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

Showing comments and forms 151 to 180 of 194

Object

Local Plan Review: Preferred Approach 2016-2035

Representation ID: 2178

Received: 01/02/2019

Respondent: Mrs Fiona Horn

Representation Summary:

Object to AL6 due to conflict with S24 Countryside.

Full text:

Including AL6 is against these statements "a design that is unlikely to cause unacceptable harm to the appearance"..."keen to protect the characteristics of Chichester Harbour. Joke ! How can concreting within 100mtrs of AONB and building a 4mtr elevated road ever achieve these statements.Never mind, noise, air and light pollution which will destroy the AONB. Yet again the land to the south of SDNP is excluded.Unless this is adequately addressed in future iterations of the plan, i will raise this with the examiner at the appropriate time.

Object

Local Plan Review: Preferred Approach 2016-2035

Representation ID: 2179

Received: 31/01/2019

Respondent: Mrs Fiona Horn

Representation Summary:

Object to AL6 due to conflict with S23 Transport and Accessibility.

Full text:

REMOVE AL6.The plan does exactly the opposite for all local traffic. It decreases road capacity, increases congestion increases air pollution and hinders accessibilty to Chichester City.New road from Birdham to Fishbourne was emphatically rejected as environmental and heritage vandalism and detrimental to local traffic whilst not solving the congestion issue. Should not be included as no funding.Junction upgrades would create 15 yrs of misery and pollution and not solve the issue.Unless this is adequately addressed in future iterations of the plan, I will raise this with the examiner at the appropriate time.

Object

Local Plan Review: Preferred Approach 2016-2035

Representation ID: 2180

Received: 31/01/2019

Respondent: Mrs Fiona Horn

Representation Summary:

Object to AL6 due to conflict with S22 Historic Environment.

Full text:

Areas that have been included ie AL6 are clearly against this policy and should be removed immediately.Unless this is adequatley addressed in future iterations of the plan, I will raise it with the examiner at the appropriate time.

Object

Local Plan Review: Preferred Approach 2016-2035

Representation ID: 2181

Received: 31/01/2019

Respondent: Mrs Fiona Horn

Representation Summary:

Object to AL6 due to conflict with S8 Meeting Employment Land Needs.

Full text:

Alot of work in Chichester is low paid, service/industrial work/part time or seasonal.Chichester needs a variety of smaller business/ industrial opportunities rather than large scale which does not suit the area. Plenty of land already available on existing brown field site without concreting more. Priority to regenerate the city centre which is dying because of too much out of town retail parks. Encourage cheaper parking, lower business rates etc. REMOVE AL6 no data and incredibly damaging to the environment.Unless AL6 is adequately addressed in future iterations of this plan I will raise this with the examiner at the appropriate time.

Comment

Local Plan Review: Preferred Approach 2016-2035

Representation ID: 2184

Received: 06/02/2019

Respondent: Erica Bryant

Number of people: 2

Representation Summary:

Comments on AL6 link road relate to:
- Increased traffic a barrier for tourism
- No easy access to the rail networks, employment, secondary schools and higher education.
- No secondary school in this area
- Local schools at capacity
- Medical centre at capacity
- Lack of employment

Full text:

Having read the Local Plan - Preferred Approach we are extremely concerned that the powers that be do not fully comprehend the geography and economic importance of the Manhood Peninsular. We therefore set out our comments below.
There is only one road (A286) linking the Witterings/Bracklesham to the A.27 which is one of the most congested roads in the area and it has proved difficult on occasions for the emergency services to reach accidents etc. It also makes travel to and from these villages, including by buses, extremely difficult. The proposed AL6 link road will not solve the problem and nor will the junction changes which will result in local journeys becoming longer and more difficult. The housing targets will also impact greatly on the road capacity. There needs to be a long term solution to the A27. Indeed, the A286 which links the Witterings/Bracklesham to Chichester is so frequently gridlocked that St Richards hospital recommends that its senior staff do not live in the area because they cannot guarantee that they will be able to reach the hospital within a necessary time limit.
The proposed provision of a commercial development site and a raised link road will be on a flood plain and is adjacent to an internationally important habitat site. This would suggest that such a site for the development would be unsuitable. The impact of a raised road on the Apuldram/Donnington area would also be substantial on the local community.
Consideration has apparently not been given to the impact of the changes at the Hunston junction. There is now a large secondary school near to the junction which has resulted in an increase in the amount traffic at the junction of as the considerable number of children have to be taken to/from school by car due to the lack of public transport particularly from the Witterings areas.
For the reasons stated above we do not think the proposed AL6 link road or the provision of a commercial development site is a sensible or economic solution.
In the Section "S2 - 4.14 Development Strategy it states "consideration has been given to other factors in determining whether a settlement is a suitable location for additional housing growth, including infrastructure capacity". However, these factors do not appear to have been fully taken into account and we would like to comment as follows.
The minimum housing target of 350 set for the Bracklesham/East Wittering area will have a significant impact on the villages and the A286 and suggests that a higher housing target could be reached. Even a maximum of 350 would excessive, in view of the increase in housing that has already taken place and is currently under construction in the area (including Birdham). There is no easy access to the rail networks, employment, secondary schools and higher education. There is no secondary school in the Witterings/Bracklesham area and there is very limited employment in the Manhood Peninsula, which means people have to commute to access employment, schooling and rail networks. One has to assume that it is most likely that each property is likely to use two cars. All traffic from these villages has to travel along the frequently congested A286. The schools are already almost at capacity as is the medical centre which already finds it necessary to divert some patients in need of medical attention to other practices outside of the villages. These village communities rely heavily on tourism for employment and their economy. If the road becomes even more congested this will inevitably lead to tourists avoiding the area, which would also have an adverse effect on the contribution the Peninsular makes to the Chichester district.
We live in Somerley in a conservation area. We have already been impacted by the increase in noise levels from traffic passing along Bell Lane/Bracklesham Lane. According to a Transport Study for the LPR by Peter Brett it forecasts that the further increase in housing will raise the level of noise to "major". We suggest that consideration should be given to reducing, not increasing, the level of noise.
In view of the above we object to East Wittering/Bracklesham being considered as a settlement hub and it should be removed.

Attachments:

Object

Local Plan Review: Preferred Approach 2016-2035

Representation ID: 2193

Received: 07/02/2019

Respondent: Debbie Leonard

Representation Summary:

AL 6 is wholly inappropriate for development for the following reasons:
-unacceptable harm to the AONB and loss of view from harbour to cathedral
-increased light pollution and noise pollution, waste water issues and habitat risk.
-is a flood plain and is therefore totally unsuitable for residential property.
-loss of green buffer between Chichester and Manhood Peninsular
- un-necessary link road which simply moves pollution
- harm to Salterns Way as a leisure route for cyclists/pedestrians

Full text:

S16 Goodwood buffer and adjoining land to be made a strategic site for employment space as not affected by noise pollution and will not contribute further to noise pollution.

S30a & S30b are draft corridors as the biodiversity study is incomplete at the time of this consultation and will need to be re-consulted on.
Al 1 is incomplete as presented. The settlement boundary should extend to include sites to the North to accommodate the unmet housing need as an exemption site for affordable homes 100% within 5 miles of the need as required in statute (unless the unmet housing need is returned to SDNP as it should be).
AL4 the land proposed for removal should not be removed as a strategic employment site and should be included in the plan as any development will not be affected by the noise buffer and will not contribute to further light and other pollution not currently present at this commercial site. The settlement to the north should be extended as per statements in AL1
AL 6 is wholly inappropriate for development:
It affects the AONB on its border including the following:
There will be increased light pollution and noise pollution, waste water issues and habitat risk.
The only view of cathedral from the sea will be lost.
This is a flood plain and is therefore totally unsuitable for residential property.
Green buffer between Chichester and Manhood-
If the proposed link road goes ahead, the views of cathedral framed by South Downs will be lost.
Traffic congestion onto the Fishbourne roundabout moves pollution and provides absolutely no purpose and is a ruse to get option 2 delivered with no evidence of being supported by HE as there is no indication of a consultation.

