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

The Council needs to remove from the Local Plan any development on areas such as AL6 which are identified by the Environment Agency as a floodplain and are untested for their suitability for development.

I am writing to Object to CDC Local Plan. The Plan as it stands , is not a Local Plan. It is a plan to destroy large areas of Chichester's historic and environmentally sensitive areas in the South, east and west,whilst leaving the Northern part of the city completely untouched. Chichester Harbour has the same protection afforded to as the SDNP and yet there has been absolute no regard to its preservation. In fact that exact opposite. The plan aims to build on the flood plain and right up to the Chichester Harbour boundary with no viable detail or acknowledgement of just how destructive this would be. The inclusion of AL6 Apuldram/Donnington link road and proposed development is tanter mount to vandalism of the highest degree and I am appalled that it is even being considered. The fact that there is no detail or consultation within the document to show the required consultation with Highways England that should have taken place prior to it's inclusion just shows what an inaccurate and shoddy piece of work this plan is. AL6 is on a category 3 Flood Plain that according the Governments own recommendations should never be built on because of the environmental damage that can ensue, never mind the risk to flooding of any buildings on such a site. The suggested link road would have to be raised to at least 4 mtrs in order to alleviate the risk of flooding this would then lead to a complete eyesore and desecration of historic views of the Cathedral from the sea (the only one in England ) towards the Downs, something that the Local Plan states must be protected at all cost. There is no mention of the increased traffic, air pollution, noise and light pollution that such a development would cause. Councillor Dignum has lied, " NOT...embracing any 2016 options for the A27", but this plan clearly has. Where is his integrity and impartiality ? I allege that he has shown time and again that he has a much greater interest in preserving the North to the detriment of all other areas of Chichester !!! AL6 should be removed with immediate effect.Unless this is adequately addressed in future iterations of the plan, then I will raise it with the examiner at the appropriate time.
The plan also fails to address/acknowledge the huge increase in traffic volume now and in the future. There is no viable transport data/ study included within the Plan. The only reference is the Peter Brett Assoc report which was issued in 2010 and has been shown to be incorrect. It is also now completely useless as it is so outdated and claims there is no risk of air pollution from vehicles. We all know that Chichester has one of the worst hotspots for car pollutants/air quality on the South coast. Unless this is addressed in any future iterations of the plan then I will raise this with the examiner at the appropriate time.
I OBJECT to the CDC Local Plan in its present form and unless the Plan is rewritten to take into account the huge inaccuracies and biased, in future iterations then I will be raising it with the examiner at the appropriate time.

Representation by Oliver James (Trustee) on behalf of The Apuldram Centre in respect of Policy AL6 - Strategic Site Allocations - Land South West of Chichester (Apuldram and Donnington Parishes).

1. I am making this representation on behalf of The Apuldram Centre, a local charity of which I have been a Trustee for 20 years. The Centre, which was established in 1989, provides day and supported living facilities for adults with learning disabilities. It is based on a former smallholding in Appledram Lane that it now owns and has developed over the years, and in respect of which planning permission was granted in 2017 for major improvements, the first phase being completed recently. It now provides day-care facilities for 67 people and supported living for 32 people, both at the Centre and in houses and flats in Chichester. We are also planning to further develop both aspects in the coming years.

2. The Centre, which has an area of about 1.3ha, is in a very pleasant rural, yet convenient, location on the east side of Appledram Lane, bounded by open fields and adjoining the Area Of Outstanding Natural Beauty (AONB). These facets enable Apuldram to provide a good and safe environment for all those using its facilities. The Trustees are, therefore, very concerned with the large development proposed in Policy SA6, which will effectively extend the Built-Up Area for Chichester right up to its boundaries and to the boundary of the AONB.

3. The Trustees appreciate, however, the need for additional housing and the requirement that the Government has placed upon the Council to provide it. They also understand the benefit of the link road that will be constructed as part of the proposed development.

4. The Trustees are very concerned at the effect that these proposals will have on the amenities at the Centre, and would ask your Council both to ensure that these are kept to a minimum and to liaise with the Centre to ensure that this is achieved. They are particularly anxious that the proposed link road is kept well away from the Centre, rather than on its boundary, as was at one time proposed, and that it is not elevated, as they have heard may be necessary on account of the propensity of the land to flooding and to which they would be totally opposed.

Proposals for AL6 are at odds with this policy. Distinctive local landscape character cannot be preserved if the link road is built.

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."

Site AL6 land south west of Chichester includes a flood plain. This means it is not suitable for housing or industrial development. The relief road would only be built with money from the housing development. How will the houses be accessed until the road is built? Similarly the industrial area.
The road would have to be elevated by some 2.5 metres above the flood level meaning it would be some 4 metres high thus destroying the views of the cathedral and south downs.

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 4metres (13 feet). The impacts of this are:

This would destroy the iconic views of the cathedral framed by the South Downs.

The noise generated by a road at this elevation would also be unacceptable in terms of Policy DM25.

There is no mention of retaining the separation of Donnington, Apuldram and Fishbourne

Serious local concerns over the ability to ensure adequate Waste Water Treatment provision. Apuldram Wastewater Treatment Works (WwTW) is inadequate by CDC's own admission inpara 6.40 in the context of the Southern Gateway Strategic Allocation AL5/ Wastewater from the site currently drains to the Apuldram WwTW. These works are subject to "environmental constraints which restrict its capacity to accommodate future development."

An additional access onto Fishbourne roundabout would be dangerous, even with the closure of the Terminus Road access.

There is no pedestrian access to the area proposed for employment use. A footbridge would be required to access across the A27 and the costs for this have not been factored in.

The concept of a link road was rejected by the public as part of the Highways England A27 Chichester Bypass Improvement proposals

This site has previously been considered and discounted from development plans (see DPD Sustainability Appraisal November 2016, Local Plan Inspector's report May 2015).

