Policy AL5: Southern Gateway

Showing comments and forms 1 to 30 of 41

Object

Local Plan Review: Preferred Approach 2016-2035

Representation ID: 129

Received: 13/01/2019

Respondent: Chichester Society

Representation Summary:

We propose the following changes are made: "3. Respect for the historic context, have regard to that part of Southern Gateway that lies within the Conservation Area and to the Listed Buildings and Heritage Assets, and make a positive contribution towards protecting and enhancing the local character and special heritage of the area and important historic views, especially those from the Canal Basin towards Chichester Cathedral; "provision of a bridge or underpass to allow the removal of the level crossings on Stockbridge Road and Basin Road"

Full text:

On Policy AL5: Southern Gateway
* The Chichester Society propose the following changes are made:
* In site specific requirement number 3 we propose "3. Respect for the historic context, have regard to that part of Southern Gateway that lies within the Conservation Area and to the Listed Buildings and Heritage Assets, and make a positive contribution towards protecting and enhancing the local character and special heritage of the area and important historic views, especially those from the Canal Basin towards Chichester Cathedral;
* We propose to add as site specific requirement number 4 "provision of a bridge or underpass to allow the removal of the level crossings on Stockbridge Road and Basin Road"
* We propose the removal of paragraph 7

Object

Local Plan Review: Preferred Approach 2016-2035

Representation ID: 209

Received: 15/01/2019

Respondent: Miss M Pratt

Representation Summary:

Sensible builder knows its full cost but unknown cost for junctions.
No dedicated cyclepaths shown or section of cyclepath near Appledram Centre.
Use of narrow residential streets in city centre unwise
No right turn from Terminus Road to Stockbridge Road is unhelpful for local residents.
Detailed plans to be shown to residents for housing and construction traffic. All the proposed alterations at junctions are detrimental - pollution, noise - not just the Stockbridge one and ruining so much farmland forever.
Chichester Gate remains an eyesore

Full text:

Every sensible builder knows its full cost but unknown cost for junctions.
No dedicated cyclepaths shown or section of cyclepath near Appledram Centre. Current recommendations ignored e.g. Systra.
Use of narrow residential streets in city centre unwise, especially for cyclists.
No right turn from Terminus Road to Stockbridge Road is unhelpful for local residents.
Detailed plans to be shown to residents for housing and construction traffic. All the proposed alterations at junctions are detrimental - pollution, noise - not just the Stockbridge one and ruining so much farmland forever.
Chichester Gate remains an eyesore, a reminder of how alter the city particularly if Southern Gateway will be so much more visible.

Object

Local Plan Review: Preferred Approach 2016-2035

Representation ID: 249

Received: 29/01/2019

Respondent: Sustrans

Representation Summary:

Currently National cycle routes NCN 2 [ and 88] cross this site, albeit not very safely. New proposals should make better provision.

Full text:

Currently National cycle routes NCN 2 [ and 88] cross this site, albeit not very safely. New proposals should make better provision.

Comment

Local Plan Review: Preferred Approach 2016-2035

Representation ID: 271

Received: 20/01/2019

Respondent: Steve Blighton-Sande

Representation Summary:

It is not clear at this stage what the proposals will be to ensure no negative impact to users of the bus station.

Full text:

It is not clear at this stage what the proposals will be to ensure no negative impact to users of the bus station.

Object

Local Plan Review: Preferred Approach 2016-2035

Representation ID: 336

Received: 23/01/2019

Respondent: Mr Paul Sansby

Representation Summary:

This policy must include a requirement to provide a road bridge across the railway from the sorting office to the old bus station. The Master Plan can still include a sustainable road layout suitable for pedestrians, cars and buses.

Full text:

This policy must include a requirement to provide a road bridge across the railway from the sorting office to the old bus station. The Master Plan can still include a sustainable road layout suitable for pedestrians, cars and buses.

Object

Local Plan Review: Preferred Approach 2016-2035

Representation ID: 473

Received: 28/01/2019

Respondent: Mr Richard Hutchinson

Representation Summary:

The plans for the Southern Gateway are fundamentally flawed in terms of proposed land uses, transport issues, sustainability and density of development. As alternative schemes such as Freeflow and Gateway + have shown, a more imaginative approach is possible that will truly regenerate this area and boost Chichester as a thriving City. The current plans are unimaginative and narrow minded and waste a once in a century opportunity.

Full text:

The plans for the Southern Gateway are fundamentally flawed in terms of proposed land uses, transport issues, sustainability and density of development. As alternative schemes such as Freeflow and Gateway + have shown, a more imaginative approach is possible that will truly regenerate this area and boost Chichester as a thriving City. The current plans are unimaginative and narrow minded and waste a once in a century opportunity.

Comment

Local Plan Review: Preferred Approach 2016-2035

Representation ID: 517

Received: 29/01/2019

Respondent: Commander Brian Raincock

Representation Summary:

The current CDC Masterplan does not meet the objectives set out in AL5 and wastes a huge opportunity to enhance the public realm in Chichester, in particular it does not currently include specific proposals for a high quality distinctive design response.
The road layout with the level crossings being maintained does nothing to improve safety, communication, and environmental issues such as exhaust fumes. Item 7 completely misses the requirement

Full text:

The current CDC Masterplan does not meet the objectives set out in AL5 and wastes a huge opportunity to enhance the public realm in Chichester, in particular it does not currently include specific proposals for a high quality distinctive design response.
The road layout with the level crossings being maintained does nothing to improve safety, communication, and environmental issues such as exhaust fumes. Item 7 completely misses the requirement

Comment

Local Plan Review: Preferred Approach 2016-2035

Representation ID: 522

Received: 29/01/2019

Respondent: Sam Pickford

Representation Summary:

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

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

Full text:

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

Object

Local Plan Review: Preferred Approach 2016-2035

Representation ID: 656

Received: 28/01/2019

Respondent: Lavant Parish Council

Representation Summary:

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.
The proposal as outlined is a 20th century concept; we live in the 21st Century. Southern Gateway is undeliverable.