Whilst there is a movement away from car use and getting both adults and children to use bicycles for transport and fitness the important, safe and tourist attracting cycle path of Salterns Way will be lost.
Requirement for infrastructure (schools) which can be met with development in North with 100% exception site to meet unmet housing need of SDNP.
The employment space is in a flood plain

This Policy is insufficiently developed to be meaningful. There is nothing in the Evidence Base (as at the last afternoon for public consultation) in relation to "the forthcoming Chichester Vision - Transport Feasibility Study", which means that no-one taking part in this consultation can be expected to know what this Policy S14 means!
This Policy is crucial to the Plan's Strategic Objectives, including for "safe, clean" communities and Health and Well-Being, as well as Environment. I strongly object to it being brought forward for consultation without adequate detail. This aspect of the Plan should be re-opened for public consultation when CDC can evidence the aforementioned Transport Feasibility Study and respondents are able to consider the full picture. SB1 map should include an employment space and residential strategic site as an exception site for the SDNP unmet housing need. South and east of Goodwood is an ideal site for employment space and then the areas South of Lavant outside the SDNP to be inserted as a strategic site for 100% affordable homes (exception) to meet the unmet need from SDNP.

The decisions on Chichester's housing, roads, employment areas and the infrastructure to support all of these cannot be done piecemeal. The various proposed housing developments, green living and areas such as Southern gate will all be affected by the roads, these issues all need to be discussed and formed as one overall, if longterm, development plan.

Comment

Local Plan Review: Preferred Approach 2016-2035

Representation ID: 2214

Received: 07/02/2019

Respondent: Environment Agency

Representation Summary:

At this stage we do not support the inclusion of this site within the Plan:
- need further evidence to support allocation e.g. SFRA Part 2
- understanding of risk of link road flooding
- policy does not ref flood risk - need to be amended
- consider how proposals could be delivered & identify mitigation measures
- all housing devt within FLood Zone 1
- issues of watercourses & impacts on biodiversity/water quality
- concerns over wastewater

Full text:

Thank you for the consultation on the above document. We have reviewed the document and have the following comments to make in response.

Summary
Overall we are pleased to see that the Plan provides a framework to ensure that new
development will take place in a considered manner to address environmental constraints as well as provide policy hooks for the delivery of environmental enhancements. However, to ensure that the Plan is as effective as possible and meets necessary policy and legislative requirements we have made some recommendations for improvements. These are set out in detail below. Where we support a policy we have also highlighted this below.

We have highlighted concerns with policy AL6 - Land SW of Chichester and have made recommendations for more significant changes to policies in relation to flood risk management (both strategic and development management) and wastewater management and water quality.

As a general comment we note that a significant proportion of the housing numbers
proposed through the Local Plan will be delivered by Neighbourhood Plans. We have
highlighted key criteria for individual locations that we would wish to see considered by those Plans when allocating sites. Where possible we would wish to see these included within the Local Plan policy but as you will be aware we have produced a checklist for Neighbourhood Plan groups in your District which will guide the identification of sites and other key issues and opportunities to be addressed in their Plans.
We would be happy to meet with you to discuss further any of our comments and support the rewording of the policies prior to the production of a pre-submission Plan.

Specific comments

Strategic policies
Policy S12 - Infrastructure
Overall we support the policy. We would recommend that paragraph 3 be amended to
include reference to flood risk management infrastructure.

Policy S17 - Thorney Island
We are currently exploring opportunities for habitat creation in an area on Thorney Island. This is part of our Habitat Creation Programme which seeks to create new habitat to offset losses elsewhere as a result of sea level rise and implementation of coastal and flood risk management infrastructure.
Whilst the policy as drafted, along with other policies in the Plan, would not restrict this opportunity we would like you to consider whether further wording could be included to provide specific support for habitat creation.

Policy S18 - Integrated Coastal Zone Management
We support the continued inclusion of this policy and the specific references to key Plans.
We also support the intention that financial contributions should be sought to deliver both flood risk management infrastructure as well as improvements to the quality of watercourses in the area.

Policy S20 - Design
We support the specific requirements of this policy in point 5 and 8 with regard to green infrastructure and enhancing biodiversity and climate change resilience.

Policy S23 - Transport and Accessibility
The policy includes a new road connecting Birdham Road to the A27 Fishbourne
roundabout. The site includes areas within flood zones 2 and 3 and will cross a number of watercourse. It is essential that the requirements of the NPPF paras 157-8 are satisfied prior to the allocation. We have made detailed comments on this in relation to policy AL6 - Land South West of Chichester.

Policy S25 - The Coast
We are pleased to see the support in this policy for future habitat creation as well as the delivery of flood defences and adaptation to climate change. This supports principles of net environmental gain advocated through the NPPF and the 25 Year Environmental Plan as well as providing necessary policy hooks to support our future plans through our Habitat Creation Programme.
As we highlighted through the Issues and Options consultation this Programme was set up to deliver the compensatory habitat required to address the losses in habitat that would take place as a result of the flood and coastal risk management measures identified in the Shoreline Management Plans. There are specific locations within Chichester District which offer opportunities to provide saltmarsh and coastal grazing marsh in the medium to longer term. These locations include areas in Fishbourne, Chidham and Hambrook and on Thorney Island.

Policy S26 - Natural Environment
We would recommend that the policy wording be extended to say "protect and enhance biodiversity". This is consistent with the NPPF requirements in para 170 regarding net gain and current Government proposals to mandate biodiversity net gain for all new developments.

Policy S27 - Flood Risk Management
We support the intention of the policy, however, we would wish to see changes made to ensure the policy is as clear as possible. We would also recommend you consider what a strategic policy on flood risk management is seeking to achieve in addition to the development management policy. As drafted there are some duplications and/or inconsistencies between the two policies.
It may be more prudent to have a shorter overarching policy that seeks to ensure that flood risk will be taken account of at all stages in the planning process in order to avoid inappropriate development in areas at current or future risk (taking into account climate change) and to direct development away from areas of highest risk. Reference could and should be made to the Strategic Flood Risk Assessment to enable this. We would also support a requirement here for development to seek to achieve a reduction in flood risk for existing communities on and off site.
The principle of point 3 is supported but again should be considered whether it sits best within the development management policy.
We would recommend removing point 4. It is not clear entirely what the rationale behind this is but as drafted it suggests that development within areas with a certain level of flood risk would be approved. This should only be the case when the sequential and exception test have been satisfied in accordance with the NPPF paragraph 157- 8. I would be happy to discuss this further if the intention behind the statement is different.

Policy S29 - Green Infrastructure
We support the policy and are pleased to see specific reference to "blue" infrastructure.

Policy S30 - Strategic Wildlife Corridors
We are supportive of this policy and believe it provides a strong framework for the protection and enhancement of biodiversity within the Plan Area. In particular we support the corridors along watercourses and the links with Biodiversity Opportunity Areas.
As previously highlighted in our Issues and Options response to the Local Plan the
Environment Agency are looking to deliver more natural flood management (NFM) measures to complement and support traditionally engineered flood defenses. This is about working with natural processes in whole catchments and has the potential to help us manage and reduce flood risk in a more efficient, cost effective and sustainable way whilst securing wider environmental benefits. We would be interested to discuss whether the Strategic Wildlife Corridors Background Paper could be expanded upon to consider these opportunities.
A nationally consistent set of opportunity maps to indicate potential for natural flood
management have been produced and I have attached a briefing not which shows how you can access this screening information. The identification and safeguarding of wildlife corridors could support our further work on NFM in the Chichester District and we would welcome the opportunity to discuss this further. In particular we would be interested to discuss whether the Strategic Wildlife Corridors Background Paper could be expanded upon to consider these opportunities.