As a resident of Apuldram I wish to object to the proposed future development plans currently outlined in the Chichester Local Plan Review for the following reasons.
Flood Plain. Using figures from CDC's flood plain assessment it would be necessary to elevate any new road by over 2 metres, thus adversely affecting the special views of Chichester Cathedral. No dwellings or industrial sites should be constructed on a flood plain. Some new dwellings could be built in the South Downs National Park in line with their allocation. In addition there is an alternative site for industrial development within the buffer zone at Goodwood.
Pollution. Recent reports confirm that Air Quality levels at Donnington already exceed recommended levels. Any increase in the amount of traffic resulting from additional dwellings and industrial development between the Fishbourne roundabout and the A286 will significantly increase the pollution level with the corresponding risks to health.
Noise pollution will also be seriously increased as it is completely wrong to undertake such large scale development so close to the AONB & SSSI, which it would not be possible to mitigate and would also seriously affect the local ecology.
Traffic Following the proposals from Highways England for junction changes at Fishbourne the local community rejected such ideas. The roundabout is already considered very dangerous and adding a new link road, plus the additional traffic coming from additional dwellings from a new link road will further endanger peoples lives and should therefore not be undertaken.

Rubbish. AL6 takes no account of the biodiversity of the area. Unless this is adequately addressed in future iterations of the plan. I will raise this with the examiner at the appropriate time.

I object to this proposal because I do not consider the proposed link road between Birdham Road and Fishbourne Roundabout to be a solution to congestion on A27, or a solution to the problems of access to A27 and Chichester from the Manhood Peninsula. Attempting to facilitate access to and from the Manhood Peninsula in this way will simply move the problem of congestion further along the A286. The link road will become a rat run for all those wanting to avoid the A27 south of Chichester to the Bognor Roundabout, encouraging longer distance traffic to use Wophams Lane and other local roads. It will also encourage westbound traffic from Selsey and Bognor Regis heading for the A27. Visitors heading to and from the Witterings beaches already queue at times in the whole length of A286 back to A27 and a link road would either accelerate the traffic to queue on A286 or block the link road entirely. As this holiday traffic is not related to land allocations and may not occur on an 'average' day (a weekday rush hour when the schools are open), it is is possible that it has not been included in the Traffic Study for the Draft plan. At Fishbourne Roundabout, it is already difficult to emerge from Fishbourne Road because of the volume and speed of traffic travelling west on A27 and it is impossible to see how an additional junction can be added to the roundabout successfully.

The proposal to build the Stockbridge link road across the river Lavant flood plain is totally unacceptable.
It is my understanding that in order to avoid the road being flooded it would need to be elevated. this will destroy the views across the plain to the Cathedral and the Downs, and will increase pollution to adjacent properties (including the proposed new builds) given the prevailing south westerly wind.

Light industrial development is not appropriate because
1) the proximity to the Chichester Harbour AONB
2) the impact on traffic management at The Fishbourne roundabout, already a complex junction with a poor safety record in terms of accidents
3) there is currently no access to railway station, or other public transport or cycle or pedestrian friendly links to the rest of Chichester between the Stockbridge and Fishbourne roundabouts on the A27,

Such extensive development in this area can only be bad for the environment and the people already living in the area. Fewer dwellings and much reduce 'industrial' building might be acceptable if proper mitigation was carried out to protect the Area of Outstanding Natural Beauty and cope with the flood plain without spoiling the views. Small developments in all the areas in and around Chichester should be considered.

"The Council will seek to ensure that development protects, and where possible, improves upon the amenities of existing and future residents, occupiers of buildings and the environment in general. Where development is likely to generate significant adverse impacts by reason of pollution, the Council will require that the impacts are minimised and/or mitigated to an acceptable level."

I cannot see any of these features improving when AL6 / S23 is considered.

The 2015 Chichester Local Plan Inspectorate Report stated "Early proposals to locate strategic development to the south west and west of Chichester and at Fishbourne were discounted due to their environmental impact on the Chichester and Langstone Harbour Special Protection Area (SPA). Subsequently a mitigated strategy for recreational disturbance was developed and a solution to address the issue of waste water treatment emerged. This led to the strategic location for development West of Chichester being re-introduced. However, the SA report makes it clear that no such justification exists to re-introduce South West of Chichester or Fishbourne as locations for strategic development."

I and many others cannot find any evidence which has changed from this position since 2015 for CDC to include AL6 in the Local Plan Review 2035.

AL6 is one of several Policies to not have had a development location assessment in the Appendix of the Sustainability Appraisal which is in breach of Section 19 of the Planning and Compulsory Purchase Act 2004 requires a local planning authority to carry out a sustainability appraisal of each of the proposals in a Local Plan during its preparation.

Section 85 of the CRoW Act of 2000 requires relevant authorities to have regard to the purpose of the AONB 'in exercising or performing any functions in relation to, or so as to affect, land" in these areas. The AONB do not support this Policy and were not consulted on prior to its publication.

The NPPF states that great weight should be given to conserving and enhancing landscape and scenic beauty of AONBs (para 172).

Landscape Appendix: Chichester District Council Landscape Capacity Study states "Landscapes of great wildlife importance", "...the rural foreground in views to the Cathedral from Chichester Harbour", "... the landscape pattern that dates from the late post-medieval planned private enclosure associated with Apuldram Hamlet"

Against CPRE Policy of protecting and enhancing Landscape, Dark Skies, Hedgerows and Tranquillity.

AL6 - states the following:

Apuldram and Donnington Parishes 6.47 The impacts of development (including landscape, flooding and transport) in this location, along with the commercial attractiveness of the site, will need to be tested further as this local Plan Review is prepared. However based on initial assessment of the area so far, it is considered that there is potential to deliver significant development in this area which addresses the constraints of the site and its wider environment."

The development proposed would be on a Fluvial and Coastal Flood Plain 2 & 3 with significant risk of flooding. This is not mentioned in AL6. In AL4 (positioned on a Floodplain 1) 10. "Adoption of a comprehensive approach to flood risk management on the site, including consideration of surface water drainage as part of the masterplanning process;" why is this statement not also included in AL6? Is it because no actual thorough assessments set out in Policy S27 have been carried out? Strategic Flood Risk Assessment Level 1 and NPPF 2018 section on Planning and Flood Risk: Sequential test, Exception test and Environment Agency requirements. AL6 Policy is at complete odds with the Flood Risk and Water Management 5.54 "As a consequence of the rise in sea levels and storm surges, parts of the plan area will be at increasesd risk from coastal erosion, groundwater, fluvial and/or tidal flooding...villages are protected by sustainable means that make space for water in suitable areas."