Full text:

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').

Object

Local Plan Review: Preferred Approach 2016-2035

Representation ID: 669

Received: 31/01/2019

Respondent: Mrs Fiona Horn

Representation Summary:

Southern Gateway is flawed as it stands. It will disadvantage local residents hugely . lead to even more gridlock around the Station and lead to a hideous gentrification of the a wonderful asset, the canal. Stop ruining Chichester's heritage and assets for the sake of the greed from developers. The whole scheme needs to go back to the drawing board and be led by local Chichester residents who do not have developers manipulating the outcome.

Full text:

Southern Gateway is flawed as it stands. It will disadvantage local residents hugely . lead to even more gridlock around the Station and lead to a hideous gentrification of the a wonderful asset, the canal. Stop ruining Chichester's heritage and assets for the sake of the greed from developers. The whole scheme needs to go back to the drawing board and be led by local Chichester residents who do not have developers manipulating the outcome.

Object

Local Plan Review: Preferred Approach 2016-2035

Representation ID: 721

Received: 01/02/2019

Respondent: West Itchenor Parish Council

Representation Summary:

It is proposed that there is provision of a bridge or underpass to allow the removal of the level crossings on Stockbridge Road and Basin Road
It is proposed that paragraph 7 is removed.

Full text:

It is proposed that there is provision of a bridge or underpass to allow the removal of the level crossings on Stockbridge Road and Basin Road
It is proposed that paragraph 7 is removed.

Object

Local Plan Review: Preferred Approach 2016-2035

Representation ID: 816

Received: 02/02/2019

Respondent: Mrs Fiona Horn

Representation Summary:

Southern Gateway should be removed from the plan until the A27 issue has been addressed. There is NO non essential traffic using this route. It is traffic that is local/national that would otherwise clog the A27. Define non essential traffic !! Housing would no doubt be overpriced and not affordable for locals .Unless this is adequately addressed in future iterations of the plan, I will raise this with the examiner at the appropriate time.

Full text:

Southern Gateway should be removed from the plan until the A27 issue has been addressed. There is NO non essential traffic using this route. It is traffic that is local/national that would otherwise clog the A27. Define non essential traffic !! Housing would no doubt be overpriced and not affordable for locals .Unless this is adequately addressed in future iterations of the plan, I will raise this with the examiner at the appropriate time.

Object

Local Plan Review: Preferred Approach 2016-2035

Representation ID: 975

Received: 30/01/2019

Respondent: Chichester Conservation Area Advisory Committee

Representation Summary:

Policy fails to acknowledge that part of the site is within the Conservation Area and includes heritage assets.
Statements about buildings in area not making positive contribution are misleading e.g. bus garage is an example of early use of thin-shell pre-stressed concrete to give a clear span.
Need for high quality design is included but will the policy be enforced?
Traffic management and diverting all but buses along Basin Rd are dubious ideas.

Full text:

Retail Hierarchy and Sequential Approach.

We support this policy and commend the six bullet points in para 4.60. We strongly support in 4.66 the promotion of the city centre's retail offer and the restriction of further retail development in out-of-centre locations.

Chichester City Development Proposals.
Whilst this acknowledges need for new development to have special regard for the city's historic character by the use of Supplementary Planning Documents or Development Plan Documents, what faith can we have that they will be adhered to? The previous Southern Gateway Development Framework specified that buildings should be two storey with occasional three. Despite this the recent canal-side development, known as John Rennie Road, was permitted to be three storey with a lot of four, and is of such poor quality design it damages the approach to the city and the Conservation Area. Chichester Gate, as permitted, is an architectural disaster displaying as it does poor design and cheap materials. Furthermore the policy should make the point that the whole of the city centre is a conservation area and should be respected as such. A map shewing the Conservation Area boundary should be appended to the Local Plan

The Council must undertake to enforce the provisions of their SPDs etc otherwise they are worthless. The policy should make the point that the whole of the city centre is a conservation area and should be respected as such. A map shewing the Conservation Area boundary should be appended to the Local Plan.

Design
This acknowledges the historic environment, the need to create high quality buildings and the need for policies to drive this. All well and good - but policies need to be adhered to by CDC when determining applications and there is little evidence of this happening at present.
Policy S20 introduces the concept of 'Sense of Place' and the importance of getting scale, height density right. This is a laudable aspiration which has been ignored in the past.

Ensure the policy is enforced when determining all planning applications

Historic Environment.
This acknowledges the importance of Heritage Assets, the need for further Conservation Area Character Appraisals (CACA) and the importance of protecting Heritage Assets. Fine - but with no Conservation Officers on the staff preparation of CACAs is falling woefully behind. The revision to the Chichester CACA is still not completed over two years on.

Commit to filling the Conservation Officer posts and completing all the CACAs as a matter of urgency

Southern Gateway
This policy fails to acknowledge that a large part of the designated Southern Gateway area lies within the Conservation Area and includes several Designated and Non-Designated Heritage Assets, GII-listed buildings in Southgate and Basin Road, buildings on the Local List and others identified as positive in the latest Conservation Area Character Appraisal. The statements regarding the majority of the buildings in the SG area not making a positive contribution are misleading. The railway station, county court, Boys' High School and bus garage all do make a positive contribution. The bus garage is an important example of the early use of thin-shell pre-stressed concrete to give a clear span. It is an attractive building whose open space should be put to new uses (an open market for e.g.). Once again the need for high quality design is included in the policy but will it be enforced? The Southern Gateway has recently been defiled by two appalling permitted developments - John Rennie Road and Chichester Gate.
The ideas for traffic management and diverting all but buses along Basin Road are dubious.

Correct the policy by stating that the SG area is in the Conservation Area and include from the above about the heritage assets, listed buildings etc. Also commit to enforcing the design policy.