Policy S31 - Wastewater Management and Water Quality
We support the intention of this policy, however, we recommend that the policy is amended to ensure that specific issues associated with the Apuldram WwTW catchment are addressed and that wider opportunities for the necessary protection and enhancements of water quality in the catchments across the Plan area are taken forward through development. As drafted the supporting text to the policy talks primarily around wastewater treatment capacity and impacts on water quality. However, we would recommend that this is expanded to discuss wider water quality and water resources issues within the Plan area.
This should include reference to the Water Framework Directive and the South East River Basin Management Plan, for which the Council has an obligation to support their delivery.
We would wish to see the Plan include a policy that will ensure that the design and location of development will both protect and enhance water bodies, both surface and groundwater.
We are aware of a few adopted policies regarding water quality that you may wish to review ahead of the further iteration of your Plan. These include policy W DM1 - Water supply and quality in the Arun Local Plan and Policy 31 - Integrated Water Management and the water cycle in the Cambridge Local Plan. The Policy in the Arun Local Plan is subdivided in to 3 sections to cover issues of water supply, water quality and catchment specific measures.
This approach or layout may be useful for you to consider here.
You may also wish to consider whether there are elements of this policy that would be better situated in a development management policy to direct decision making on individual sites.
I would be happy to work with you further to develop this policy, however, to support this the following identifies some key wording that could be included:
"All new development must demonstrate:
* That it has no adverse impact on the quality of water bodies and groundwater, or will prevent future attainment of good status;
* That development contributes positively to the water environment and its ecology and does not adversely affect surface and ground water quality"
This will reflect that impacts on water quality will not solely relate to wastewater infrastructure but can include diffuse pollution as well as physical changes to watercourses.
With regard to the specific requirements for the Apuldram WwTW the policy as drafted broadly reflects the current adopted Plan policy. Would there be an opportunity here for the policy to reflect elements of the recently endorsed Position Statement between the Environment Agency and Southern Water in terms of managing development in the catchment?
The policy makes reference to the higher building regulations standard of 110 l per person per day. We support this standard but would recommend you consider whether this detail is needed in this strategic policy as well as development management policy DM16 - Sustainable Design and Construction.

Site Allocations
Please note we have no additional comments to make on the sites that are being taken forward from the current adopted Local Plan as we consider that the key policy criteria we sought at that stage has been transposed across. We continue to support these requirements.

Policy S32 - Design Strategies for Strategic and Major Development Proposals
We support this policy and specifically requirements for issues such as green infrastructure and SuDS to be fully considered through a Masterplan. Without this overarching vision for larger sites it is often difficult to provide a comprehensive scheme to address key environmental constraints and opportunities.

Policy AL13 - Land East of Chichester
There is a small area within the site located in Flood Zone 2, along with an additional surface water body (lake). We would recommend that the masterplan for this site fully considers these constraints in designing the site including the adopting the sequential approach. We would wish to see built development located solely within Flood Zone 1.

Policy AL 5 - Southern Gateway
We have previously made comments on the proposals for the Southern Gateway through the adopted masterplan for the site. As highlighted there are a number of constraints to development in this area, however, we are pleased to see specific criteria in the policy toensure that these key constraints to the site within our remit are fully considered.
These are:
- Bullet 8 which requires the provision of a wastewater management plan which
demonstrates no net increase in flow to the Apuldram WwTW. This is in line with the
Surface Water and Foul Drainage SPD and the Position Statement on managing new
housing development in the Apuldram (Chichester) Wastewater Treatment Works
Catchment agreed between the Environment Agency and Southern Water.
- Bullet 10 which sets out the requirement for a Flood Risk Assessment to address the
specific flood risk issues on the site. We would recommend that this policy criteria
could be expanded upon to require the sequential approach within the site and to
ensure that more vulnerable uses such as housing be located in the lowest areas of
flood risk.

Policy AL6 - Land SW of Chichester
At this stage we do not support the inclusion of this site within the Plan.
The allocation is composed of housing, employment and a road scheme. Large areas of the allocation falls within flood zones 2 and 3 and we would wish to see further evidence to support this allocation. This may be as part of a Level 2 Strategic Flood Risk Assessment for this site which would then inform a Sequential and if necessary an Exceptions Test. The assessment would need to consider how the proposals could be delivered and identify any mitigation and/or compensation measures that may be necessary to ensure that the development is safe and that there is no increase in flood risk to third parties.
Whilst we note that there are areas outside of the flood plain within the allocation and that some of the development could avoid these areas it is anticipated that the road would cross the flood plain and therefore further detailed understanding of this risk and how it would be managed should be provided.
As drafted the policy makes no reference to flood risk and we would wish to see this
amended.
With regard to housing development we would wish to ensure that all development be located in Flood Zone 1 and that the policy criteria would reflect this.
Other issues include the crossing of watercourses and impacts on biodiversity and water quality. This should be referenced within the policy criteria with requirements for any watercourse crossings to be clear span in design. This will ensure that flood water conveyance is not impeded and protect the habitat associated with those watercourses.
In addition to flood risk we also have concerns with regard to where the sites wastewater would drain to. In line with our Position Statement on managing new housing development in Apuldram (Chichester) Wastewater Treatment Works Catchment allocations within the Local Plan should not drain to the Apuldram WwTW but be directed to alternative WwTW catchments, notably Tangmere WwTW via the new sewer pipeline connection once operational.
It is difficult to understand how this site would connect to an alternative WwTW and therefore would question whether the site would be deliverable.

Policy AL9 - Fishbourne
Fishbourne parish falls within the Apuldram WwTW catchment and we would recommend that the policy makes specific reference to the issues that the Neighbourhood Plan group should consider when identifying sites for their Local Plan.
We would also recommend that specific reference is made to the Source Protection Zone that covers part of the parish in order to ensure that the groundwater, and in turn the drinkingwater supply, is protected.

Policy AL11 - Hunston
There are parts of Hunston that fall within flood zones 2 and 3. We would recommend that if possible the policy makes reference to the fact that built development should be located solely in Flood Zone 1. If this is not possible some reference would need to be made to flood risk and the requirement for the Neighbourhood Plan group to fully consider this through their site allocation process. If sites were to be allocated in flood zone 2 or 3 it is likely that the Plan would need to be supported by a Level 2 SFRA or equivalent.

Policy AL13 - Southbourne Parish
Point 16 identifies the need to ensure that sufficient capacity is available at the relevant Wastewater Treatment Works prior to the delivery of development. This could be expanded to include sewer network capacity. Liaison with Southern Water regarding any necessary phasing of development would be encouraged.

Development Management Policies

Policy DM5 - Accommodation for GTTTS
We support the specific criteria in this policy to ensure that GTTS sites are not located in areas at risk of flooding.

Policy DM14 - Caravan and Camping Sites
We support the particular reference to restricting the occupancy of these sites in flood risk areas. However, there is no specific mention that flood risk areas should be avoided where possible. We would recommend that this should be included within the policy criteria.

Policy DM15 - Horticultural Development
We are pleased to see specific reference to the need to demonstrate adequate water
resources are available and/or water efficiency measures.