Chichester Harbour Trust 's response to AL6 have voiced concerns against further deterioration in water quality leading to the downgrading of Chichester Harbour's SSSI status.

AL 6 in addition is adjacent to the Chichester Harbour (AONB, RAMSAR, SPA and SSSI sites) boundary which is not highlighted in AL6 Map and The Fishbourne Meadows Conservation Area, with the complete loss of the buffer zone outside the AONB . Breaching the SSI impact risk zone and negatively impacting the SAC, SPA and Ramsar designated areas. Contravening Policy DM28

Wildlife Habitats/Hedgerows- Destruction of habitat for protected species dependent on woodland edge, scrubland and rough grassland habitat.

Destruction of natural wildlife corridors and subsequent effect on biodiversity see Wildlife Corridor attachment. DM29 Biodiversity is at odds with AL6 as there is no adequate survey nor data to support the impact of the Wildlife with this development.

Negative impact on River Lavant Marsh SNCI site and associated vegetation including floodplain grazing (see attachment AL6 River Lavant SNCI)

Wildlife stepping stones- this piece of land is an existing wildlife stepping stone between Pagham and Medmerry Harbours, the historic Chichester Ship Canal and Chichester Harbour.

Urbanisation of the countryside contrary to policy S24 Countryside and destroys the separation of Stockbridge, Apuldram and Fishbourne which contravenes 3.7 Spatial Vision and Strategic Objectives-The East-West Corridor "maintaining and enhancing the countryside between settlements".

Landscape- destruction of the outstanding, historic and unique views of the Cathedral framed by the SDNP from Chichester Harbour (the only view of a Cathedral from the sea in England) and Salterns Way cycle path (see attached images) Contravening Landcape Policy 22, Policy DM28.

The destruction of this historic landscape will have a negative impact on Tourism and Wellbeing and contravenes the Vision and Objectives in the Plan along with Visit Chichester's Destination Management Plan statements:

Vision
"Follow a socially responsible and more environmentally friendly way of life, in the knowledge that the natural environment and biodiversity of the area is being conserved, managed and enhanced;"

"Enjoy...areas of attractive, accessible and unspoilt harbours, coast and countryside;"

Objectives
"...aims of the Chichester Vision" -
Economy- "Enable viability of the rural economy"

Visit Chichester's Destination Management Plan states that a key strength of Chichester's tourism economy is "Protected landscapes (Chichester Harbour and the South Downs) and the opportunities are "Coastal Tourism (Chichester Harbour and Selsey Coastal Trust)."

Agricultural Land- fields within AL6 are grade 1 agricultural land, some of which are covenanted to the National Trust. This rushed policy is at odds with Policy 26 Natural Environment "Considering the quality of the agricultural land, with development of poorer quality agricultural land being preferred to the best and most versatile land." Have the National Trust been consulted on this plan?

Soil Pollution affecting the AONB, River Lavant SNCI and The Fishbourne Meadows Conservation Area.

Air quality - loss of this part of the City's open space and one of its remaining green lungs, will have a negative effect on residents' health and wellbeing. The creation of a further AQMA is very likely at Fishbourne within the vicinity of the AONB with these junction changes and raised road.

HEDNA has identified a need for 23.2 hectares of additional employment sites; AL1, AL2, AL15 totals 12.4 hectares which leaves 10.8 hectares remaining. AL6 is proposed to have 33 hectares for employment development space. That is 3 times the requirement! See my response to Policy S8

Noise pollution from the industrial business units, and the minimum of 100 homes - disturbing and affecting the AONB Chichester Harbour natural inhabitants, not mentioned in the Local Plan

The proposed Link road slipped into the plan in September 2018 to facilitate the development on this site and is brushed over in this Policy as "a new link road". Not stating that it will need to be elevated to cross over the River Lavant and floodplain. Correspondence with the Environment Agency has confirmed this. "Where a road is crossing a watercourse we would seek a clear span design. This has the benefit of not only maintaining the continuity of flow routes but also are beneficial for biodiversity. We would look for any new road to be designed in such a way to manage any impacts to the environment from their drainage systems and therefore have no additional impact on the Harbour. We would not support surface water drainage from the development being connected to the Wastewater Treatment Works at Apuldram".

An elevated link road will negatively impact on the dark skies area of the AONB across this flat harbour area. The increase in noise pollution from the industrial park and raised road will destroy the value of the AONB, RAMSAR, SPA and SSSI sites. Any mitigation will obliterate the historic Landscape views of the Cathedral from the harbour.

The raised link road and Fishbourne roundabout alterations encroach 7,000m2 into The Fisbourne Meadow Conservation area. Any noise mitigation will further obliterate the historic Landscape views of the Cathedral from the harbour.

Local residents have already been consulted on the junction improvements in 2016 repeated in this plan the combination of Opt 2 & 3- the results 3% supported junction changes and 47% objected to the junction changes and link road, they understood the negative impacts stated in my comments on AL6. 56% voted to consult on a northern alignment. This begs the question, are those against a northern alignment for personal reasons within CDC putting in a southern alignment by stealth without consultation of another option?

Remove the employment development site and place the HENDA advised 10.8 hectares remaining in AL4.
Remove the housing development of minimum of 100 homes and country park and return them to the 41 per year SDNP allocation. The residents in the SDNP are crying out for affordable housing to meet the needs of undersubscribed local schools and shops are closing. At a Boxgrove Meeting in Autumn 2018 residents of the SDNP raised their frustration at their undersubscribed and in some cases closing primary schools alongside shops due to the lack of affordable homes in the SDNP to their MP Gillian Keegan.