Chichester Centre Retail
We support paragraphs 1 to 4 of this policy and revision to the shopping frontages, especially with regard to Crane Street. The policy rightly acknowledges the constraints of the historic character of the city centre and the need to improve the visitor experience. Out-of-town retail developments such as Barnfield suck the life out of the city centre and should be resisted. 7.69 mentions the importance of considering the Council's Shopfront and Advertisement Design Guidance Note within the Conservation Area. This is a laudable aim but, sadly, shopfronts which patently do not conform are usually permitted. The Guide requires hand painted lettering on a painted timber fascia, yet metal or plastic fascias with raised lettering are invariably permitted without question. Case officers do not seem to know of the existence of the guide and one has to wonder whether applicants are made aware of it. It is not easy to find on the CDC website.

Ensure case officers are aware of the ship front guide and that it is enforced in their decisions. Strengthen enforcement to rule on unauthorised shopfronts

Historic Environment
7.154-7.166 acknowledges conservation areas, the existence of local lists and character appraisals and emphasises the need for further conservation area character appraisals (CACA) and the need to protect Heritage Assets. Fine words, but with no Conservation Officers on the staff all this is getting woefully behind. The revision to the Chichester CACA is still not completed over two years on. CCAAC have put forward in the past four years several proposals for additions to the local list whose scoring was agreed by the then Historic Buildings Advisor but which have still not been signed off, leaving those buildings with no protection Once again, with no conservation officers these aspirations cannot be met .
Policy DM27 itself includes conserving and enhancing the special interest and settings of designated and Non-Designated Heritage Assets but not about the need to protect these assets themselves. This omission should be corrected

Complete processing of outstanding Local List applications, appoint Conservation Officers, and reword the policy to provide for protecting the assets

Support

Local Plan Review: Preferred Approach 2016-2035

Representation ID: 1141

Received: 25/01/2019

Respondent: British Horse Society

Representation Summary:

Support and welcome the requirement for opportunities for the provision of green infrastructure with links to the wider countryside to be explored. Creating new routes and links is especially important on the Coastal Plain, where an off-road multi-use path network would be of great benefit to all NMUs.

Full text:

The British Horse Society (BHS) is the UK's largest equine charity and equestrian membership organisation and the governing body for recreational riding. Its charitable objects include the promotion of equestrian safety, particularly on roads, and equestrian access to bridleways and other off-road multi-use routes for the public benefit. On behalf of The Society I would like to make the following comments:

Chichester Local Plan Review 2016-2035 Preferred Approach

The Society's priority when commenting on this document is to try and ensure that the policies and wording in the text include commitments to support and protect vulnerable road user groups, including equestrians (West Sussex Transport Plan, page 32, para 1.4.5), from the dangers they face on local roads due to the inevitable increase in traffic on these roads brought about by planned housing development.

The Plan area covered is home to a large number of equestrians, who bring significant economic benefits, especially to rural communities, but unless they have access to a safe network of bridleways, byways, and other off-road informal recreational routes which they can use daily, the dangers to horse riders will increase, and the industry will struggle to survive.

Policy S18: Integrated Coastal Zone Management for the Manhood Peninsula (page 68)
Equestrians on the Manhood Peninsula feel increasingly unsafe on the local roads they have always used, where the speed and volume of vehicles has grown considerably, and will do so even more as a result of the proposed housing development. There are now more than 500 horses kept in the area (Manhood Riding Club count) in private stables, livery yards, and the local Riding School (at which the Chichester Group of Riding for the Disabled is based).

We would, therefore, absolutely support objective 5 of this Policy "Improve infrastructure to support sustainable modes of transport, especially cycle ways, bridleways and footpaths, including the National Coastal Footpath ".

We would suggest the best way to do this is to ensure that at least one multi-use route (bridleway) is provided through, or around the fringe of developments, which can also serve as a green corridor for leisure and recreation and, and benefit health and well-being, wildlife and biodiversity. These routes can form the basis of a safe non-motorised user (NMU) network and link with existing public rights of way (prow) where possible.

Policy S20: Design (page 74)
Bullet point 5 - wording is supported "incorporates and/or links to high quality Green Infrastructure and landscaping to enhance biodiversity and meet recreational needs, including public rights of way."
However, it is important as mentioned above that this incudes 'multi-use' public rights of way for the benefit of all.

Transport Infrastructure
Para 5.15 - very good to see "bridleways" included in this para.
Para 5.16 - The wording "There is an extensive public rights of way network across the plan area... is misleading. The wording implies that this prow network is available to all users, whereas on the Coastal Plain the prow network consists almost entirely of footpaths, which are not available for use by cyclists and equestrians. Upgrading appropriate/suitable prow to bridleways would contribute to the West Sussex Transport Plan (2011-2026) aim of "improving safety for all road users", mentioned in para 5.18.

Policy S23: Transport and Accessibility
Bullet point 8 - Our view is that the objective "improving safety for all road users", should be included in the actual Policy wording, not just in the accompanying text. However, it is good to see 'public rights of way' included, which need to be multi-use bringing safety benefits for all vulnerable road users.

Countryside and Countryside Gaps (page 82)
Para 5.37 - Absolutely agree the plan area's countryside is an important and diminishing resource, and the Council's aim to protect the countryside from the urbanising impacts of development is welcomed. For existing and future residents, the opportunity to enjoy 'informal recreation' (walking, cycling, horse riding) in the countryside is important for leisure, health, and well-being. The Council needs to take a very active role in ensuring that any development provides benefits, most likely in the way of safe, off-road multi-use routes(green links), and the mention of this in para 5.40 is welcomed.

