Policy AL6: Land South-West of Chichester (Apuldram and Donnington Parishes)

The allocation of this site presents a significant opportunity to address the congestion of the Fishbourne and Stockbridge junctions of the A27. Both junctions are over capacity and Stockbridge in particular creates a barrier to / from the Manhood Peninsula whilst also creating air and noise pollution issues close to a heavily populated area.

There is an opportunity to construct a new grade separated junction within the northern part of the allocated site to provide dedicated access from the Manhood Peninsula and the A259 Fishbourne road to the A27 combined with the link road.

This could remove the need for the Stockbridge junction to operate as a roundabout and reduce significantly the traffic using the Fishbourne roundabout to access the A27.

There is an opportunity for CDC to consider the proposed minor upgrades to the A27 junctions in a wider context and to work with Highways England to develop a phased approach to a wider and more long term improvement through developer funding and RIS funding.

Your policy DM8 states that any development must minimize and not create or add to problems of highway safety, congestion , air pollution or other damage.

I have been involved since the early 1980's in Sussex traffic issues, including the A27 Forum and I predicted that the BABA27 result would not be successful. The Conservative Government have not spent money in Sussex for decades and there has been little done since the Brighton Bypass. I believe from experience that there is a policy, or a non written agenda that money will not be spent on the south's transport infrastructure. It is time they were honest. London, Runcorn, the motorways and the north billions, the south nothing! This lack of investment brings the actual and proposed increase in housing and transport problems into sharp focus.

I have looked at the range and planning verbiage in the review, and it is so wide ranging that for any individual or Parish Council to assimilate and prepare a full response would be very difficult given the ridiculous time constraint. I can only give a snapshot of my thoughts, without any real evidence as back up. Given that you must have taken a very long time to write a wish list of properties to be built without much evidence either, this is may be acceptable.

The areas of objection for Fishbourne, Bosham and Chidham are considerable, but I will concentrate on the traffic and access problems set out by statements in the main Plan, and an assessment of the proposed Bethwines development.

I set out my reasoning herewith:-

2.5 The A27 does not serve communities west of Chichester unless they use the A259 as a feeder road. We all know about the congestion and danger of Fishbourne Roundabout now.

2.13 There are no major employers in Fishbourne making travel to work a necessity.

2.29 I have to ask what employment needs? What employment? Much of this document must be speculation and entirely subjective. There is no employment in Fishbourne, and no plans to provide it, and no one I know can see where the employment will be unless the new resident travels a considerable distance - using the A259 to access the A27.

Where are you going to create new open space? The open space currently exists as a buffer between villages but this report is actually planning to take it away. Views from Apuldram to the Cathedral, and the loss of the buffer zone west of Fishbourne. Your statement on the preservation of landscapes is therefore ridiculous set against the building of houses on current landscapes and views.

3.2 This is all speculative. Where is the evidence of local need, demography and transport. It is not set out in this document.

3.6 How can this conserve and enhance local distinctiveness? It is unsupported verbal junk. The impact of such huge traffic increases on the A259 cannot be over emphasized. This Local Plan report will seek to add to the problem already agreed from the increase of 1600 houses currently in the expansion development to the west of the City, and the proposed 100 houses and commercial development south of the A27.

3.7 Fishbourne is designated as a service village. The definition is that the village can provide a reasonable range of basic facilities, or have reasonable access to nearby facilities. Fishbourne has no facilities being wholly residential, in fact only two pubs and the Fishbourne Centre. Reasonable access - This is not so due to huge traffic problems currently on the A259 accessing the Fishbourne roundabout which will greatly deteriorate given the building scale. The 700 bus is excellent, but it is nationally accepted that unless a bus stop is within 400 metres of the house, residents will not use it. The 56 bus runs every one and a half hours up Salthill Road but will again still be out of reach of Bethwines residents. The railway provision is a halt, not a station, and only has one train an hour in each direction, and again is out of reach of Bethwines development.
We also need to add the destructive effects of pollution if we have miles of standing traffic in Fishbourne and on the A27 west of the city.

6.49 Development south of the A27 between Stockbridge and Fishbourne.

I am very aware of the history of Fishbourne roundabout, which was a disaster from its initial construction. It was proved then to the Agency that it was possible to negotiate the roundabout east/west at 70mph, and is still the same. The Highways Agency of course would not agree to their error despite proof, but they have left this over stretched and dangerous roundabout as their legacy to us.