Remove Stockbridge Link Road as there is no real need to waste funds building it and the subsequent environmental impact when employment and housing development can be placed elsewhere.

Is this raised link road being slipped in to allow for a business development and housing estate with a minimum of 100 homes and a country park? Or is the development an excuse to get the raised link road put in?

Development Plan & Infrastructure Panel (DPIP) is there to advise the Cabinet on Planning Matters including the Local Plan. It is appointed by the Cabinet and is Chaired by the Cabinet Member for Planning and also includes the Leader of the Council and Deputy Leader (who represents an SDNP Ward) both of whom are Cabinet Members also; the constitution allows for the Cabinet Member for Planning as Chairman and the Leader not for any other Cabinet Members. No agendas or Minutes of this panel's proceedings are published. Not withstanding the fact that it is within CDC's constitution this appears highly undemocratic and open to a lack of transparency or objectivity in plan making. This calls for a change in CDC's constitution.

I wish to raise all of my points with the examiner.

Potential housing development in this flood plain will present a risk for householders and a significant visual intrusion on the 'views across farmland' protected under other council properties. Industrial buildings in this area and the inclusion of more relief road development will impact the adjacent AONB, affecting wildlife, tourism and the access to the countryside of local residents. It is unclear how the access to the city for users of this area could be improved by this policy.

I object to the land being allocated for development of housing, employment and a link road. The land borders the Chichester Harbour AONB and should be preserved as a strategic green space, without development, stretching from the coast at Fishbourne Channel right up to the edge of the City. Development of housing, employment and especially a link road will destroy this.
You should be increasing access to this greenspace and the Salterns Way thereby encouraging leisure and recreation to local residents.
The employment land could be provided adjacent to the Goodwood Motor Circuit (previously allocated as a strategic site but now withdrawn and shown as a buffer zone). The proposed 100 dwellings could be accommodated in the South Downs National Park if it took its allocation of 41 dwellings per annum.
The allocation of this site appears to prejudge the resolution of the A27 problems as the traffic mitigation proposed for development of this site aligns with one of A27 improvement options rather than a northern bypass. Donnington residents will be severely disadvantaged by the proposed changes to the A27 especially if they want to travel to the east.

According to CDC's flood plain assessment the land proposed includes a flood plain with the average height of of flood water at 2.05 metres above sea level. As a result the road will presumably need to be elevated by around 4 metres, once supporting structures and the road itself are taken into account. As this would severely impact the iconic views of the cathedral in the South Downs setting it would have an unacceptable impact and the protection proposed by para 3 of Policy AL6 would not be accomplished.

I object to the building of a 33ha industrial estate, 100 houses and Linkroad between Fishbourne Roundabout and the A286 Birdham Road on an Active Floodplain which includes the River Lavant and important wildlife areas, and extensive productive farming land.
The main reason for the proposed development appears to be for the funding of the Linkroad and not because AL6 is the correct place to put the industrial site.
It would be better to build some of the industrial site at the Whitehouse Farm development where 1600 houses are planned and within the buffer zone at Goodwood. Remove Policy AL6

Site AL6 Land South West Of Chichester (Apuldram and Donnington Parishes) includes a flood plain. Using data from CDCs flood plain assessment, the average height of flood water on the River Lavant is 2.05 meters (6.07ft) above datum (sea level).This means the road will have to be elevated by at least 2.5m and more with the supporting structures and road thickness itself. Therefore nearer 4m (13ft). This would destroy the iconic views of the cathedral framed by the South Downs.

I strongly object to the allocation of this site for the following reasons
:it will cause demonstrable harm to the environment ,and harbour conservatory area
:the proposed industrial B class is far to wide and as drafted will lead to development which will not comply with development control policies DM28;DM23: DM24 and DM25
;the density of the proposed development and provision of new access road is contradictory in addressing the site specific criteria set out in the policy
;the area is within the flood plain and therefore the proposed road and any development would require land raising which will have a significantly harmful effect on the environment
; Air quality will deteriorate further where existing levels already exceed recommended levels
;a viable alternative site for industrial use is available within the buffer zone at Goodwood
; the

I strongly object to the AL6 proposed development and the associated Stockbridge Link Road.

This area is one of the most attractive parts of Chichester, it offers outstanding views from the South of the Cathedral and South Downs enjoyed by locals and visitors alike. We already have countryside within walking distance, a cut down park area is not equivalent and is no substitute for what is already in place and cannot be replaced if lost. This will cause irrevocable harm to the appearance of the countryside which we all love and choose to reside here for.
Any development will impact the wildlife of the area and their habitat, There is a strong Bat population at home in this area which I have not seen anywhere else. Bordering the Chichester Harbour AONB it attracts a wide variety of wildlife..Any changes to the area will cause great disruption and a suggested corridor is a poor excuse to deflect objections to the reality of destroying this. Any development here will impact the AONB, its too close and if anything the AONB should be extended to include this location from harm to prevent further encroachment.
The proposed site which only specifies Minimum figures is on a Zone 3 Flood Plain. The idea that it can be developed on the fringes is flawed and will increase water displacement and flooding to surrounding areas, increasing the flood risk. A raised SLR will add to this risk and drastically alter the landscape.This is contrary to the aim to 'Minimise flood risk for new and existing developments' how can this proposal stand with such contradictions?. It is not sustainable. This proposal runs contrary to 5.54
This is arable farmland which is well managed and will serve as a loss of produce, removing Mile Pond Farm completely adversely affecting the farm and those dependant on it for their livelihood and home. In the present climate this is short sighted.
The policy is against the CDC own aims to ensure environmental protection, protect and enhance wildlife, enhancement of the landscape, habitat networks and dark skies (over the South Downs National Park and the Chichester Harbour AONB). This proposal will negate all of those elements and there is no mitigation that would be able to prevent that impact.
'In order to protect the landscape, character, quality and tranquillity of the countryside it is essential to prevent inappropriate development.' this proposal is inappropriate in its entirety.
7.118 'The flatness of the landscape makes the AONB particularly vulnerable to visual intrusion from inappropriate development, both within or adjacent to the boundary, which can often be seen from significant distances across inlets, the main harbour channels, or open countryside.'
This idea is ill conceived and destructive, its impact would be to detract from the area and lose that quality which attracts visitors to Chichester. Its unbelievable that people would seek to throw away that which makes our surroundings so special, the character and beauty which makes it so attractive. It doesn't make any sense and the argument does not add up, it would be a disaster if any element of this policy progressed further.

