms of their impact on dark skies. The entire SDNPA area is also declared as an International Dark Sky Reserve. Development directly impacting this area will be subject to similar scrutiny.
19. P96, Policy NE22 Air Quality
20. P97, Policy NE-23 Noise
21. P142, Para 6.29, Amenity: Private space, shared space and the design quality and construction of communal spaces all contribute to amenity
22. P155-6, Policy P11:Conservation Areas "protecting the setting (including views into and out of the area)"
23, P55, Para 4.26 - The council is under a legal duty to protect designated habitats, by ensuring that new development does not have an adverse impact on important areas of nature conservation, and by requiring mitigation to negate the harm caused.
24. P58, Para 4.33 The council is under a legal duty to protect their designated bird populations and supporting habitats
25. P95, Para 4.129 The council has a duty to review and assess air quality within the district
26. P301, Conservation Area: An area of special architectural or historic interest, designated under the Planning (Listed Buildings & Conservation Areas) Act 1990. There is a statutory duty to preserve or enhance the character, appearance, or setting of these areas.

Reduced housing numbers.

If no additional funding is available. The timing of these improvements will depend on the timing of development and will therefore be dependent on commercial decisions by developers. This is not a sound long-term strategy. Moving away from ‘predict and provide’ to ‘monitor and manage’ is a decision made because no additional funding sources have been identified. To build 10,350 homes in the plan area with no such certainty is leaving the A27 open to be being at gridlock constantly. It will become a car park with idling engines.

1) Reduce number of houses which equates to less cars on already busy roads
2) Upgrade infrastructure i.e. improve bus routes, provide cycle paths, construct railway station.

See representations

A revised development/transport strategy needs to be articulated which will provide 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.

Not justified – not an appropriate strategy

Not justified – lack of participation of local community

In relation to the adoption of a ‘monitor and manage’ approach for problems which already exist and will inevitably be exacerbated by new development please see my comments on paragraph 8.10 above. Please also see the comments in that paragraph with regard to this change in policy and lack of evidence of participation of local community

Not effective – transport infrastructure improvements are not likely to be deliverable during plan period through lack of funding

The reason given for this approach is stated to be that the full cost of these works cannot be funded from existing funding sources. However proceeding with new development with no deliverable plan to provide the requisite highways improvements (before or after development) presents a very high level of risk to residents and business and the general prosperity of the area.

The plan provides no strategy as to how this risk can be managed so as provide a realistic way forward. Paragraph 8.5 of the Plan refers to the possible National Highways A27 improvement scheme which may or may not be confirmed. If this scheme does not proceed within the requisite timeframe what then? This issue is not addressed at all in the plan.

A significant reduction in the scale of development or more the development to a more appropriate site (e.g. use brownfield sites not green belt or good arable farmland). Reduction will help to minimise the increase in pollution, air quality will be negatively impacted and noise will affect a recognised conservation area around the old Saxon church - so use more appropriate sites to build homes.

See representation

Reduce building on green field sites. Use existing property, the spaces above shops in the city are dark at night. Use the existing green field sites, close to the city and thus less car use. Visit European cities where it is common and cheap to live centrally.

See representation

Modification of the plan to reduce or cancel the development to avoid further traffic congestion.

See representation

See attached.