Any attempt to add a further junction from a link road onto the current A27 Fishbourne roundabout must be rejected. There will still be huge obstruction to A259 eastbound gaining access onto the roundabout as it struggles now, but if an additional junction is given precedence over A259, entry to the roundabout will be even more clogged and more dangerous. Not only will Fishbourne traffic be required to give way to growing A27 westbound traffic, it will also have to give way to traffic from any proposed new link from the south. The only possible alternative to a grade separated junction is a signalized and re-created hamburger roundabout. We all know that signals will improve safety, but would never cure the future serious congestion. Even if the dangerous traffic problems on the roundabout are mitigated by signalisation, the congestion will remain heavy and excessive. The huge proposed increase in traffic along the corridor will make this junction unusable with consequences to surrounding minor roads such as Salthill Road, Clay Lane, Funtington Road and Hunters Race.

6.54 The development at Highgrove Farm, Bosham where 250 homes are planned will also reduce the strategic gap between Bosham and Fishbourne and impact upon the A259.


Bethwines development Traffic problems.

The previous application for Bethwines development submitted a transport plan that was frankly ludicrous. Such suggestions as car sharing and extensive use of cycling/walking would never work to reduce regular car use out of the village.

Public transport is not a viable option for the new estate unless a new bus route was created, or the 56 diverted, and I doubt that this is an option. The 700 bus route along the A259 is too distant.

Traffic will therefore have to access the new development via Blackboys Lane.

Blackboys Lane at the south end is narrow, with ditches either side and properties closely border the roadway. The exit onto the A259 is narrow with limited visibility, and an exit almost impossible with the proposed traffic flow. North of the railway crossing the road is open and wider, but leads to Clay Lane that is itself not satisfactory for this growth in car use. Road upgrades would be necessary and roads such as Halfrey Road would have a significant increase in rat run traffic .

The junction of Clay Lane and Salthill Road, and Salthill Road and the Funtington Road would need an assessment using current models to establish the correct junction control. The Funtington Road/Salthill junction has very poor visibility. The narrow Clay Lane throughout it's length to Fishbourne Road East, that is a 20mph residential road would also need to be upgraded including pavements and/or cycle routes.

It is inevitable that Salthill Road, Hunters Race and Clay Lane would become a popular route out of the area. It is over stretched now with the road surface deteriorating quickly especially in Lavant.


The A27 and A259

There has been no time to establish current traffic flows on the A259, but as we all know, the congestion to Fishbourne Roundabout is often back to The Woolpack, and encourages the use of Salthill Road out of the village. The A27 daily has six miles of standing traffic eastbound in two lanes to Fishbourne roundabout

The transport corridor is not effective now let alone with the 2250 houses you are suggesting along the corridor between Chichester and Southbourne. 2250 houses mean 4500 cars, established by a study of Flavian Fields development at Fishbourne. This showed that there were two cars per household, 35% of adult residents in the Flavian Fields development do not work, that means that 65% do work and have to travel to employment outside of the village, and must apply equally to Chidham, Bosham and Southbourne. This also takes no account of the fact that mothers will transport their children to school by car. These schools will be outside of the villages due to an already full Fishbourne and Bosham School and the only secondary school at Southbourne being further away than Chichester schools. It has been established that Fishbourne already has the highest car dependency in Chichester District.

Specifically for the A259 between Chidham and Fishbourne roundabout, the huge growth of 1000 houses in Fishbourne, Bosham and Chidham, amounts to 2000 additional cars that will use the A259. I would anticipate that these villages will use Chichester for employment, schools, access to the A27 and facilities. The 1250 houses in Southbourne will further complicate the numbers, but some will probably travel westbound for services.

National statistics reveal that at least half of those additional cars from our villages will use the A259 the only feeder road for travel at peak time to work. The average length of a family car is now 4.8 metres. Allowing for about a one metre+ gap between them, 1000 cars need a stationery road space of about 6000 metres or Fishbourne roundabout to Chidham if lined up. That is a staggering fact, and no thought has been given to this problem in the planning strategy, exacerbated by the lack of an upgraded A27.

This must now be a factor in responding to the Government's demand for housing in this narrow area as I repeat your policy DM 8

'any development must minimize and not create or add to problems of highway safety, congestion , air pollution or other damage.'