The inclusion of several rehashed A27 proposals such as the SLR, Fishbourne roundabout additions, removal of the Terminus Road exit, Stockbridge lights with no right turns, left turn access etc has totally undermined the BABA27 proposals. Its disappointing that CDC have tried to reintroduce these elements through the backdoor knowing full well that these had been rejected by the majority under the A27 consultations. These were flawed then and are still now, even more funds have been diverted to repeat the errors of the past. The preference over through traffic to that of local residents will not assist residents. The addition of exits and link roads will merely create further bottlenecks and pinch points, displacing traffic into the side roads. The Donnington/Stockbridge area will be enclosed in a pollution triangle surrounded on all sides by increasing traffic. In view of pollution levels already in Chichester this will rise and raise health concerns further. Their inclusion will not mitigate traffic but contribute to it. These need to be recognised as flawed from the outset and the motivation for their inclusion raises questions when alternatives based on local consensus have been put forward supposedly with the backing of the CDC yet again being contradicted by the plan.

1 This is blatant urbanisation of a rural area at the Gateway to the Manhood peninsular by the extension of Chichester City, into a parish outside the city boundary. The parish, is within the newly named electoral ward of the Harbour Villages Ward, which should indicate its character. This is contrary to the commitment in para 5.37
2. Removal of the strategic gap between Donnington and Appuldram and merging the two with the "extension to Chichester City" will destroy the identity of 2 communities.Contrary to policy S3
3.The statement at 6.44 is incorrect. Donnington does not rely on Chichester City for everyday facilities, there are perfectly good shops within the Stockbridge area of Donnington and it has its own centre in the Parish Hall.
4.The land is currently mostly valuable agricultural land providing food for the nation, contributing to the agricultural economy and providing employment. It is not clear how the value of land for economic use is assessed and business use valued more greatly that agriculture.
5 The land provides an important hinterland to the Chichester Harbour Area ANOB SSSI, SPA and RAMSAR and is rich in wildlife and ecology.
6.The ditches shown on the map as drains do not actually drain anywhere other than into ther ground. They are more soakaway ditches that receive run off and rise and fall with the water table.
7. There is a large pond/lake adjacent to the Stockbridge settlement area boundary of Donnington. This is spring fed as is Mile Pond (adjacent to the A286) itself, indicating an underground water connection. The pond supports a large variety of wildlife such that it is to be subject to conservation regeneration by the Manhood Wildlife Group within the next 2 years (by 2021) funded by National Lottery funding.
The field immediately to the south of the pond/lake has been maintained as grassland and cut for a single hay crop each year for several years providing a habitat for ground nesting birds, amphibians such as frogs, toads .as well as reptiles such as slow worms and grass snakes which have all been seen here.. Water voles have been seen visiting the pond and a survey a few years again demonstrated vole activity in most of the ditches back to Fishbourne Meadow. The wildlife corridor connecting this Pond/lake with Mile Pond and Fishbourne Meadow must be preserved.
8.The springs, flood plain and underground water courses should not be intercepted by development as they provide an important underground drainage route from the city to the sea.
9. The land of AL6 is up to a metre above the properties in the Stockbridge settlement area increasing flood risk.
10 Being in such close proximity to the Harbour Area ANOB, SSSI, SPA and RAMSAR makes it totally unsuitable for development on such a scale.
11 The need to elevate the proposed Fishbourne/Birdham Road as well as the buildings will destroy the landscape and views of Chichester Cathdral against the downs and the views and landscape towards the ANOB etc.
12 Green tourism is very important to the economy of the Manhood Peninsular and to overdevelop and destroy the landscape and natural environment at the very gateway to the Manhood would be extremely damaging.
13 The LPA has previously followed a policy of keeping an open landscape to the south of the A27 so people passing through would see Chichester City as a jewel situated in a rural landscape, encouraging them back as tourists. The open landscape to the south is a major shop window to the tourist economy of the whole area.
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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 4metres (13 feet). The impacts of this are:
This would destroy the iconic views of the cathedral framed by the South Downs.
The noise generated by a road at this elevation would also be unacceptable in terms of Policy DM25.

There is no mention of retaining the separation of Donnington, Apuldram and Fishbourne

Serious local concerns over the ability to ensure adequate Waste Water Treatment provision. Apuldram Wastewater Treatment Works (WwTW) is inadequate by CDC's own admission inpara 6.40 in the context of the Southern Gateway Strategic Allocation AL5/ Wastewater from the site currently drains to the Apuldram WwTW. These works are subject to "environmental constraints which restrict its capacity to accommodate future development."

An additional access onto Fishbourne roundabout would be dangerous, even with the closure of the Terminus Road access.

There is no pedestrian access to the area proposed for employment use. A footbridge would be required to access across the A27 and the costs for this have not been factored in.