Policy DM16 - Sustainable Design and Construction
We support the requirement for new development to achieve a water usage of a maximum of 110litres per head per day.
For completeness we recommend that point 5 should be expanded to include compensation as well as make reference to net gain. This is in line with NPPF para 170.
We support the requirement in point 8 with regard to measures to adapt to climate change.

Policy DM18 - Flood Risk and Water Management
para. 7.115 - reference to the Environment Agency should be removed from this sentence.
The responsibility for surface water drainage and consideration of SuDS sits with West Sussex County Council as the Lead Local Flood Authority for this area.
para. 7.116 - vulnerability - it should be noted that not all development types would be appropriate in all flood zones. Basement dwellings would not be supported in flood zone 3. This paragraph should be amended to reflect this.
We would recommend that you review this policy alongside the strategic policy on flood risk to ensure that they are complementary. Whilst the intention of the policy is good some further clarity could be provided to ensure that all sources of flood risk are considered through decision making.
As drafted there is no reference to the Sequential Test which is a key step in decision
making with regard to proposals in a flood zone. It appears that a number of the criteria included in policy 42 of the current adopted Local Plan have been stripped out. We would recommend further consideration of this for the next iteration of the Plan.
We note that the policy also makes reference to wider water management and does refer tothe South East River Basin Management Plan, however, as per our comments on policy S31 we would wish to see a specific policy that provides for the protection and enhancement of water quality. It may be prudent to consider whether an overarching strategic policy to address flood risk and water management would be best with separate detailed development management policies for each topic.
We would be happy to work with you regarding this detail.

Policy DM20 - Development around the coast
We support this policy and the requirement to safeguard a strip of land behind existing or proposed sea defence or coastal works. Please note that the Environment Agency would seek a 16 metre buffer behind any of our tidal defences.
We support the specific requirement to ensure that development for boat or marine use would not be detrimental to water quality.

Policy DM24 - Air Quality
We are pleased to see that this policy recognises that new development may be located near to existing uses that may be potentially polluting to housing. It is important that the onus should be on the developer/applicant to manage any impact to ensure that they don't leave the existing user affected, e.g. by complaints.

Policy DM26 - Contaminated Land
We support this policy as drafted.

Policy DM29 - Biodiversity
We support this policy as drafted and are pleased to see that specific reference has been
provided to ensure that net gain in biodiversity is actively pursued. Consideration should be
given to the current Government consultation on mandating biodiversity net gain in all new
development and whether this may require further strengthening of the policy wording.
Policy DM32 - Green Infrastructure
We support policy.

Attachments:

Object

Local Plan Review: Preferred Approach 2016-2035

Representation ID: 2238

Received: 06/02/2019

Respondent: Mr Andrew Thrasher

Representation Summary:

Object to AL6 due to conflict with Policy S27 Flood Risk Management.

The land is part of an Active floodplain of the Lavant and in wet winters there is flooding. Rising sea levels are likely to mean a higher water table and increased risk of flooding in Apuldram Lane South which already floods in winter. Concreting over 35ha of land will seriously reduce the ability of the floodplain to sponge up excess water and a raised linkroad will act like a dam, increasing the risk of flooding in neighbouring estates, the proposed 33ha industrial estate, 100+ houses or the A27!

Full text:

AL6/S27 The land in AL6 is part of an Active floodplain of the Lavant and in wet winters there is flooding. Rising sea levels are likely to mean a higher water table and increased risk of flooding in Apuldram Lane South which already floods in winter. Concreting over 35ha of land will seriously reduce the ability of the floodplain to sponge up excess water and a raised linkroad will act like a dam, increasing the risk of flooding in neighbouring estates (Graydon Avenue etc), the proposed 33ha industrial estate, 100+ houses or the A27!

Object

Local Plan Review: Preferred Approach 2016-2035

Representation ID: 2241

Received: 06/02/2019

Respondent: Mr Andrew Thrasher

Representation Summary:

Object to AL6 due to conflict with Policy S26 Natural Environment.

This is a rich biodiverse area for wildlife, I've seen many species here that I've not seen elsewhere in Apuldram. It is good habitat for water voles, the Lavant flows all year and there is little human disturbance. The wildlife areas and ditch systems provide supporting habitat for Chichester Harbour AONB and should not be built on.
Most of the rest of AL6 is intensively farmed productive farmland which should be kept in production and not built on and lost forever

Full text:

AL6/S26 This (SU846038) is a rich biodiverse area for wildlife, I've seen many species here that I've not seen elsewhere in Apuldram (including Scorpion fly, conehead, azure damselfly, Parhelophilus, Cercopsis and Gymnosoma Ladybird fly). It is good habitat for water voles, the Lavant flows all year and there is little human disturbance. The wildlife areas and ditch systems provide supporting habitat for Chichester Harbour AONB and should not be built on.
Most of the rest of AL6 is intensively farmed productive farmland which should be kept in production and not built on and lost forever.

Object

Local Plan Review: Preferred Approach 2016-2035

Representation ID: 2267

Received: 07/02/2019

Respondent: Mr and Mrs A Martin

Representation Summary:

Elevation of Birdham/Fishbourne road across flood plain takes pollution to bedroom window level.HE accept it would be upgraded to dual carriageway. Traffic tailbacks in holiday season caused by speed of access to coastal car parks not road infra-structure. Tailbacks will still occur obstructing access to business units on AL6. First stage of new southern by-pass by deceit. Major risk of obstruction to water vole and other wildlife corridors between Fishbourne meadow, Lavant, pond and ditches on AL6.

Full text:

1.Donnington residents will trapped having to travel west before going East where the major retail/business park has been developed by the LPA over recent years, adding 2+ miles to every vehicle movement or taking a shorter route through the city increasing pollution.(DM24&SP28) where Air Quality already fails to meet the required standards.
2.The Peter Brett report identifies a drainage ditch alongside Fishbourne roundabout as a constraint. The ditch links the Fishbourne meadows water vole habitat with the ditch network and River.Lavant. A survey a few years ago identified their presence in most of the ditches and they are known to visit the spring fed pond/lake halfway down the Mile Pond farmland (Site AL6) adjacent to Stockbridge settlement boundary.Threat to this network will be contrary to the Policies on ecology and biodiversity.
3.Site AL6 land includes a flood plain and HE previously confirmed any Appuldram link road would need to be elevated upto 4 metres. This will raise vehicle noise and pollution to the level of bedroom windows contrary to national guidance (Only new development will be protected by Policy DM25.not exisiting) Climbing vehicles produce more pollution due to greater load on the engine..Stockbridge already exceeds the statutory air quality limits.(Policy DM24 &SP28). Traffic pollution has been proven to be a cause of asthma and sleep interruption by traffic noise has been proven to affect mental health.
4. Necessary flood avoidance elevation will prevent noise mitigation screening without additional land commitment. If it was possible to provide it will obstruct views of Chichester cathedral and the Chichester Harbour ANOB 100 metres away.
5.The HE highways Planning Engineer at the A27 consultation admitted the link road would need to be upgraded to a dual carriageway within 10 years. This has not been identified. He also explained it is "HE's job to get the traffic off of the A27 as quickly as possible, the problems it causes on local roads is a matter for the local highway authority"!
6. The traffic which backs back to the A27 in the height of the summer season is not caused by the road capacity or design on the Manhood Peninsula but the speed with which vehicles can enter the car parks and other holiday destinations at the coast. The traffic will still back up and will obstruct access to any business units on site AL6 contrary to policy on easy access to industrial/business sites. It is difficult to get onto the Fishbourne roundabout from the A259 now without the additional traffic from new housing developments such as Whitebridge Farm.. An additional entrance/exit and priority to through traffic and the number of returning daytrippers who want to go east will make it impossible.
7. Plans for the A27 improvements are similar to HE option 3a which was strongly rejected by the community. Early in the 1970's the Stockbridge, Hunston and other junctions were controlled by traffic lights which were removed, because they caused congestion, and replaced by roundabouts. We have been there before!
8.The plans for the A27 junction improvements give priority to through traffic and completely ignores local traffic and local people and businesses.
9. With the prevailing wind from the SW (source WSCC weather) air pollution will continue to be distributed across the whole of Chichester including the developing lungs of pupils at Bishop Luffa, the High School and Kingsham Primary.
10 there is a strong suspicion that the long term plan is to extend the Fishbourne/Birdham link road incrementally to join Hunston, Bognor Road and then on to rejoin the A27 thereby achieving a second southern by-pass and strategic route by stealth, avoiding proper scrutiny and inquiry by the Government Inspector .
11There are mature trees on existing roundabouts which help to absorb CO2 which will be destroyed by hamburger route clearance.