Policy S32: Design Strategies for Strategic and Major Development Sites (page 92/93)
The references in Point b, "movement and access arrangements and Green Infrastructure provision", in Point e, "community leisure and recreation facilities as appropriate", and Point g, "contain a Green Infrastructure framework to ensure that public and private open space standards are met, relate well to each other and to existing areas and that the new spaces are safe, convenient, accessible and functional" are welcomed.
However, it is important that leisure and recreational routes, and new prow connect to the wider countryside for public benefit, and are not just contained within a development. There are many examples in the county where new routes have been created across or on the fringe of a development, which link to a wider network of recreational routes. The National Planning Policy Framework (NPPF), para 98, 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"

Policy AL1: Land West of Chichester (page 96)
Point 4 - whilst welcoming the provision of "open space and green infrastructure", this development provides an excellent opportunity to improve links to the wider countryside, in particular to BW 270 and Park Lane (which should be formally dedicated as a prow).
Point 10 - An "appropriate landscaping buffer", is also an excellent opportunity to provide a multi-use prow (bridleway), for the safety and enjoyment of all vulnerable road users, which as a 'green corridor, would also contribute to green infrastructure.
We would also request that when looking at 'key landscaping' of the Centurian Way (CW), the issue of upgrading this to a multi-user path where possible, to include equestrians is considered, so that they can also benefit from a safe and secure off-road environment. The CW is the only disused railway line in the county that is not available for use by all NMUs. The Worth Way and Downs Link are fully multi-use, and are highly valued and well used.

Policy AL2: Land at Shopwyke (Oving Parish) (page 99/100)
Point 9 - Despite repeated requests for the proposed bridge connection across the A27 at Coach Road (a route used by all NMUs until it was severed when the A27 was realigned) to also be made available for equestrian use, it would appear from the Policy wording that horse riders continue to be excluded, despite the large numbers of horses kept in the Oving area.

At present, riders have to box their horses over the A27 to access the safe network of bridleways and riding routes in the National Park, which is a situation contrary to the aims and objectives set out in this Plan. In order to gain maximum benefit from bridge infrastructure, it should be made available for as many users as possible.

Policies AL3 to AL14
All of these Policies require opportunities for the provision of green infrastructure with links to the wider countryside to be explored, and these are welcomed and supported. Creating new routes and links is especially important on the Coastal Plain, where an off-road multi-use path network would be of great benefit to all NMUs.

The West Sussex Rights of Way Management Plan 2018-2028 has Objectives (page 3) which include:
2. Improve path links to provide circular routes and links between communities.
3. Improve the PRoW network to create safe routes for both leisure and utility journeys, by minimising the need to use and cross busy roads.
4. Provide a PRoW network that enables appropriate access with minimal barriers for as many people as possible.
5. Promote countryside access to all sections of the community enabling people to confidently and responsibly use and enjoy the countryside.

The Plan also states in Improvement schemes (page 13), that "A starting point for new schemes will be to consider who could benefit from a new route, such as walkers, cyclists, horse riders and the disabled, and be as inclusive as possible, often the aim will be to achieve at least bridleway status.

Policy DM32 Green Infrastructure (page 199)
It is disappointing that the wording (on page 197/198) omits to mention that prow (footpaths, bridleways, byways), are defined by Natural England, and also recognised nationally, as multifunctional 'green corridors', and are therefore part of GI. Providing a multi-use (walker, cyclist, equestrian) prow or recreational route around the periphery would comply with NPPF, para 98, as mentioned above.
It is good to see public rights of way, and bridleways mentioned in Point 4 of the Policy, although the wording "do not lead to the dissection of the linear network" appears to be rather negative, much better to tell someone what they should do "The proposals protect, and contribute to the improvement of ........"

Policy DM34: Open Space, Sport and Recreation .... (page 204)
We support the aim to "seek to retain, enhance, improve access and increase the quantity and quality of....rights of way including improvement of links to them." This will be of great benefit to all NMUs.

Point 1 - Excellent to see requirement for development to contribute to new links to the existing rights of way network, which should be multi-use wherever possible.
Also support the aim to secure on-site provision secured via S106 agreements to provide (amongst other things) links to the existing rights of way network to meet any identified shortfalls in the local area, and would request in line with the WS RoW Management Plan that these links will be "as inclusive as possible, often the aim will be to achieve at least bridleway status."

Attachments:

Object

Local Plan Review: Preferred Approach 2016-2035

Representation ID: 1205

Received: 06/02/2019

Respondent: Mrs Susan Pope

Representation Summary:

Whilst supporting the general principles of the Southern Gateway Development, it would be detrimental to the residents of the area south of the A27 if vehicular access to the City from the south was to be restricted prior to the implementation of a Highways England scheme to relieve congestion on A27. The planning strategy recognises that Chichester is the centre upon which residents to the south of Chichester rely for many of their needs. Access for them needs to be maintained until an alternative improved access across the A27 to the City had been provided.

Full text:

Whilst supporting the general principles of the Southern Gateway Development, it would be detrimental to the residents of the area south of the A27 if vehicular access to the City from the south was to be restricted prior to the implementation of a Highways England scheme to relieve congestion on A27. The planning strategy recognises that Chichester is the centre upon which residents to the south of Chichester rely for many of their needs. Access for them needs to be maintained until an alternative improved access across the A27 to the City had been provided.

Object

Local Plan Review: Preferred Approach 2016-2035

Representation ID: 1222

Received: 05/02/2019

Respondent: Ms Jacqueline Jones

Representation Summary:

CDC's £5million grant from central government's Coast to Capital regeneration fund specifically for the Southern Gateway provides financial resources for CDC to mitigate traffic congestion and noise light and traffic pollution that will doubtless result from current regeneration plans
350 dwellings and further commercial buildings will result in heavier traffic
All this traffic is intended to use Basin Road only which will become two way according to current plans
Resulting air, noise and light pollution will have a massive detrimental impact on those living in this area

Full text:

350 dwellings as well as mixed commercial/retail/leisure sites could produce up to 700 private cars and more commercial vehicles to service commercial sites
The current car park in Basin Road is earmarked for housing development and therefore will not mitigate this issue

Southern Gateway Traffic plans show all through traffic will be using Basin Road planned to be two way (not one way as it is now) with Stockbridge Rd reserved for pedestrians/bikes/buses
Cars using Basin Road and consequent congestion will increase considerably