The concept of a link road was rejected by the public as part of the Highways England A27 Chichester Bypass Improvement proposals

This site has previously been considered and discounted from development plans (see DPD Sustainability Appraisal November 2016, Local Plan Inspector's report May 2015). Reasons include:
the likelihood of flooding in the area;
impact on water pollution of runoff
proximity to AONB
impact on wildlife
impact on protected views


ALTERNATIVES TO AL6
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 wish to object to this plan, for the following reasons:
1. There has been no attempt to justify the increase in annual housing numbers from 435 in the Adopted Plan to 650. The Adopted Plan cited environmental and infrastructural constraints as a reason for using 435 as the annual figure. None of these constraints have changed, yet the housing figure has increased by nearly 50% without a word of justification. No houses should be accepted from the SDNP, and the housing figure should be reduced to reflect the 2016 ONS household projections. Chichester does not need 609 houses every year until 2035, and is under too much environmental pressure to accept houses from a vast National Park.
2. Using the figure of 650 houses per year, the plan calculates that 4400 houses are needed from strategic locations. It then lists the strategic locations, which adds up to a total 7985 houses. Considering that the total figure should be more like 550 houses pa, the figure of 4400 is itself too high, and should be more like 2900. This means an excess of 5000 houses has been allocated. I may be reading these figures incorrectly, but it seems to me that a large number (I would suggest at least 2500) be removed from the proposed sites. A large number of the houses proposed are more or less immediately adjacent to the Chichester Harbour AONB. I suggest removing those doing most harm to the AONB.
3. Far too much building has been proposed that damages the Chichester Harbour AONB. Especially Policy AL6 (Land South-West of Chichester, Apuldram and Donnington Parishes) which proposes a new link road which cuts the harbour off from the city, and a major commercial development within a few hundred metres of the AONB. Any plans for a link road should be abandoned, and the commercial site should be moved to the East of the city. Airfields usually provide a good hub for commercial sites, so close to Goodwood airfield would be a suitable place. The houses proposed for this site are not needed.
4. Environmental, and particularly infrastructural constraints were recognised when allocating housing on the Manhood Peninsula in the adopted Plan. Additionally, building on the Manhood Peninsula was front loaded because of capacity limitations at the Tangmere Water Works. The Manhood's requirement until 2029 has already been exceeded by a large margin. The environmental, and particularly infrastructural constraints remain completely unchanged, with the A27 improvements seemingly further than ever from resolution. The A286 is becoming busier and noisier, with complete gridlock on holiday weekends. As there is a huge oversupply of development sites, no housing should be allocated to Birdham, Bracklesham or West Wittering in this plan cycle, or until infrastructure improvements are complete.

We wish to support this policy.

The Berkeley Group is the sole owner of Lawrence Farm which forms part of the land that is allocated for development by Policy AL6. Lawrence Farm is extends to 3.67 hectares and is located adjacent to the Fishbourne roundabout. The site is referred to in the Strategic Housing Land Availability Assessment as CC08209A and it remains both available and deliverable.

We support the principle of improving the Fishbourne roundabout and the provision of a new link road connecting the A27/A259 Fishbourne roundabout and A286 Birdham Road. Lawrence Farm can help to facilitate and deliver the roundabout improvements and the northernmost part of the link road. We would therefore like to work collaboratively with the Council and the adjoining landowners to support the allocation of the site as the Local Plan progresses.

We believe that the land to the South-West of Chichester is a sustainable location for development. It is located adjacent to the built-up area of Chichester, the largest and most sustainable settlement in the District, and benefits from being approximately one mile from the train station and the high street.

Policy S8: Meeting Local Employment Needs includes 145,835m2 floorspace as identified in the Housing and Economic Development Needs Assessment (HEDNA) and an additional 86,000m2 of floorspace as an allowance for future losses. The HEDNA includes four scenarios for employment need which results in a wide range of floorspace requirements. We believe that total floorspace provision in Policy S8 might be overly ambitious for a couple of reasons. Firstly because the rate of future loss of employment is likely to slow down compared to the rate experienced by the Council when permitted development rights first came into effect and secondly, given the current and emerging economic uncertainties.

It will be important for the Local Plan to contain sufficient flexibility and to be able to react to economic changes during the Plan period. We would therefore recommend removing the reference to the acreage of employment land and number of new homes and including an additional sentence added at the end of the first paragraph to say:

"The final quantum of employment space and number of dwellings will be determined by an up-to-date market assessment to determine the viability of the proposals, the need for additional commercial floorspace and the demand for more housing at the time of submission."

We would like to work with the Council and the adjoining owners of land within Policy AL6 to understand if there is scope for Al6 to provide a greater number of new homes.

AL6 also represents a great opportunity to deliver a new country park and green infrastructure. The provision of strategic open space can not only assist with protecting the Chichester Harbour Area of Outstanding Natural Beauty, the Solent Special Area of Conservation and the views of Chichester Cathedral spire, it can also help to achieve a net biodiversity gain.

As set out in Policy AL6, proposals will need to demonstrate that sufficient capacity will be available within the sewer network. We are happy to work with the adjoining landowners, Council, Southern Water, and other stakeholders to ensure that the Apuldram waste water treatment works can accommodate the development.

We anticipate that strategic highway improvements, new strategic open spaces and potential improvements to the Apuldram wastewater treatment are likely to have an impact on the viability of the allocation. The viability of AL6 will need to be considered in greater detail as the Local Plan progresses. A further advantage of AL6 providing more than 100 new homes is the potential to improvement to the viability of the allocation.

In order to enable and deliver the most suitable improvements to the Fishbourne roundabout, we recommend that the full extent of the land at Lawrence Farm is included in the Proposed Strategic Site Allocation AL6. The amendment of the accompanying plan for AL6 to include all of our client's land around the Fishbourne roundabout will not only maximise opportunities for the road to be provided within the red edge of the site, but also help to avoid complications later in the process.


1. We believe the text of the policy should be amended to have an additional sentence added at the end of the first paragraph to say:

"The final quantum of employment space and number of dwellings will be determined by an up-to-date market assessment to determine the viability of the proposals, the need for additional commercial floorspace and the demand for more housing at the time of submission."

2. The plan in the policy map for AL6 should be altered to include all of the land outlined in red in the allocation:

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!

The 2015 Chichester Local Plan Inspectorate Report stated "Early proposals to locate strategic development to the south west and west of Chichester and at Fishbourne were discounted due to their environmental impact on the Chichester and Langstone Harbour Special Protection Area (SPA). Subsequently a mitigated strategy for recreational disturbance was developed and a solution to address the issue of waste water treatment emerged. This led to the strategic location for development West of Chichester being re-introduced. However, the SA report makes it clear that no such justification exists to re-introduce South West of Chichester or Fishbourne as locations for strategic development."

I and many others cannot find any evidence which has changed from this position since 2015 for CDC to include AL6 in the Local Plan Review 2035.