This policy cannot be fulfilled!!

The AL6 link road and commercial development site flies in the face of climate change resilient planning.It is adjacent to internationally designated habitat sites, crosses Flood Zones 2& 3 and degrades significant views of cathedral and Downs from harbour, marina, Salterns Way and A286.As such is contrary to CDC's own ICZM policy. The environmental, social and economic harm to the tourist industry completely outweighs any (unproven and short term) benefit.Directing more Manhood traffic off the A27 and onto the A286, the most congestion prone road in the district, is an unsound strategy.

This development site is not climate change resilient and is contrary to NPPF and ICZM.It is adjacent to internationally designated habitat sites,crosses Flood Zones 2& 3,harms significant views of cathedral and Downs from harbour, marina, Salterns Way and A286.The site is physically removed from residential and other business areas and environmental, social harm and economic harm to tourist industry outweighs any benefit.The link road directing more local traffic off the A27 and onto the A286, the most congestion prone road in the district, is an unsound strategy.There are better sites for commercial development eg motor circuit noise buffer zone.

On Policy AL6: Land South-West of Chichester (Apuldram and Donnington Parishes)
* The Chichester Society supports this new policy, and its land allocation.

I approve fully the use of this parcel of land for light industry and housing as it will offer employment for the Manhood Peninsula without a long and difficult commute.

The Link Road is essential

Agree with Point 5 if site is to be developed.

I think it would be a good thing to have a new link road to bypass Donnington .I am in favour of this plan.

The views of the Cathedral from the South West of the city should also be protected

I am not supportive of the proposed link road. I also believe that the development is in flood plain.

There is room for some development in this area, especially immediately south of the A27, however scale of the proposed developments do not seem to be compatible with the stated aims.

Because of the flood plain, the road would have to be elevated, destroying the iconic view of the cathedral that the Plan elsewhere says it will protect.

You do realise the River Lavant runs through the area as two rivers joining as one.
A drainage ditch runs under the Fishbourne Roundabout.
There is no easy way to get across the A27 by foot to reach the train station.
That a link road would deliver more traffic from the peninsular directly to Fishbourne Roundabout and block the Fishbourne, Portsmouth and Chichester exits.

I am aware that CDC is currently consulting on plans to further develop the Donnington & Apuldram Parishes of Chichester.
Having read the information, I must express my OBJECTION to the proposed plans.
The previous plan was overwhelmingly rejected by local residents and this 'new' plan addresses NONE of the objections.
There has been NO improvement of services to people of the Parishes and on the Manhood peninsula in terms of schools, GP and dental service and yet further housing is planned. There is more & more traffic coming into Chichester & the A27 and now you are proposing NO right turn at the Donnington roundabout.
Do you have no idea how congested this area is already, plus the Tesco's roundabout ? Your plan will only make the situation worse in terms of traffic congestion apart from the unfairness of not being able to turn right.

Resident, Donnington Parish.
The proposals contained under AL6 are an attempt to re-instate by the back door elements of Option 2 ( the Stockbridge Link Road) and Option 3A ( no right turns at the Stockbridge roundabout on the A27) of the Chichester Bypass Improvement Scheme. Both these options were rejected then at the consultation stage and are no more acceptable now.
There are a number of specific points I would like to make in support of my objections to the proposals contained in the Local Plan Review:

● Donnington residents will be hugely disadvantaged by proposed changes to A27 access arrangements under Policy S23 and the Peter Brett Associates report - effectively no access to the East from Donnington (or the Manhood Peninsula) via A27 unless residents either head West first, encountering the amended Fishbourne Roundabout which will prioritise through traffic and will include an additional junction. Alternative routes to the East are either through the City or via unsuitable "back roads", increasing traffic levels through Hunston and North Mundham. Increased traffic from Whyke (facing the same issue) will cause even more congestion between Donnington and Fishbourne.
● Site AL6 Land South West of Chichester (Apuldram and Donnington parishes) includes a flood plain. Using data from CDC's flood plain assessment, the average height of flood water on the River Lavant is 2.05 metres (6.07 feet) above datum (sea level). This means that the road will have to be elevated by at least 2.5 metres and more with the supporting structures and road thickness itself. Therefore nearer 4 metres (13 feet). This would destroy the iconic views of the cathedral framed by the South Downs. The protection proposed by para 3 of Policy AL6 is unachievable. REMOVE POLICY AL6
● Each of the five junction modifications will require three years of work. This means 15 years of misery for Chichester residents whilst the junction works take place. We all remember the chaos caused by the replacement of one footbridge in Stockbridge, bringing gridlock to the area. (Policy S23 and Peter Brett Associates Transport Assessment)
● Overall, the plans for improvements to the junctions are to the advantage of through traffic not local residents. The proposals bear a marked similarity to Option 3a from the Highways England Improvements to the Chichester A27 Bypass consultation, which were emphatically rejected by the local community - in Donnington and across the whole of Chichester. (Policy SP23 and Peter Brett Transport Assessment)
● Air Quality will further deteriorate as a result of the proposed plans. Stockbridge already exceeds the recommended air quality levels and development on this scale will increase the problem. This has serious health implications for residents. (Policy DM24 & SP28)
● The South Downs National Park should take its allocation of 41 dwellings per annum - without some low level development in the Park, particularly social housing, communities there will not thrive. (Policy S3, Policy S5 & Policy S19 )
● There are no proposals for any new primary schools in the Manhood Peninsula. This will only increase pressure on current schools to provide more places, and lead to increased traffic on the roads as parents are forced to commute to schools outside their local area where spaces may be available.
● Impact on ecology - the Chichester Harbour and surrounding area are designated as an Area of Outstanding Natural Beauty and have the status of being a Special Protection Area, Special Area of Conservation, Site of Special Scientific Interest and is a Ramsar site. It is wholly inappropriate to consider development on this scale in such close proximity to an area with this status. There will be a significantly adverse impact on the ecology of the area and mitigation is not sufficient. (Policy S18 Integrated Coastal Management Zone Manhood)
● Green tourism is a very important part of the Manhood Peninsula economy and to overdevelop and spoil the natural environment which attracts this trade would be inappropriate and hugely detrimental (Policy S18 Integrated Coastal Management Zone Manhood)
● A viable alternative site is available for industrial development within the buffer zone at Goodwood and the employment land should be allocated there. (Policy AL6, S15, S16)
As well as the above points which directly and negatively impact on Donnington residents and with reference to the proposals contained in AL6:
There is currently no direct access from the area delineated by AL6 and Chichester City Centre over the A27 or any proposals in the Plan for such a direct route. The traffic generated under AL6 proposals will add considerably to existing severe congestion and delays on the existing the A27.
The AL6 proposals do not seem to have been considered with reference to any future road improvement schemes proposed by Highways England. As the A27 is a strategic route, the effect of the proposals under AL6 will inevitably impact on future HE plans concerning on- line improvements to this route. No consultation with HE seems to have been considered or taken place concerning this critical area and the effect on traffic flows, pollution, delays to local traffic etc.

The site now called AL5 'South West Chichester' has been proposed in previous CDC Local Plans including the need for a Stockbridge Link Road. The previous site details identified sufficient capacity for 750 houses under the reference SL164. It is not clear why such a large allocation has been made for business use and why only 100 houses are included in this draft reveiw. The allocation should be for 750 houses at 'West of Chichester' and the allocation of an additional 300 houses at Tangmere should be removed.

This area is already close to a highly populated area of Donnington which is extremely congested, it also next to an area of AONB. More houses and business can only lead to more gridlock, more pollution and more unhappy and unhealthy residents and the impact on wildlife. Even with a well built and environmentally mitigated link road, I feel this land should be used promote clean energy e.g solar panels or left as it is as environmental corridor. Land in the buffer zone around Goodwood or Westhampnett is less congested and has better transport links and are less environmentally challenging.