Pollution - there is no specific planning to mitigate this in Southern Gateway plans
Current plans would increase pollution in air quality, noise from increased traffic and commercial deliveries (many probably either late night or early morning) and light from increased vehicles and further housing
CDC has received a £5 million grant specifically for development of Southern Gateway scheme from central government regeneration fund 'Coast to Capital' and must use this to ensure the scheme results in outcomes that are acceptable to all

Object

Local Plan Review: Preferred Approach 2016-2035

Representation ID: 1343

Received: 06/02/2019

Respondent: Mr Simon Davenport

Representation Summary:

The reliance on commercial and housing development in this critical area for the city appears to be misplaced. The success or otherwise will depend on a community led development scheme that incorporates significant public open space and high quality buildings. The city will not be well served by Chichester Gate style developments with low grade design and building. This is a great opportunity to enhance the experience for visitors to the city approaching from the rail and bus stations.

Full text:

The reliance on commercial and housing development in this critical area for the city appears to be misplaced. The success or otherwise will depend on a community led development scheme that incorporates significant public open space and high quality buildings. The city will not be well served by Chichester Gate style developments with low grade design and building. This is a great opportunity to enhance the experience for visitors to the city approaching from the rail and bus stations.

Comment

Local Plan Review: Preferred Approach 2016-2035

Representation ID: 1365

Received: 06/02/2019

Respondent: Mr David Leah

Representation Summary:

Generally agree but needs a fully integrated bus/train interchange and the closing of both level crossings with maybe a tunnel for local buses and deliveries.

There is no point what so ever in attracting cars to use the city centre as a n-s or e-w route. These should be forced on to routes around.

Full text:

Generally agree but needs a fully integrated bus/train interchange and the closing of both level crossings with maybe a tunnel for local buses and deliveries.

There is no point what so ever in attracting cars to use the city centre as a n-s or e-w route. These should be forced on to routes around.

Comment

Local Plan Review: Preferred Approach 2016-2035

Representation ID: 1373

Received: 06/02/2019

Respondent: Rev. John-Henry Bowden

Representation Summary:

Southern Gateway redevelopment is to be welcomed, but must include a modern, safe vehicle crossing of the railway line.

Full text:

Policy AL5: Southern Gateway. I welcome much of this proposal and strongly agree with the need to make this key arrival point, for visitors and tourists to Chichester, match in with the grace and history of the City. But I would like to see it much, much more imaginative, with transformational proposals for hotel(s) and fine tourist and community facilities to match those in the centre and to the North of the City, not to speak of the Harbour AONB.
In particular the proposal as it stands does nothing at all to improve the flow of road vehicle traffic in this transport hub. It is almost beyond belief that a plan of this magnitude could have been drawn up without paying any attention to the crying need for a continuous road crossing of the railway line - whether a bridge or an underpass. The congestion in this area is legendary and it must be impinging on the access to and viability of businesses in the city, to say nothing of the economic and environmental/pollution costs of all that queuing traffic, throughout the day. This is deliberately to ignore both health and safety. The implied proposal to limit this crossing to pedestrians and cyclists is short-sighted, unimaginative and detrimental to the future of the whole city.

Comment

Local Plan Review: Preferred Approach 2016-2035

Representation ID: 1463

Received: 05/02/2019

Respondent: Ms Helen Boarer

Representation Summary:

The Southern Gateway idea is completely ludicrous and a waste of tax payers money!

Full text:

There is too much information here and it feels like it is an opportunity for CDC to put strategies in that will be missed by the general public.

No further development should occur in this area until the profound issues of the A27 are resolved - it is already an area that has become difficult to live in with each year that passes. It is no longer an attractive city to live in and squeezing resources further will exacerbate that.

I strongly object to AL6 which concerns the construction of a relief road from Fishbourne roundabout to the A286 - what benefits will this bring to the area ? It will destroy an area of natural beauty and habitat. It will add to the danger of this roundabout which already has significant accidents.

As for the Southern Gateway idea - it's completely ludicrous and a waste of tax payers money!

Object

Local Plan Review: Preferred Approach 2016-2035

Representation ID: 1492

Received: 07/02/2019

Respondent: Mr Derrick pope

Representation Summary:

Whilst supporting the general principles of the Southern Gateway Development, it would be detrimental to the residents of the area south of the A27 if vehicular access to the City from the south was to be restricted prior to the implementation of a Highways England scheme to relieve congestion on A27. The planning strategy recognises that Chichester is the centre upon which residents to the south of Chichester rely for many of their needs. Access for them needs to be maintained until an alternative improved access across the A27 to the City had been provided.

Full text:

Whilst supporting the general principles of the Southern Gateway Development, it would be detrimental to the residents of the area south of the A27 if vehicular access to the City from the south was to be restricted prior to the implementation of a Highways England scheme to relieve congestion on A27. The planning strategy recognises that Chichester is the centre upon which residents to the south of Chichester rely for many of their needs. Access for them needs to be maintained until an alternative improved access across the A27 to the City had been provided.

Object

Local Plan Review: Preferred Approach 2016-2035

Representation ID: 1551

Received: 07/02/2019

Respondent: Mr John Davies

Representation Summary:

Revisit Southern Gateway taking idea from Gateway + to improve transport and interchange

Full text:

In spite of the adoption by the Council of a masterplan which" provides detailed guidance on the expectation for development" I feel that this site is so important that it must be re-visited in the context of the Local Plan. the plans for the level crossing are messy and mixed and much more consideration needs to be given to the ideas from the Gateway+ team , such as the limited size underpass. The area must be provided with good transport interchange facilities, attractive access into the city centre, and avoidance of any "traffic roundabout feel". In addition to affordable housing, provision should be made for cultural and possible conference facilities. the area is far too important for the city for it to be viewed solely as another opportunity for property profit. An excellent example of what can be done in just such an area, is the new "Depot" in Lewes. If they can do it - so can Chichester!