Comment

Local Plan Review: Preferred Approach 2016-2035

Representation ID: 2268

Received: 01/02/2019

Respondent: Historic England

Representation Summary:

According to our records, the site Land South-West of Chichester (Apuldram and Donnington Parishes) contains no designated heritage assets. We therefore have no comment on the principle of the allocation, although we would expect its potential for non-designated archaeology to have been assessed, with reference to the Council's Historic Environment Record, in accordance with paragraph 187.

Historic England welcomes and supports clause 3.

This comment is without prejudice to any comments we may wish to make on any planning application that may be submitted for the development of this site.

Full text:

Paragraph 1.5 of the Local Plan Review states "This Plan seeks to balance the economic, social and environmental dimensions of sustainable development". "Balance" implies some gains and some losses. However, this does not reflect the four bullet points that follow this sentence.
In addition, Paragraph 8 of the National Planning Policy Framework explains that;
"Achieving sustainable development means that the planning system has three overarching objectives, which are interdependent and need to be pursued in mutually supportive ways (so that opportunities can be taken to secure net gains across each of the different objectives)".

We therefore suggest that "balance" is not the most appropriate word.

The three overarching objectives include; "c) an environmental objective - to contribute to protecting and enhancing our natural, built and historic environment......". We therefore welcome the fourth bullet point of paragraph 1.5; "Protecting and enhancing the unique and special qualities of our environment".

Reword the first sentence of paragraph 1.5 as; "This Plan seeks to deliver the economic, social and environmental dimensions of sustainable development in mutually supportive ways".

Paragraph 1.16 explains that the National Planning Policy Framework reiterates the importance of significantly boosting the supply of new dwellings, whilst ensuring provision for other development needs including economic growth.
Whilst not untrue, we consider that this does not fully represent the Government's objectives and policies as set out in the Framework and therefore gives the misleading impression that the Framework is only about housing supply and economic development.
In fact, the protection and enhancement of the natural, built and historic environment is also identified as important in the Framework e.g. in the environmental overarching objective for the planning system as set out in paragraphs 8, 11b)i and 20 d).
Reword the final sentence of paragraph 1.16 as:
"The importance of significantly boosting the supply of new dwellings is reiterated, whilst ensuring provision for other development needs including economic growth and protecting and enhancing the natural, built and historic environment".
Paragraph 31 of the National Planning Policy Framework requires "The preparation and review of all policies should be underpinned by relevant and up-to-date evidence". We previously expressed our concerns about the historic evidence base for the policy framework for the district when commenting on the Issues and Options stage of the Local Plan Review;
"We are aware of the Council's series of Conservation Area Character Appraisals, The Future Growth of Chichester Study and the Landscape Capacity Studies. However, the Council's "Supporting documents" webpage has no historic environment documents and we are not clear if the Council has other historic environment evidence e.g. is there an extensive urban survey of Chichester or other townscape or characterisation study ? Is there an urban archaeological database ? Is there a list of locally important heritage assets ? Has the Council undertaken a survey of grade II buildings at risk ?".
However, looking at the Council's Local Plan Review Preferred Approach Plan - Evidence Base - December 2018 webpage, the only specific historic environment evidence base document identified is the Chichester Historic Environment Strategy and Action Plan. Whilst we welcome the Strategy, we have previously expressed the view that we do not consider that it forms, by itself, an adequate historic environment evidence base for the Local Plan Review.
We are aware that the Council has a list of locally important buildings, but that Chichester was not covered by the West Sussex Extensive Historic Town Surveys - perhaps as it was thought a candidate for the more intensive approach of an Urban Archaeological Database (UAD). However, we are not aware that such a UAD exists, and whilst we are aware of the Council's Historic Environment Record (the availability of which accords with paragraph 187 of the National Planning Policy Framework), we do wonder if the archaeological evidence and significance of the city is fully understood and readily available. We suggested that the Historic Environment Strategy could set out actions to enhance understanding and management of the archaeological resource of the historic city and we would be pleased to discuss how we might be able to assist with this.
We will expect the Council to have an adequate, up-to-date and relevant historic environment evidence base and to demonstrate in the Pre-Submission Local Plan how that historic evidence base has informed and influenced the Plan's policies and site allocations.
The historic environment evidence base for the Local Plan Review should be set out on the Council's Evidence Base webpage. If there are indeed gaps in that evidence base, then these should be filled and that evidence taken on board in preparing the Pre-Submission Local Plan Review document.
Historic England welcomes and supports the reference to the historic environment of Chichester district, and the heritage assets therein, in paragraphs 2.27 and 2.28 as part of the positive strategy for the conservation and enjoyment of the historic environment required by paragraph 185 of the National Planning Policy Framework.

Historic England welcomes and supports, in principle, the identification of "Protect the area's valuable heritage and historic assets" as one of the challenges faced by the Plan.
However, the National Planning Policy Framework requires local plans to deliver an environmental overarching objective which includes "to contribute to conserving and enhancing our natural, built and historic environment" (paragraph 8 c)) and to include strategic policies to make sufficient provision for "conservation and enhancement of the natural, built and historic environment" (our underlining).
The Framework therefore requires local planning authorities, through their local plans, to do more than just conserve the historic environment i.e. to enhance it as well. This should be identified as a challenge (although it is also an opportunity).
Reword the last bullet point of paragraph 2.28 as; "Protect and enhance the area's valuable heritage and historic assets".
Historic England welcomes, in principle, as part of the positive strategy for the conservation and enjoyment of the historic environment required by paragraph 185 of the National Planning Policy Framework, the reference to the historic environment in paragraph 3.1;

"It is the intention of the Council to enable the delivery of infrastructure, jobs, accessible local services and housing for future generations while supporting the historic and natural environment".

However, the National Planning Policy Framework refers to "conserving and enhancing our natural, built and historic environment" (paragraph 8 c)) and the "conservation and enhancement of the natural, built and historic environment". We therefore suggest that "supporting" should be "conserving and enhancing" as terminology more consistent with the Framework and possibly ambiguous than "supporting".