Elevating the road would destroy the iconic views of the cathedral

-no mention of Flood zones 2 and 3 with significant risk of flooding; see Policy S27, sequential test, exception test, DM18, 8 and 16 metres fluvial and coastal flood risk setback distances, etc;
no mention of Flood Risk Assessment and EA requirements.
-Para 5.54 in Flood Risk and Water Management section referring to coastal and fluvial flood risk states .'.. development needs must be strongly resisted in areas at risk of flooding.'
-no detail provided of Stockbridge link road and river bridge
-need to raise previously proposed link road estimate by 1 metre; after imminent publication by EA of revised 100 year sea level rise forecast, further raise will likely be required
- link road interference with views to Cathedral and Downs
-no mention of AONB buffer zone as previously required
-works are a major development within impact area of AONB and its SSSI and designated sites: raises obligations under NPPF and Rural Communities Act 2006 coupled with requirement to consult with Harbour Conservancy
-no evidence that CDC is having 'regard to the purpose of the AONB' as required under the PROW Act 2000 Section 85
-link road is part of earlier Option 2 which received very low acceptance
-why is there a requirement for a 'strategic open space and a managed country park' -these are not defined in the Glossary.
-33 hectares of employment land is postulated in this Policy; three times what is required to satisfy the 2035 HEDNA estimate in Policy S8 for 231,835 sq.m (or 23.2 ha) of additional floor space for employment: taking into account Para 4.52: 6 ha in AL1; 4 ha in AL 2, and 2.4 ha in AL 15, i.e. total of 12.4 ha, leaving 11 ha to be identified-not 33 ha; additional 11 ha can be distributed over other sites with better connections not requiring new road-see also entry under Meeting Business and Employment Needs paras 4.56 and 4.57
100 homes can also be redistributed elsewhere;
Stockbridge link road, introduced at late stage of PBA work,and justified by introduction of excess employment space and housing, should be removed from :Local Plan Review.
AL 6 is one of several strategic sites missing from the development location assessments in the Appendix of the Sustainability Appraisal document.

This area was previously excluded from development plans (December 2016 Report: Site Allocation: Proposed Submission Development Plan Document 2014-2029 Methodology and Assessment - Table 9.1 P 40)

Reasons include:
The likelihood of flooding in an area with risk Zones 2/3a/3b (December 2018 Report: Strategic Flood Risk Assessment and October 2018 Report: Sustainability Appraisal for the Chichester Local Plan Review -Preferred Approach)
The proximity to and detriment of the AONB, wildlife etc.
The negative impact on many of the most important views of Chichester Cathedral (April 2005 Report: The Future Growth of Chichester - Landscape and Visual Amenity Considerations)

The Sustainability Appraisal in November 2016 states: "Overall this site has the most negative impacts and the fewest positive of all the Chichester options."

If there is to be any meaningful consultation on the development of this site, CDC needs to be clear about the reasons it has changed its view since previous iterations of the Local Plan.

There are viable alternative sites for these developments as cited in Policies S15 & S16 of the Local Plan.

This area is very attractive rural land, and contributes to the adjacent AONB and harbour. Whilst a strip of land adjacent to the A27 could be suitable for employment uses, the area to the south should not be developed for environmental reasons and harm to the AONB. 33 hectares of employment plus housing and new road would radically change the area. Provision of a country park sounds potentially good, but doesn't seem compatible with the amount of proposed development.

I have been studying your proposals in the Local Plan 2035. It does seem to me that this seems remarkably like the rejected route Option 3A. This seems to benefit through traffic rather than local traffic.

Air Quality at the Stockbridge roundabout is already bad, this can only make it worse.

We all remember the trouble caused by the work on the footbridge over the Stockbridge roundabout, having continuous and more serious work as envisaged by this plan will make travel in/through Chichester terrible for years.

There are no proposals for extra schools on the Manhood peninsular, school traffic is already a major contributor to traffic jams and poor air quality, this can only make it worse.

I understand that there is an alternative site within the buffer zone at Goodwood and the employment land should be allocated there.

Can I also ask will you be building on a flood plain?

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.

Resident of West Wittering
An ill thought through plan. This development will do untold damage to the AONB and it will clearly remove view of the cathedral when driving into Chichester and when walking along footpaths and lanes within the AONB.

It should also be noted that this area is on the Manhood Peninsula and should be treated as part of the Peninsula.

This area includes a flood plain. CDC's own data indicates that any road will need to be elevated by nearly 4 metres to avoid flooding by the Lavant destroying the heritage views of the Cathedral which attracts som nay to the area and gives such pleasure to residents.

Building on a flood plain very sensible idea! Why build in this area?
Fishbourne and Donnington would become one BIG settlement they would merge together. The capacity at Apuldram Waste Waster is already high. There are so many houses being built at the moment that it will not cope with more.
All these new houses, Industrial Units etc. will all will be using the A27 at some stage. It is damaging and detrimental to our quality of life having all this pollution coming from the A27.