Comment

Local Plan Review: Preferred Approach 2016-2035

Representation ID: 1599

Received: 07/02/2019

Respondent: Mr Robert Probee

Representation Summary:

I would like to see a support for a road bridge over the railway as part of this development.

Full text:

I would like to see a support for a road bridge over the railway as part of this development.

Support

Local Plan Review: Preferred Approach 2016-2035

Representation ID: 1792

Received: 07/02/2019

Respondent: Harbour Villages Lib Dems Campaign Team

Representation Summary:

Supported but should be extended to include railway and other buildings. An extension to the station is required with additional platform and line for a Metro service. Multi use building for concerts, conferences, exhibitions and community activity also neccesary. All waste water must be pumped to TANGMERE.
Include suitable housing for young people, employment sites for entrepreneurs and a link to the gigabyte project.

Full text:

6.37 to 6.43 and AL5
We support this but feel it needs to be extended to include the railway and other buildings. It requires an extension to the station with an additional platform and line for a Metro service.
There needs to be a multi use building for concerts, conferences, exhibitions and community activity.

All waste water must be pumped to TANGMERE.
We need to include suitable housing for young people. Employment sites for entrepreneurs. A link to the gigabyte project.

Object

Local Plan Review: Preferred Approach 2016-2035

Representation ID: 1833

Received: 07/02/2019

Respondent: Ms Paula Chatfield

Representation Summary:

Please reference trees and links to the Lavant course and to the trees/greenspace in the vicinity of The City Walls, both north-east and north-west of the site, and in the vicinity of Kingsham Road and the Canal - there is significant opportunity to introduce green infrastructure to enhance this location and the connectivity of other sites.

N.B. as a volunteer Chichester Tree Warden, Chichester Tree Wardens may wish to pursue the subject of the inclusion of trees in the context of Policy SAL5: Southern Gateway.

Full text:

Please reference trees and links to the Lavant course and to the trees/greenspace in the vicinity of The City Walls, both north-east and north-west of the site, and in the vicinity of Kingsham Road and the Canal - there is significant opportunity to introduce green infrastructure to enhance this location and the connectivity of other sites.

N.B. as a volunteer Chichester Tree Warden, Chichester Tree Wardens may wish to pursue the subject of the inclusion of trees in the context of Policy SAL5: Southern Gateway.

Comment

Local Plan Review: Preferred Approach 2016-2035

Representation ID: 1844

Received: 07/02/2019

Respondent: Mr Andrew Bain

Representation Summary:

Propose amendments to the policy regarding:

respecting historic context to include part of Southern Gateway lying within Conservation Area as well as Listed Buildings and other heritage aspects; provision of height limited underpass on Basin Road; deleting reference to accommodating buses/coaches, restricting vehicular traffic using Stockbridge Rd level crossing and provision of appropriate car parking.

Full text:

Policy S13 Chichester City Development Principles
I support the protection of the views of the Cathedral

Policy S14 Chichester City Transport Strategy
I propose the following aspects are added in:-
a) Replacement of the level crossings in Basin Road and Stockbridge Road by a height limited underpass capable of taking single decker busses and being accommodated between the Kingsham Road junction and extended Avenue de Chartres junction on Basin Road. This would also incorporate a grade separated cycle and footway.
b) Safeguarding of land to enable the expansion of Chichester Railway Station from its present 2 platforms to 4 as envisaged by Network Rail to enable a faster service from Portsmouth to Brighton, and to allow for a fully integrated transport hub for bus and rail services.
c) Safeguarding of land close to the A27fora future "park and ride".
d) Safeguarding of land close to the A27for a "consolidation centre "for break bulk delivery to city centre retail units.

Policy S20; Design
I welcome this proposed additional policy to be used positively to protect our City against the creep of dumbing down with the poor design quality of new housing estates and ill-considered extensions and alterations to existing housing.

Policy S23; Transport and Accessibility
a) This additional policy is welcomed
b) I particularly welcome the proposed new road connecting Birdham Road to the A27 at Fishbourne roundabout. This was known as the Stockbridge Link Road as part of Highways England Option 2in their 2016 ill-fated consultation. I feel other aspects of Option 2 should be allowed for future inclusion particularly the flyovers for the A27 at the Fishbourne and Bognor Road roundabouts.

Policy AL5; Southern Gateway

a) In site specific requirement number 3 I propose " Respect for the historic context, have regard to that part of Southern Gateway that lies within the Conservation Area and to the Listed Buildings and Heritage Aspects and make a positive contribution towards protecting and enhancing the local character and special heritage of the Aareaand important historic viewsespecially those from the Canal and its Basin towards the Cathedral,"
b) I propose you site specific requirement number 4 "provision of a height limited underpass on Basin Road to allow removal of the level crossings on Stockbridge Road and Basin Road.
c) I propose the removal of paragraph 7

Policy AL6; Land South -West of Chichester (Apuldram and Donnington Parishes.
I support this new policy and its land allocation. There should be allocation on this Land for relocating the Bus Garage and Royal Mail Postal Distribution Depot to allow the early freeing up of the existing sites within the Southern Gateway Masterplan.

Comment

Local Plan Review: Preferred Approach 2016-2035

Representation ID: 1994

Received: 07/02/2019

Respondent: Mr Martin Tomlinson MBE

Representation Summary:

Attachment raises concerns regarding lack of indication of new employment possibilities; housing mix reflecting current population range; possible low quality build materials and potential repeat of failings at Chichester Gate.