Reword the first sentence of paragraph 3.1 as;
"It is the intention of the Council to enable the delivery of infrastructure, jobs, accessible local services and housing for future generations while conserving and enhancing the historic, built and natural environment".
Historic England welcomes the inclusion of "Have a quality of life that is enriched through opportunities to enjoy our local culture, arts and a conserved and enhanced heritage;" in the Vision as part of the positive strategy for the conservation and enjoyment of the historic environment required by paragraph 185 of the National Planning Policy Framework.
Historic England welcomes "As an historic walled cathedral city, its rich cultural and architectural heritage will be conserved, enhanced and promoted together with the views and landscape value afforded by its setting" in paragraph 3.4 as part of the positive strategy for the conservation and enjoyment of the historic environment required by paragraph 185 of the National Planning Policy Framework.
Historic England welcomes and supports "The conservation and enhancement of the historic environment, the high quality landscapes and the agricultural and other rural activities that support it will remain paramount" in paragraph 3.14 as part of the positive strategy for the conservation and enjoyment of the historic environment required by paragraph 185 of the National Planning Policy Framework.
Historic England welcomes and supports, in principle, the Strategic Objective "Conserve and enhance landscape and heritage" as part of the positive strategy for the conservation and enjoyment of the historic environment required by paragraph 185 of the National Planning Policy Framework. However, we suggest that it could be rather more ambitious e.g. "Conserve, enhance, increase appreciation and enjoyment of and access to heritage"
Paragraph 4.2 states that; "New development must achieve sustainable development principles and must not adversely affect the character, quality, amenity or safety of the built environment, wherever it occurs". The implication is that this is a requirement of the National Planning Policy Framework, but we cannot find this exact wording in the Framework.

However, paragraph 127 of the Framework does set out what planning policies and decisions should ensure of developments, including "are sympathetic to local character and history" and "establish or maintain a strong sense of place". In addition, paragraph 185 of the Framework requires plans to set out a positive strategy for the conservation and enjoyment of the historic environment, which should take into account "the desirability of new development making a positive contribution to local character and distinctiveness".

We therefore consider that the final sentence of paragraph 4.2 should be revised to more closely reflect the requirements of the National Planning Policy Framework.

Reword the final sentence of paragraph 4.2 as ""New development must achieve sustainable development principles, must not adversely affect the history, quality, amenity or safety of the natural, built and historic environment and should make a positive contribution to local character and distinctiveness and establish or maintain a sense of place". (Alternatively, these could be set out as bullet points for clarity).
Historic England welcomes and supports "enhance the quality of the built, natural, historic, social and cultural environments" in Policy S2 as part of the positive strategy for the conservation and enjoyment of the historic environment required by paragraph 185 of the National Planning Policy Framework.
Although the historic environment is not identified as a constraint or as an opportunity for enhancement in paragraph 4.12 as a factor in the definition of the Settlement Hierarchy, we note that paragraph 4.14 does explain that consideration has been given to other factors in determining whether a settlement is a suitable location for additional housing growth. We would like to think that these other factors include the potential effects on the historic environment.
Historic England welcomes and supports "where possible enhances the character, significance and setting of heritage assets" as one of the considerations to guide potential discussions on a possible site for a new settlement in paragraph 4.33 as part of the positive strategy for the conservation and enjoyment of the historic environment required by paragraph 185 of the National Planning Policy Framework.
Historic England welcomes and supports "it is acknowledged that new development needs to be planned sensitively with special regard to the unique character of the city's historic environment and setting, and should be underpinned by historic characterisation assessments" in paragraph 4.90 as part of the positive strategy for the conservation and enjoyment of the historic environment required by paragraph 185 of the National Planning Policy Framework.
Nevertheless, we suggest that reference should also be made to heritage impact assessments to underpin the planning of new development.
Reword paragraph 4.90 to read;
"it is acknowledged that new development needs to be planned sensitively with special regard to the unique character of the city's historic environment and setting, and should be underpinned by historic characterisation assessment and heritage impact assessments".
Historic England welcomes and supports "such development will need to be sensitive to the
historic character of the city" in paragraph 4.91 as part of the positive strategy for the conservation and enjoyment of the historic environment required by paragraph 185 of the National Planning Policy Framework.
Historic England welcomes and supports "conserve and enhance the city's historic character and heritage", "Enhance the city's existing heritage, arts and cultural facilities", "Protect views of the cathedral" and "All development will be required to have special regard to the city's historic character and heritage. Development proposals should be underpinned by historic characterisation assessments and make a positive contribution to the city's unique character and distinctiveness" in Policy S13 as part of the positive strategy for the conservation and enjoyment of the historic environment required by paragraph 185 of the National Planning Policy Framework.
Nevertheless, we would like to see a reference to heritage impact assessments to underpin development proposals.
We also wonder if it would be helpful to have a specific policy to protect important views, allied to or combined with a policy for tall buildings in the historic city ?
Reword Policy SP13 to read "Development proposals should be underpinned by historic characterisation assessment and a heritage impact assessment......".
Historic England welcomes and supports "Any development proposals within the vicinity of the site must clearly demonstrate how the development would protect, and where possible enhance, the operation and heritage of the site as a motor-circuit and airfield" in Policy S15 as part of the positive strategy for the conservation and enjoyment of the historic environment required by paragraph 185 of the National Planning Policy Framework.
Historic England welcomes and supports "All proposals must ensure that the cultural and historical significance of the military facilities (and any other significant archaeological assets) located on the site, are understood and inform the scope of future development of that site" in Policy S17 as part of the positive strategy for the conservation and enjoyment of the historic environment required by paragraph 185 of the National Planning Policy Framework.
However, we would prefer "significant archaeological assets" to be retained in situ.
Reword Policy S17 as;
"All proposals must ensure that the cultural and historical significance of the military facilities (and any other significant archaeological assets) located on the site, are understood and inform the scope of future development of that site, with any significant archaeological assets retained in situ".
Paragraph 2.2 of the Plan notes that the North of the Plan Area has "rich cultural and heritage assets". We are surprised, therefore, that paragraph 4.128 has no mention of these assets.
Reword paragraph 4.128 "This part of the plan area is predominantly rural with few sizeable settlements, characterised by undulating countryside with a high proportion of woodland, typical of the Low Weald landscape. Conserving the rural character of the area, with its high quality landscape and natural and historic environment, is a key objective".
Historic England welcomes and supports "Conserve and enhance the rural character of the area, the quality of its landscape and the natural and historic environment;" in Policy S19 as part of the positive strategy for the conservation and enjoyment of the historic environment required by paragraph 185 of the National Planning Policy Framework.
Historic England welcomes paragraph 5.1 as part of the positive strategy for the conservation and enjoyment of the historic environment required by paragraph 185 of the National Planning Policy Framework.
Strictly-speaking, historic parks and gardens are registered for their special historic interest rather than their protection per se, but one of the purposes of Registration is to encourage appropriate protection and inclusion on the Register is a material consideration in the determination of planning applications.
Historic England welcomes paragraph 5.5 as part of the positive strategy for the conservation and enjoyment of the historic environment required by paragraph 185 of the National Planning Policy Framework.
Historic England welcomes and supports Policy S20, particularly the references to history, historic character and local identity in clause 1, sense of place in clause 2, character in clause 8 and high quality public realm in clause 11 as part of the positive strategy for the conservation and enjoyment of the historic environment required by paragraph 185 of the National Planning Policy Framework.
However, we would also like to see a specific clause relating to heritage assets.
Add a new clause; "conserves or enhances the significance, special interest, character and appearance of heritage assets".
Historic England welcomes and supports paragraph 5.12 as part of the positive strategy for the conservation and enjoyment of the historic environment required by paragraph 185 of the National Planning Policy Framework.
Historic England welcomes, in principle, paragraph 5.13 states that "Where development proposals might affect a heritage asset the Council will identify and assess the particular significance of the heritage asset and seek to avoid or minimise any conflict between the conservation of the heritage asset and any aspect of the proposal" as part of the positive strategy for the conservation and enjoyment of the historic environment required by paragraph 185 of the National Planning Policy Framework.
This very largely reflects paragraph 190 of the National Planning Policy Framework, but the Framework requires local planning authorities to take the particular significance of any heritage asset that might be affected by a proposal into account when considering the impact of a proposal on a heritage asset, "to avoid or minimise any conflict between the heritage asset's conservation and any aspect of the proposal". The requirement is clear - any conflict should be avoided or minimised; it is not sufficient to merely "seek to" avoid or minimise that conflict.