Dell Quay Sailing Club (DQSC), is a volunteer members club (700 plus members), situated at Dell Quay in the Area of Outstanding Natural Beauty (AONB) of Chichester Harbour providing organised competitive and recreational water borne activities for members aged 5 to 70 plus years, with other members taking to the water in their own vessels, some children younger than 5 years of age. This submission is made by the Directors of DQSC.

The proposed Adopted Plan areas all combine to further increase the infrastructure pressures in the area. The proposed development at AP/AL6 the fields between Apuldram Lane and the Stockbridge, are of particular concern to DQSC. However, when combined with existing planned expansion (Fishbourne, Southbourne and Chichester) the impact on the area as a whole will be enormous affecting the Sites of Special Scientific Interest (SSSI), AONB, wildlife habitats, road congestion, pollution (noise/light), and air quality.

The proposed adopted plan raises specific concerns with DQSC membership namely: infrastructure to support waste treatment/run off water, local flooding, traffic management on minor roads, the effects on the SSSI, the AONB and habitats will adversely affect the area. The greatest concerns are the quality of water within Chichester Harbour where members swim or race/sail in small boats that regularly capsize (potential Public Health Issues) and the effects of more vehicle traffic and limited facilities within the AONB to accommodate increased numbers of people and recreational (e.g. walkers/pedal bikers) users.

Sewage Treatment and Waste Water Disposal.
DQSC has particular concerns about the proposed development at AP6 the details of which are unclear as the impact on the sewage process works is described as "untested" in the report. Currently it is well known that the Apuldram waste water treatment cannot cope with the existing volume that is sent to it with lorries taking some effluent to other processing facilities and regular storm discharges into the SSIs 24, 27, 29. 30 and 31 (Ref https://magic.defra.gov.uk/magicMap.aspx) which are returned on the incoming tide and settle on the mud. The areas shown below are those affected and the state of those areas is shown in the table (copied from the defra.gov.uk website) below in which it states that the areas that are covered by the tide waters are "Unfavourable - Recovering" and to add further to any pollution from waste would be detrimental to the recovery of the eco systems affected.



027
27 MUD Unfavourable - Recovering Medium LITTORAL SEDIMENT 51.3959 SU 833 031 View map

028
28 Favourable No identified Condition Threat NEUTRAL GRASSLAND - Lowland 5.4059 SU 833 035 View map

029
FISHBOURNE SWAMP Unfavourable - Recovering Medium FEN, MARSH AND SWAMP - Lowland 6.4553 SU 836 044 View map

030
FISHBOURNE CHANNEL MUD Unfavourable - Recovering Medium LITTORAL SEDIMENT 33.1731 SU 837 036 View map

031
COPPERAS POINT Unfavourable - No change Medium LITTORAL SEDIMENT 49.3458 SU 830 020 View map

045
NON-SAC GRASSLAND SW OF FISHBOURNE Favourable No identified Condition Threat FEN, MARSH AND SWAMP - Lowland 3.5043 SU 832 038 View map


Any discharges from the Apuldram Treatment works directly affect Dell Quay Sailing Club as they flow past Dell Quay and affect the water quality in the area within which we organise on water activities and the general public visit. In the past 10 years DQSC has complained via the Chichester Harbour Conservancy to the Environment Agency who have attended and taken samples of the harbour water.

Recommendation
Further Sewage and Waste Water treatment plants need to be incorporated in the development plan.

Flooding. Nothing in the report assures DQSC that this has been considered and the effects that development will have on the increased likelihood of flooding affecting the site. The proposed development at AP/AL6 the fields between Apuldram Lane and the Stockbridge are on the FLOOD PLAIN for the river Lavant and any development their can only further increase the risk of flooding properties or if suitable drainage is installed only move the problem further down river or into Chichester Harbour either through the Waste Water Treatment plant at Apuldram (more storm water discharges) or by direct drainage which again will impact the SSSI (noted above) and the ensuing effect on water quality in the harbour.

The picture below shows the fields below the Water Treatment Plant at Apuldram and was taken from the Apuldram Lane looking towards Chichester Harbour however the fields the other side (the flood plain for the Lavant could not be seen due to the height of the hedge) this shows how great the problems could be now let alone what would happen if the flood Plain was built over.


Recommendation
There should be no development in the area designated AP/AL6.

Roads and Transport.