Full text:

PBA's report Table 7.1 states no right turns from A27. The directional arrows NSN on the A286 in Fig 7.3.5 are so indistinct they do not appear to agree with the Table statement. Linda Boize corresponded with PBA's Paul Gebbett who wrote 'Agreed, this is not clear on the figure, the nearside lane on the A286 in both directions is for straight ahead and right turn and offside lane for right turn only'. In response to her query 'The words at the RHS of the drawing are incomplete, but look as though they say the footbridge should be pulled down and replaced with a signal controlled at-grade pedestrian crossing. Is this correct?' he wrote 'The text referred to in the figure, should have been removed as it refers to the previous 2029 mitigation on which this mitigation was based. Our mitigation does not propose to remove the footbridge'.
Thus, PBA are acknowledging significant and misleading errors in their report and I think that CDC would not have to expect a local person to have to contact PBA direct to get clarification.
PBA are also acknowledging their reliance on and 'cut and paste' of previously produced A27 reports, which raises doubt about how much original, newly informed and up-to-date data has been used, which has been properly tested against current conditions for its relevance.

Consultation documents should be accurate and easy to read/understand. An Executive Summary which easily and clearly identifies the differences of the report from reports produced over the recent years is needed. This would have revealed exactly how much or how little account was taken of all the work that went into the BABA27/Systra exercise. That this is lacking raises the question of how 'desk top' PBA's study is and how much liaison and consultation with WSCC concerning Systra actually took place. PBA are also acknowledging their reliance on and 'cut and paste' of previously produced A27 reports, which raises doubt about how much original, newly informed and up-to-date data has been used, which has been properly tested against current conditions for its relevance. PBA's proof reading of their report is woeful. The lack of clarity with Fig 7.3.5 is repeated elsewhere in the report. Improvements = CDC insist that consultants produce accurate reports. How else can a properly informed consultation take place?

The PBA report states 'At this time, the study (Systra) is desk top only and no formal modelling or design has been progressed.' PBA thus appear to dismiss the Systra and BABA27 work in its entirety.
PBA have taken no account of all the background work leading to the 2 concepts of the Systra consultation, which identified key issues needing resolution eg separating through and local traffic. If these had been taken account of, the proposed unworkability of roundabout (rbt) mitigations would have become clear as traffic would have to use local narrow, residential roads within the City, with speed bumps, schools, residents' parking to compensate for inaccessible roundabouts.
For example, no right turns for westbound traffic from the A27 onto the A286 at the Stockbridge and Whyke rbts - traffic for the Southern Gateway and Whyke would have to leave the A27 at the Bognor rbt and use Quarry Lane and Kingsham Ave and Kingsham Road, both narrow residential roads. Or, would have to continue west on the A27 to the Fishbourne rbt into Ave de Chartres and then onto Terminus Road. But no right turn into Stockbridge road don't allow access to John Rennie Road, South Bank and Kings Ave, Lacy House and Byron Court.

Air quality at the A27/Stockbridge junction deteriorates year on year. Although monitoring of NO2 at the junction shows levels generally below the prescribed upper limit, adequate monitoring of particulates and NO2 for 200m from the junction on the A286 north and south is not done. Several blocks of student accommodation, apartments for retirement and health impaired people, most of whom are elderly, are located on these stretches of road. Residential dwellings line both sides of these stretches of road and form effective traps for vehicle emissions. It is difficult to conceive that bunching of idling vehicles at the A286 north/south traffic signals will not add to further deterioration in air quality and residents' health. No account is taken of the damaging effect recurring/constant air pollutants cause to people with alreadycompromised respiratory health, resulting in unnecessary health and well-being deterioration, reduced mobility, increased medication and reduced enjoyment of life.

The impact of air polluants is not a 'one size fits all'. The demographic of the population must be recognised. In addition to the elderly population on the Stockbridge Road from the railway lines to the junction, there are large schools with their playing fields immediately adjacent to the A27 between the Stockbridge and Whyke junctions. The foot/cyclepath alongside the A27 is used by schoolchildren and others to access the school. The Free School just south of the Whyke rbt will be affected by vehicle emissions from idling traffic queuing at the S-N lights on the Whyke B2145 junction. Signalising the Stockbridge and Whyke junctions for the benefit of through traffic does not benefit people. Air quality impacts argue for separation of through and local traffic.

Traffic noise on the A27 increases year on year as its volume increases. The further predicted increases will maintain this trend. Signalising the Stockbridge junction will result in bunched traffic accelerating away from the lights, with high-powered motorbikes particularly accelerating hard to get past traffic. This already is very noisy, especially in the evenings and at weekends (when motorbike convoys use the A27), and will get even more so. Even good quality double glazing does not exclude the noise and leaving south-facing windows open in good weather is impossible. Despite PBA's conclusion that noise will not be a problem, they acknowledge some roads merit further study. Since Appendix H 'Noise assessments' does not open on my computer, it is not possible to examine how noise was measured, what time of day etc.

Page 92, 6.5 states 'The strategic development locations will be planned and designed to be of a high standard as sustainable development, well integrated with existing settlements and neighbourhoods.' Compare this with the Chichester Gate Design Concept...'the proposed design will provide a high quality development that formalises a historic gateway into and out of Chichester. Located along the city's principle southern approach.....the development creates a strong and lasting impression as visitors travel along Stockbridge Road.' And look at what we got. Chichester Gate with its unused piazza and tawdry, empty premises is the template of how not to do it. The planned Southern Gateway development will be very visible to all, residents and visitors. Chichester Gate is a reminder of CDC's failure to deliver its aspirations. The Southern Gateway development may follow a similar trajectory, not meeting CDC's flagship project aspirations as developers/builders sacrifice quality to higher/denser buildings, poor and low cost design and build. Good design and use of good materials doesn't have to imply high cost. It implies imagination and flair. Across the Stockbridge Road is the John Rennie Road development whose design brief was 2 storeys with the occasional 3rd, but resulted in 3 storeys with the occasional 4th. Is this now the CDC ruling for building height and bulk?

Attachments:

Comment

Local Plan Review: Preferred Approach 2016-2035

Representation ID: 2051

Received: 07/02/2019

Respondent: Homes England

Representation Summary:

Homes England is concerned that the wording within Policy AL5 doesn't give planning certainty to the delivery of the site.