In addition, paragraph 189 of the Framework states;

"In determining applications, local planning authorities should require an applicant to describe the significance of any heritage assets affected, including any contribution made by their setting......Where a site on which development is proposed includes, or has the potential to include, heritage assets with archaeological interest, local planning authorities should require developers to submit an appropriate desk-based assessment and, where necessary, a field evaluation.

There is, therefore, a clear onus to be placed upon the applicant/developer to identify and describe the significance of any heritage assets affected.

Paragraphs 193, 194, 195 and 196 of the Framework set out how local planning authorities should consider the impact of a proposed development on the significance of a designated heritage asset. We believe that this could usefully be summarised in the Plan.

Reword paragraph 5.13;
"Where development proposals might affect a heritage asset the Council will identify and assess the particular significance of the heritage asset and take that significance into account when considering the impact of a proposal on a heritage asset, to avoid or minimise any conflict between the heritage asset's conservation and any aspect of the proposal".
Add new paragraphs;
"For applications which affect, or have the potential to affect, heritage assets the applicant will be expected to describe the significance of the asset and its setting, using appropriate expertise; at a level of detail proportionate to its significance and sufficient to understand the potential impact of the proposal; using appropriate references such as the Historic Environment Record and, if necessary, original survey (including, for assets of archaeological interest, an appropriate desk-based assessment and, where necessary, a field evaluation)";
"When considering the impact of a proposed development on the significance of a designated heritage asset, the Council will give great weight to the asset's conservation. Any harm to, or loss of, the significance of a designated heritage asset (from its alteration or destruction, or from development within its setting), will require clear and convincing justification"; and

"The Council will refuse proposals that would lead to substantial harm to (or total loss of significance of) a designated heritage asset unless it can be demonstrated that the substantial harm or total loss is necessary to achieve substantial public benefits that outweigh that harm or loss, or all of the circumstances in paragraph 195 of the National Planning Policy Framework apply. For proposals that would lead to less than substantial harm to the significance of a designated heritage asset, the Council will weigh this harm against the public benefits of the proposal".

Historic England welcomes and supports Policy S22, which we consider complies with the requirements of paragraphs 17 and 20 of the National Planning Policy Framework to contain strategic policies and for those strategic policies to make sufficient provision for the conservation and enhancement of the historic environment.

We also consider that the policy forms part of the positive strategy for the conservation and enjoyment of the historic environment required by paragraph 185 of the National Planning Policy Framework. We consider that the word "positive" is significant, and we believe that the Plan (and Council) should be proactive in the conservation and enhancement of the historic environment. National Planning Practice Guidance states "Such a [positive] strategy should recognise that conservation is not a passive exercise".
We therefore consider that the positive strategy for the conservation and enjoyment of the historic environment is not a passive exercise but requires a plan for the maintenance and use of heritage assets and for the delivery of development including within their setting that will afford appropriate protection for the asset(s) and make a positive contribution to local character and distinctiveness. We therefore look to local plans to contain commitments to positive measures for the historic environment. We therefore welcome the commitments within Policy S22 to positive actions, including heritage at risk, which paragraph 185 requires to be part of that positive strategy for the conservation and enjoyment of the historic environment. However, we do feel that the supporting text could helpfully explain a little more about the Council's approach to heritage at risk, perhaps borrowing some text from the Chichester Historic Environment Strategy and Action Plan.
We also consider that the positive strategy should comprise recognition throughout the Plan of the importance of the historic environment, of the historic environment's role in delivering the Plan's vision and the wider economic, social and environmental objectives for the Plan area, and of the potential impacts of the Plan's policies and proposals on the historic environment.
We are pleased to have identified a number of references throughout the Plan to the historic environment and we therefore consider that the Plan sets out an adequate positive strategy for the conservation and enjoyment of that historic environment as required by paragraph 185 of the National Planning Policy Framework and that the Plan is therefore compliant with that paragraph.

Add a new paragraph explaining what "heritage at risk" is and the Council's approach to assets at risk e.g.

"Unfortunately, heritage assets can be at risk from neglect, decay or other threats. Designated assets at risk, with the exception of Grade II secular buildings and Grade II places of worship used less than six times a year, are identified on the Historic England Heritage at Risk Register. Within the district outside the South Downs National Park, six assets are on the Register (February 2018): three scheduled monuments, two listed buildings and one conservation area. The Council will actively seek to address threats to heritage assets by recording and monitoring Heritage at Risk in Chichester District, publishing it on our website and working with the owners of heritage assets at risk to find solutions and secure repairs to bring them back into active use, including where appropriate viable new uses and/or proposals for enabling development so they are preserved for future generations."

Historic England suggests that paragraph 5.37 could also refer to the range of heritage assets to be found in the countryside of the Plan area.
Reword paragraph 5.37 as;

"It is valued for many reasons, including agriculture and community food production, its landscape qualities including the special characteristics of Chichester Harbour and Pagham Harbour, the setting it provides for Chichester City and other towns and villages, its range of heritage assets, including historic landscapes, and the opportunities it provides for recreation and biodiversity".
Historic England welcomes and supports clause d of Policy S32; "integrate with the surrounding built, historic and natural environments" as part of the positive strategy for the conservation and enjoyment of the historic environment required by paragraph 185 of the National Planning Policy Framework.
As noted in paragraph 6.12, the Chichester Entrenchments Scheduled Monument lies partly within and partly immediately to the north of the site. Paragraph 194 of the National Planning Policy Framework identifies Scheduled Monuments as being assets "of the highest significance", substantial harm to or loss of which should be wholly exceptional.

We have previously commented (as English Heritage) on the allocation of this site during the consultation on the Key Policies. We explained that development close to the earthworks might harm the historical value of the heritage asset by interrupting views between its parts and introducing incongruous land-use in its immediate surroundings. This in turn would make it difficult to appreciate the asset's open rural setting, its extensive linear nature and its purpose of enclosing large areas of open land.

Accordingly, we initially objected to the form of the allocation in the Key Policies, but subsequently withdrew that objection following amendments to the boundary of the Strategic Development Location on its northern side so that the boundary ran along the south edge of the belt of woodland in which the scheduled monument sits, thereby entirely excluding the monument from the SDL, and the allocation of the northern area of the amended site as open space.
We are therefore pleased to see that the Strategic Site Allocation still excludes the scheduled monument. We also welcome and support the following requirements of Policy AL1, which we consider provide, in principle, adequate protection for the Scheduled Monument in accordance with the National Planning Policy Framework:
6. Landscaped to protect priority views of Chichester Cathedral spire;
7. Keep land north of the B2178 in open use, free from built development, to protect the natural history interest of both Brandy Hole Copse, and the setting of the Chichester Entrenchments Scheduled Monument;
8. Conserve, enhance and better reveal the significance of the Chichester Entrenchments Scheduled Monument and other non-designated heritage assets and their settings and to record and advance understanding of the significance of any heritage assets to be harmed or lost;
However, this comment is without prejudice to any comments we may wish to make on any planning application that may be submitted for the development of this site.
Historic England makes no comment on the principle of the Shopwyke Strategic Site Allocation, which we note is an existing allocation.
However, the Grade II listed barn at Greenway Farm is located to the south-west of the site and the Grade II listed Shopwyke Grange and the Grade II* listed Shopwyke Hall are located to the south-east. Paragraph 194 of the National Planning Policy Framework states "Any harm to, or loss of, the significance of a designated heritage asset (from its alteration or destruction, or from development within its setting), should require clear and convincing justification". The paragraph identifies Grade II* buildings as assets of the "highest significance".