AL6 is one of several Policies to not have had a development location assessment in the Appendix of the Sustainability Appraisal which is in breach of Section 19 of the Planning and Compulsory Purchase Act 2004 requires a local planning authority to carry out a sustainability appraisal of each of the proposals in a Local Plan during its preparation.

Section 85 of the CRoW Act of 2000 requires relevant authorities to have regard to the purpose of the AONB 'in exercising or performing any functions in relation to, or so as to affect, land" in these areas. The AONB do not support this Policy and were not consulted on prior to its publication.

The NPPF states that great weight should be given to conserving and enhancing landscape and scenic beauty of AONBs (para 172).

Landscape Appendix: Chichester District Council Landscape Capacity Study states "Landscapes of great wildlife importance", "...the rural foreground in views to the Cathedral from Chichester Harbour", "... the landscape pattern that dates from the late post-medieval planned private enclosure associated with Apuldram Hamlet"

Against CPRE Policy of protecting and enhancing Landscape, Dark Skies, Hedgerows and Tranquillity.

AL6 - states the following:

Apuldram and Donnington Parishes 6.47 The impacts of development (including landscape, flooding and transport) in this location, along with the commercial attractiveness of the site, will need to be tested further as this local Plan Review is prepared. However based on initial assessment of the area so far, it is considered that there is potential to deliver significant development in this area which addresses the constraints of the site and its wider environment."

The development proposed would be on a Fluvial and Coastal Flood Plain 2 & 3 with significant risk of flooding. This is not mentioned in AL6. In AL4 (positioned on a Floodplain 1) 10. "Adoption of a comprehensive approach to flood risk management on the site, including consideration of surface water drainage as part of the masterplanning process;" why is this statement not also included in AL6? Is it because no actual thorough assessments set out in Policy S27 have been carried out? Strategic Flood Risk Assessment Level 1 and NPPF 2018 section on Planning and Flood Risk: Sequential test, Exception test and Environment Agency requirements. AL6 Policy is at complete odds with the Flood Risk and Water Management 5.54 "As a consequence of the rise in sea levels and storm surges, parts of the plan area will be at increasesd risk from coastal erosion, groundwater, fluvial and/or tidal flooding...villages are protected by sustainable means that make space for water in suitable areas."

Chichester Harbour Trust 's response to AL6 have voiced concerns against further deterioration in water quality leading to the downgrading of Chichester Harbour's SSSI status.

AL 6 in addition is adjacent to the Chichester Harbour (AONB, RAMSAR, SPA and SSSI sites) boundary which is not highlighted in AL6 Map and The Fishbourne Meadows Conservation Area, with the complete loss of the buffer zone outside the AONB . Breaching the SSI impact risk zone and negatively impacting the SAC, SPA and Ramsar designated areas. Contravening Policy DM28

Wildlife Habitats/Hedgerows- Destruction of habitat for protected species dependent on woodland edge, scrubland and rough grassland habitat.

Destruction of natural wildlife corridors and subsequent effect on biodiversity see Wildlife Corridor attachment. DM29 Biodiversity is at odds with AL6 as there is no adequate survey nor data to support the impact of the Wildlife with this development.

Negative impact on River Lavant Marsh SNCI site and associated vegetation including floodplain grazing (see attachment AL6 River Lavant SNCI)

Wildlife stepping stones- this piece of land is an existing wildlife stepping stone between Pagham and Medmerry Harbours, the historic Chichester Ship Canal and Chichester Harbour.

Urbanisation of the countryside contrary to policy S24 Countryside and destroys the separation of Stockbridge, Apuldram and Fishbourne which contravenes 3.7 Spatial Vision and Strategic Objectives-The East-West Corridor "maintaining and enhancing the countryside between settlements".

Landscape- destruction of the outstanding, historic and unique views of the Cathedral framed by the SDNP from Chichester Harbour (the only view of a Cathedral from the sea in England) and Salterns Way cycle path (see attached images) Contravening Landcape Policy 22, Policy DM28.

The destruction of this historic landscape will have a negative impact on Tourism and Wellbeing and contravenes the Vision and Objectives in the Plan along with Visit Chichester's Destination Management Plan statements:

Vision
"Follow a socially responsible and more environmentally friendly way of life, in the knowledge that the natural environment and biodiversity of the area is being conserved, managed and enhanced;"

"Enjoy...areas of attractive, accessible and unspoilt harbours, coast and countryside;"

Objectives
"...aims of the Chichester Vision" -
Economy- "Enable viability of the rural economy"

Visit Chichester's Destination Management Plan states that a key strength of Chichester's tourism economy is "Protected landscapes (Chichester Harbour and the South Downs) and the opportunities are "Coastal Tourism (Chichester Harbour and Selsey Coastal Trust)."

Agricultural Land- fields within AL6 are grade 1 agricultural land, some of which are covenanted to the National Trust. This rushed policy is at odds with Policy 26 Natural Environment "Considering the quality of the agricultural land, with development of poorer quality agricultural land being preferred to the best and most versatile land." Have the National Trust been consulted on this plan?

Soil Pollution affecting the AONB, River Lavant SNCI and The Fishbourne Meadows Conservation Area.

Air quality - loss of this part of the City's open space and one of its remaining green lungs, will have a negative effect on residents' health and wellbeing. The creation of a further AQMA is very likely at Fishbourne within the vicinity of the AONB with these junction changes and raised road.

HEDNA has identified a need for 23.2 hectares of additional employment sites; AL1, AL2, AL15 totals 12.4 hectares which leaves 10.8 hectares remaining. AL6 is proposed to have 33 hectares for employment development space. That is 3 times the requirement! See my response to Policy S8

Noise pollution from the industrial business units, and the minimum of 100 homes - disturbing and affecting the AONB Chichester Harbour natural inhabitants, not mentioned in the Local Plan

The proposed Link road slipped into the plan in September 2018 to facilitate the development on this site and is brushed over in this Policy as "a new link road". Not stating that it will need to be elevated to cross over the River Lavant and floodplain. Correspondence with the Environment Agency has confirmed this. "Where a road is crossing a watercourse we would seek a clear span design. This has the benefit of not only maintaining the continuity of flow routes but also are beneficial for biodiversity. We would look for any new road to be designed in such a way to manage any impacts to the environment from their drainage systems and therefore have no additional impact on the Harbour. We would not support surface water drainage from the development being connected to the Wastewater Treatment Works at Apuldram".