Policy AL5 in its current format doesn't give the clarity to Homes England that the principle of residential development on the Police playing fields is acceptable. When the proposal is progressed to pre-application and formal application stage local stakeholders, statutory undertakers and decision makers (including elected Members and development management officers) may take the view that loss of open space on the Police playing pitches would be contrary to Council's local evidence base and Policy AL5 (in its current format).

Full text:

Homes England would like to thank Chichester District Council for the opportunity to comment upon the 'Local Plan Preferred Approach 2016-2035' consultation. Homes England acknowledges the crucial role of this local plan document in the evolution of forward planning policies pursuant to Chichester and in its intention in promoting positive sustainable growth in the wider District and principally, to achieve the sustainable development objectives set out within the National Planning Policy Framework (NPPF).
As a major landowner/delivery partner within the District, Homes England (formerly the Homes and Communities Agency) strongly support the redevelopment opportunities within Chichester Town Centre referred to as the 'Southern Gateway' (Policy AL5). This strategic allocation will help Homes England to fulfil its remit to facilitate delivery of sufficient new homes, where they are most needed and to deliver a sustained improvement in affordability. Homes England is committed to early delivery on this site and is keen to commence formal pre-application discussions when appropriate.
The following representations are related to matters of detail and should not be read as an objection to the plan as a whole. In most cases we are seeking minor modifications that will provide greater flexibility and clarity for the delivery of the site(s). The modifications proposed within this representation would help to make Policy AL5 sound and allow Homes England to meet our remit of increasing the number of new homes that are built in England and support the Government's objective of significantly boosting the supply of new homes in accordance with Paragraph 59 of the NPPF.

Policy AL5- Retention of Open Space
As mentioned above, Homes England is a key landowner and delivery partner of the Southern Gateway allocation strategy. This includes the delivery of development opportunity 4: 'Land at the Police Station and High School', as referred to in the Chichester Southern Gateway Masterplan 2017 document.
The Masterplan details the development potential of the site(s), which has the capacity to deliver 144 residential units, with a mix of town houses and apartments.
The site includes a significant area of green 'open space' facing Kingsham Road, as outlined in the Masterplan (paragraph 3.54); this area of open space has been used by the Police as a playing pitch, but has not been in public use. Page 64 of the Masterplan details this by outlining that the pitch is now unused and is surplus to requirements by the Police. The eastern half of the site forms the now unused High-School buildings and all-weather pitch, which is owned by West Sussex County Council and is leased to the High School. The all-weather pitch is still in use and is used by the school and a number of sport clubs in Chichester.
Draft Policy AL5 details that a future planning application will need to provide an
appropriate provision of open space, whilst also stating that the existing playing pitch should be retained or at least re-provided off-site (point 5);
- Provision of open space in accordance with Policy DM34, including retention of the existing playing pitch unless suitable re-provision is provided.
Homes England is concerned that the wording within Policy AL5 doesn't give planning certainty to the delivery of 'Land at the Police Station'. Further to this, the Council's 'Playing Pitch Strategy: Final Strategy 2018' document, which is part of the Council's Local Evidence base for the Local Plan, states within Paragraph 4.12, 'the former police station playing field should be replaced by equivalent, appropriate provision when the site is redeveloped'. This is despite the fact that the site has been left unused for a number of years and has not been available for public use. Homes England's understanding is that the Council consider the Police playing fields, as open space not public open space.
This is acknowledged in the supporting text of Policy AL5 paragraph 6.41, which
refers specifically to the 'all weather playing pitch';
'The site currently accommodates an all-weather playing pitch which has previously been accessible for public use. If this playing pitch is redeveloped, suitable re-provision should be made in accordance with Policy DM34 of this Local Plan Review.'
Consequently, Policy AL5 in its current format doesn't give the clarity to Homes England that the principle of residential development on the Police playing fields is acceptable. When the proposal is progressed to pre-application and formal application stage local stakeholders, statutory undertakers and decision makers (including elected Members and development management officers) may take the view that loss of open space on the Police playing pitches would be contrary to Council's local evidence base and Policy AL5 (in its current format).

For the avoidance of doubt, Homes England requests that Policy AL5 be amended to give greater clarity that re-provision is only applicable to the allweather pitch. Accordingly, point 5 should be re-worded to the following;
- Provision of open space in accordance with Policy DM34, including retention of the existing all weather playing pitch at Chichester High-School unless suitable re-provision is provided.
Homes England considers the revised wording, albeit small, necessary to avoid any potential delays in the design, consultation, application stage and the delivery of the Southern Gateway. In addition, Homes England believes that the Council should also consider revisions to paragraph 6.41 to include commentary on the reasons why the retention or re-provision of the lost open space on the Police site is not necessary. This would further support the re-development of the site and the delivery of up to 144 residential units.

Summary
In summary the proposed amendments would greatly assist Home England's efforts in delivering a key site that is within public ownership and capable of early delivery. Homes England would be pleased to discuss these representations in greater detail in advance of the formal commencement of the pre-application process and examination in public.

Attachments:

Comment

Local Plan Review: Preferred Approach 2016-2035

Representation ID: 2085

Received: 15/02/2019

Respondent: West Sussex County Council

Representation Summary:

Minerals and waste:
Reference should be made to the mineral infrastructure safeguarding policy M10 as within 200m of the Chichester Railhead.

Full text:

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.

Attachments:

Comment

Local Plan Review: Preferred Approach 2016-2035

Representation ID: 2124

Received: 15/02/2019

Respondent: West Sussex County Council

Representation Summary:

Education:
- sufficient space/expansion capacity to accommodate the child product from 350 dwellings
- consideration to the cumulative impact of housing in AL6 to allocate land within the area for a 1FE-2FE primary. Pro rata financial contributions towards the build costs would be sought from developers to mitigate their impact.

- expansion capacity to accommodate secondary aged pupils. Contributions would be required for expansion of secondary schools if feasible and required.

- 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.

Full text:

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.

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