1. The proposed link road running from the Fishbourne roundabout to the Birdham road new roundabout. This is likely to have to be an elevated road to deal with the Lavant flood plain and so will increase light, noise and pollution near the AONB and interfere with natural habitat and wildlife movements interrupted. The proposed junctions for this link road will create more congestion on the A27 Fishbourne Roundabout and a choke point on the Birdham Road. This will further exacerbate the use of Apuldram road as a rat run - people will see congestion on the Fishborne Round about or at the roundabout on Birdham Road and then use Appuldram Road as a means of avoiding the congestion.

2. DQSC have concerns over the proposals for development west of Chichester including Apuldram, Fishbourne and Southbourne. All of these extra houses will have an impact on the A259 junction at Fishbourne and will further exacerbate the problems on the Apuldram road.

3. Lack of public transport to the areas surrounding the proposed developments.

Recommendation -

DQSC recommends that other alternative options are considered for access to developments in Southbourne and Fishbourne, possibly a suitable junction onto the A27 in both directions between Southbourne and Fishbourne.

Any correspondence or future questions should be sent to the Hon Secretary DQSC for representation to the membership of Dell Quay Sailing Club.

I am a resident of Donnington and am disappointed with the ridiculous scheme which you are proposing. In addition, I have not the slightest confidence that the scheme will be completed within budget and on time. The footbridge at the Stockbridge roundabout was a fiasco and if you cannot complete such a relatively small project, I am not convinced any of you are capable of taking on a much larger scheme.

I agree with all of our parish council recommendations and comments below.

DONNINGTON PARISH COUNCIL OBJECTIONS
Donnington residents will be hugely disadvantaged by proposed changes to A27 access arrangements under Policy S23 and the Peter Brett Associates report - effectively no access to the East from Donnington (or the Manhood Peninsula) via A27 unless residents either head West first, encountering the amended Fishbourne Roundabout which will prioritise through traffic and will include an additional junction. Alternative routes to the East are either through the City or via unsuitable "back roads", increasing traffic levels through Hunston and North Mundham. Increased traffic from Whyke (facing the same issue) will cause even more congestion between Donnington and Fishbourne.
* Site AL6 Land South West of Chichester (Apuldram and Donnington parishes) includes a flood plain. Using data from CDC's flood plain assessment, the average height of flood water on the River Lavant is 2.05 metres (6.07 feet) above datum (sea level). This means that the road will have to be elevated by at least 2.5 metres and more with the supporting structures and road thickness itself. Therefore nearer 4 metres (13 feet). This would destroy the iconic views of the cathedral framed by the South Downs. The protection proposed by para 3 of Policy AL6 is unachievable. REMOVE POLICY AL6
* Each of the five junction modifications will require three years of work. This means 15 years of misery for Chichester residents whilst the junction works take place. We all remember the chaos caused by the replacement of one footbridge in Stockbridge, bringing gridlock to the area. (Policy S23 and Peter Brett Associates Transport Assessment)
* Overall, the plans for improvements to the junctions are to the advantage of through traffic not local residents. The proposals bear a marked similarity to Option 3a from the Highways England Improvements to the Chichester A27 Bypass consultation, which were emphatically rejected by the local community - in Donnington and across the whole of Chichester. (Policy SP23 and Peter Brett Transport Assessment)
* Air Quality will further deteriorate as a result of the proposed plans. Stockbridge already exceeds the recommended air quality levels and development on this scale will increase the problem. This has serious health implications for residents. (Policy DM24 & SP28)
* The South Downs National Park should take its allocation of 41 dwellings per annum - without some low level development in the Park, particularly social housing, communities there will not thrive. (Policy S3, Policy S5 & Policy S19 )
* There are no proposals for any new primary schools in the Manhood Peninsula. This will only increase pressure on current schools to provide more places, and lead to increased traffic on the roads as parents are forced to commute to schools outside their local area where spaces may be available.
* Impact on ecology - the Chichester Harbour and surrounding area are designated as an Area of Outstanding Natural Beauty and have the status of being a Special Protection Area, Special Area of Conservation, Site of Special Scientific Interest and is a Ramsar site. It is wholly inappropriate to consider development on this scale in such close proximity to an area with this status. There will be a significantly adverse impact on the ecology of the area and mitigation is not sufficient. (Policy S18 Integrated Coastal Management Zone Manhood)
* Green tourism is a very important part of the Manhood Peninsula economy and to overdevelop and spoil the natural environment which attracts this trade would be inappropriate and hugely detrimental (Policy S18 Integrated Coastal Management Zone Manhood)
* A viable alternative site is available for industrial development within the buffer zone at Goodwood and the employment land should be allocated there. (Policy AL6, S15, S16)

I am a resident of Donnington and am disappointed with the ridiculous scheme which you are proposing. In addition, I have not the slightest confidence that the scheme will be completed within budget and on time. The footbridge at the Stockbridge roundabout was a fiasco and if you cannot complete such a relatively small project, I am not convinced any of you are capable of taking on a much larger scheme.