An elevated link road will negatively impact on the dark skies area of the AONB across this flat harbour area. The increase in noise pollution from the industrial park and raised road will destroy the value of the AONB, RAMSAR, SPA and SSSI sites. Any mitigation will obliterate the historic Landscape views of the Cathedral from the harbour.

The raised link road and Fishbourne roundabout alterations encroach 7,000m2 into The Fisbourne Meadow Conservation area. Any noise mitigation will further obliterate the historic Landscape views of the Cathedral from the harbour.

Local residents have already been consulted on the junction improvements in 2016 repeated in this plan the combination of Opt 2 & 3- the results 3% supported junction changes and 47% objected to the junction changes and link road, they understood the negative impacts stated in my comments on AL6. 56% voted to consult on a northern alignment. This begs the question, are those against a northern alignment for personal reasons within CDC putting in a southern alignment by stealth without consultation of another option?

Remove the employment development site and place the HENDA advised 10.8 hectares remaining in AL4.
Remove the housing development of minimum of 100 homes and country park and return them to the 41 per year SDNP allocation. The residents in the SDNP are crying out for affordable housing to meet the needs of undersubscribed local schools and shops are closing. At a Boxgrove Meeting in Autumn 2018 residents of the SDNP raised their frustration at their undersubscribed and in some cases closing primary schools alongside shops due to the lack of affordable homes in the SDNP to their MP Gillian Keegan.

Remove Stockbridge Link Road as there is no real need to waste funds building it and the subsequent environmental impact when employment and housing development can be placed elsewhere.

Is this raised link road being slipped in to allow for a business development and housing estate with a minimum of 100 homes and a country park? Or is the development an excuse to get the raised link road put in?

Development Plan & Infrastructure Panel (DPIP) is there to advise the Cabinet on Planning Matters including the Local Plan. It is appointed by the Cabinet and is Chaired by the Cabinet Member for Planning and also includes the Leader of the Council and Deputy Leader (who represents an SDNP Ward) both of whom are Cabinet Members also; the constitution allows for the Cabinet Member for Planning as Chairman and the Leader not for any other Cabinet Members. No agendas or Minutes of this panel's proceedings are published. Not withstanding the fact that it is within CDC's constitution this appears highly undemocratic and open to a lack of transparency or objectivity in plan making. This calls for a change in CDC's constitution.

I wish to take these points up with the examiner.

OVERALL
Whilst I commend the work put in I am dissapointed in the attitude to the South Downs National Park. Whils I acknowledge that they are their own planning authority the CDC has a major role in their area and are advised of planning being applied for. In this instance, the 2035 review I believe the CDC should have taken a much more decisive attitude and issue a requirement that they provide substantial land for both employment and domestic development. National directives do not prevent such an approach and I believe that many residents within the SDNP would support inner development to retain and expand accomodatio for those who wish to stay within its boundary to work and live. There is ample scope to develope within the SDNP.This approach would go a long way to allieviating the overdevelopment of the corridor along the A259.

POLICY SA6 Land to the South - West of Chichester.
Whilst the merits of development along the southern border of the A27 twix Fishbourne and Donnington can be seen I believe that building height restrictions would be needed to mitigate the impact views torardso and from the city and the AONB making this far less attractive. There is also a need to pay regard to possible improvements to the A27 ,a potential which can not be ignored. I believe this proposal should be shelved and held in reserve for a later plan.
The link road is a factor which in my view must be reconsidered with its impact on accessability to the already conjested Fishbourne roundabout., If it is to be recommended there must be mitigation by a flyover east - west at this junction, A27, with pre-agreement with Highways \aengland for this to go ahead.The level of the road is also a concern with views, noise and pollusion all a factor. It would seem preferable to divert traffic from the south, east of the southern development area as it is to join the A27 at the Bognor road crossing where there is more scope for a raised crossing.Highways England involvement is urgently needed here.

POLICY SA9 Fishbourne.
I can not see how the perceived view of Fishbourne can be uphed. The determination of its character appears at varience withother villages.
The structure of the village can not support a further 250 houses as there is no supporting facilities and no funding is available, nor raisable through this development, for educational, services or transport facilities . The infill of strategic gaps which is a policy of national and local government departments is being breached. The projected area is shown as preferred over an area to the east of the village which has previously been put forward for development because of the newly raised wildlife corridor and the same considerations should be applied to the preferred area taking it out of consideration..

In conclusion I must say that this plan can not be constructed in isolation and special representations should be made to The Government to delay further consideration until the A27 improvement stratagy is determined.

I object to this proposal because I do not consider the proposed link road between Birdham Road and Fishbourne Roundabout to be a solution to congestion on A27, or a solution to the problems of access to A27 and Chichester from the Manhood Peninsula. Attempting to facilitate access to and from the Manhood Peninsula in this way will simply move the problem of congestion further along the A286. The link road will become a rat run for all those wanting to avoid the A27 south of Chichester to the Bognor Roundabout, encouraging longer distance traffic to use Wophams Lane and other local roads. It will also encourage westbound traffic from Selsey and
Bognor Regis heading for the A27. Visitors heading to and from the Witterings beaches already queue at times in the whole length of A286 back to A27 and a link road would either accelerate the traffic to queue on A286 or block the link road entirely. As this holiday traffic is not related to land allocations and may not occur on an 'average' day (a weekday rush hour when the schools are open), it is is possible that it has not been included in the Traffic Study for the Draft plan. At Fishbourne Roundabout, it is already difficult to emerge from Fishbourne Road because of the volume and speed of traffic travelling west on A27 and it is impossible to see how an
additional junction can be added to the roundabout successfully.