I agree with all of our parish council recommendations and comments below.

DONNINGTON PARISH COUNCIL OBJECTIONS
Donnington residents will be hugely disadvantaged by proposed changes to A27 access arrangements under Policy S23 and the Peter Brett Associates report - effectively no access to the East from Donnington (or the Manhood Peninsula) via A27 unless residents either head West first, encountering the amended Fishbourne Roundabout which will prioritise through traffic and will include an additional junction. Alternative routes to the East are either through the City or via unsuitable "back roads", increasing traffic levels through Hunston and North Mundham. Increased traffic from Whyke (facing the same issue) will cause even more congestion between Donnington and Fishbourne.
* Site AL6 Land South West of Chichester (Apuldram and Donnington parishes) includes a flood plain. Using data from CDC's flood plain assessment, the average height of flood water on the River Lavant is 2.05 metres (6.07 feet) above datum (sea level). This means that the road will have to be elevated by at least 2.5 metres and more with the supporting structures and road thickness itself. Therefore nearer 4 metres (13 feet). This would destroy the iconic views of the cathedral framed by the South Downs. The protection proposed by para 3 of Policy AL6 is unachievable. REMOVE POLICY AL6
* Each of the five junction modifications will require three years of work. This means 15 years of misery for Chichester residents whilst the junction works take place. We all remember the chaos caused by the replacement of one footbridge in Stockbridge, bringing gridlock to the area. (Policy S23 and Peter Brett Associates Transport Assessment)
* Overall, the plans for improvements to the junctions are to the advantage of through traffic not local residents. The proposals bear a marked similarity to Option 3a from the Highways England Improvements to the Chichester A27 Bypass consultation, which were emphatically rejected by the local community - in Donnington and across the whole of Chichester. (Policy SP23 and Peter Brett Transport Assessment)
* Air Quality will further deteriorate as a result of the proposed plans. Stockbridge already exceeds the recommended air quality levels and development on this scale will increase the problem. This has serious health implications for residents. (Policy DM24 & SP28)
* The South Downs National Park should take its allocation of 41 dwellings per annum - without some low level development in the Park, particularly social housing, communities there will not thrive. (Policy S3, Policy S5 & Policy S19 )
* There are no proposals for any new primary schools in the Manhood Peninsula. This will only increase pressure on current schools to provide more places, and lead to increased traffic on the roads as parents are forced to commute to schools outside their local area where spaces may be available.
* Impact on ecology - the Chichester Harbour and surrounding area are designated as an Area of Outstanding Natural Beauty and have the status of being a Special Protection Area, Special Area of Conservation, Site of Special Scientific Interest and is a Ramsar site. It is wholly inappropriate to consider development on this scale in such close proximity to an area with this status. There will be a significantly adverse impact on the ecology of the area and mitigation is not sufficient. (Policy S18 Integrated Coastal Management Zone Manhood)
* Green tourism is a very important part of the Manhood Peninsula economy and to overdevelop and spoil the natural environment which attracts this trade would be inappropriate and hugely detrimental (Policy S18 Integrated Coastal Management Zone Manhood)
* A viable alternative site is available for industrial development within the buffer zone at Goodwood and the employment land should be allocated there. (Policy AL6, S15, S16)

"Protect views" AL6 WILL DESTROY historic views of the only cathedral visible from the sea .You cannot mitigate a road that will be 4 mts in the air due to floodplain constraints ! There will be token green spaces left on floodplain. Unsuitable.How are you going to have sustainable modes of transport.No evidence in the past or now.4.98 PBA outdated(2010) Proved to be inaccurate and flawed. Useless including it.Funding from CIL, how much and where is the rest coming from.Evidence ?Unless this is addressed in future iterations of the plan will raise this with the examiner at the approriate time