Historic England therefore welcomes and supports, in principle, the following requirement of Policy AL2, which we consider provide, in principle, adequate protection for the listed barn and Shopwyke Hall in accordance with the National Planning Policy Framework:
7. Protect existing views of Chichester Cathedral spire and conserve and enhance the historic significance of the listed barn at Greenway Farm and the cluster of buildings associated with the grade II* listed Shopwhyke Hall, which should be analysed at an early stage of the masterplan.
However, we consider that reference should also be made to the Grade II listed Shopwyke Grange. This comment is without prejudice to any comments we may wish to make on any planning application that may be submitted for the development of this site.
Reword criterion 7;"Protect existing views of Chichester Cathedral spire and conserve and enhance the historic significance of the listed barn at Greenway Farm, the listed Shopwyke Grange and the cluster of buildings associated with the grade II* listed Shopwhyke Hall which should be analysed at an early stage of the masterplan".
According to our records there are no designated heritage assets on this site, although the Grade II listed Shopwyke Grange and Grade II* listed Shopwyke Hall lie to the north-east of the allocated area, Paragraph 194 of the National Planning Policy Framework states "Any harm to, or loss of, the significance of a designated heritage asset (from its alteration or destruction, or from development within its setting), should require clear and convincing justification". The paragraph identifies Grade II* buildings as assets of the "highest significance".

We note that criterion 7 of Policy AL2 requires the development of the Shopwyke Strategic Site Allocation to ".......conserve and enhance the historic significance of the......cluster of buildings associated with the grade II* listed Shopwhyke Hall, which should be analysed at an early stage of the masterplan. We have suggested in our comments on this policy that it include reference to the listed Shopwyke Grange, and we consider that this requirement should also be included in Policy AL3 to provide, in principle, adequate protection for the listed barn and Shopwyke Hall in accordance with the National Planning Policy Framework.

Historic England welcomes and supports criterion 8 of Policy AL2; "Existing views of Chichester Cathedral spire are to be protected". However, this comment is without prejudice to any comments we may wish to make on any planning application that may be submitted for the development of this site.
Reword criterion 8 as;
"Protect existing views of Chichester Cathedral spire and conserve and enhance the historic significance of the listed Shopwyke Grange and the cluster of buildings associated with the grade II* listed Shopwhyke Hall which should be analysed at an early stage of the masterplan".
Historic England makes no comment on the principle of the two sites at Land at Westhampnett/North East Chichester Strategic Site Allocation, which we note were part of a broad strategic development location in the adopted Local Plan.
However, the site abuts the Graylingwell Hospital Conservation Area, the buildings of the former 'pauper lunatic asylum' (including the Grade II listed chapel), the Grade II listed Summersdale Farmhouse and a Grade II registered park and garden. Paragraph 194 of the National Planning Policy Framework states "Any harm to, or loss of, the significance of a designated heritage asset (from its alteration or destruction, or from development within its setting), should require clear and convincing justification".
Historic England therefore welcomes and supports, in principle, the following requirement of Policy AL4, which we consider provide, in principle, adequate protection for these designated assets in accordance with the National Planning Policy Framework:
9. Development should be designed with special regard to the Graylingwell Hospital
Conservation Area, the buildings of the former 'pauper lunatic asylum' and the Grade II registered park and garden in which they sit, and to other listed buildings in the vicinity of the site and their settings. Important views of Chichester Cathedral spire from the area should be protected;
This comment is without prejudice to any comments we may wish to make on any planning application that may be submitted for the development of this site.
Historic England makes no comment on the principle of the Southern Gateway Strategic Site Allocation.
However, the site includes a row of Grade II listed buildings on Southgate and a number of non-designated heritage assets (the southern gateway of the city had Roman roads converging upon it and this is likely to result in enhanced archaeological potential in this part of the city. The development of suburbs in the medieval and later periods is a further factor with both the canal and railway as examples of later uses of the area. There are a number of buildings of interest, including the former Law Courts and Bus Garage). Part of the site lies within the Chichester Conservation Area and there are listed buildings adjacent to the site.
Paragraph 184 of the National Planning Policy Framework states heritage assets "are an irreplaceable resource, and should be conserved in a manner appropriate to their significance, so that they can be enjoyed for their contribution to the quality of life of existing and future generations". Paragraph 194 of the Framework states "Any harm to, or loss of, the significance of a designated heritage asset (from its alteration or destruction, or from development within its setting), should require clear and convincing justification".

Historic England therefore welcomes and supports, in principle, the following requirements of Policy AL5;

3. Respect for the historic context and make a positive contribution towards protecting and enhancing the local character and special heritage of the area and important historic views, especially those from the Canal Basin towards Chichester Cathedral;
9. Include an archaeological assessment to define the extent and significance of any
archaeological remains and reflect these in the proposals, as appropriate;
However, we consider that these requirements should be strengthened to ensure that they provide adequate protection for these assets in accordance with the National Planning Policy Framework. In addition, we consider that Policy AL5 should promote more strongly the opportunity to use the heritage of the area to help define its character and the desirability of new development making a positive contribution to local character and distinctiveness as part of the positive strategy for the conservation and enjoyment of the historic environment required by paragraph 185 of the National Planning Policy Framework.
These comments are without prejudice to any comments we may wish to make on any planning application that may be submitted for the development of this site.
Reword clause 2 as follows;
Proposals should include a high quality distinctive design response appropriate to this gateway location and based on the character and heritage of the area, which establishes a clear hierarchy of streets and spaces, active frontages of buildings which front streets and spaces with clearly defined building lines;
Reword clause 3 as follows;
3. Respect for the historic context and make a positive contribution towards protecting and enhancing the local character and special heritage of the area, including the Conservation Area, listed buildings (both on and adjacent to the site), non-designated buildings of historic interest and important historic views, especially those from the Canal Basin towards Chichester Cathedral;
Reword clause 9 as follows;
9. Include an archaeological assessment to define the extent and significance of any
archaeological remains and reflect these in the proposals;
According to our records, the site Land South-West of Chichester (Apuldram and Donnington Parishes) contains no designated heritage assets. We therefore have no comment on the principle of the allocation, although we would expect its potential for non-designated archaeology to have been assessed, with reference to the Council's Historic Environment Record, in accordance with paragraph 187 of the National Planning Policy Framework which states;
Local planning authorities should maintain or have access to a historic environment record. This should contain up-to-date evidence about the historic environment in their area and be used to:
a) assess the significance of heritage assets and the contribution they make to their environment; and
b) predict the likelihood that currently unidentified heritage assets, particularly sites of historic and archaeological interest, will be discovered in the future.
Historic England welcomes and supports clause 3:
3. Protect existing views of Chichester Cathedral spire and the setting of the Chichester Harbour Area of Outstanding Natural Beauty which should be analysed at an early stage of the masterplan;
This comment is without prejudice to any comments we may wish to make on any planning application that may be submitted for the development of this site.
According to our records, the site at Highgrove Farm, Bosham, contains no designated heritage assets. We therefore have no comment on the principle of the allocation, although we would expect its potential for non-designated archaeology to have been assessed, with reference to the Council's Historic Environment Record, in accordance with paragraph 187 of the National Planning Policy Framework which states;
Local planning authorities should maintain or have access to a historic environment record. This should contain up-to-date evidence about the historic environment in their area and be used to:
a) assess the significance of heritage assets and the contribution they make to their environment; and
b) predict the likelihood that currently unidentified heritage assets, particularly sites of historic and archaeological interest, will be discovered in the future.
This comment is without prejudice to any comments we may wish to make on any planning application that may be submitted for the development of this site.

Historic England has no comments on the principle of land being allocated in the revised Fishbourne Neighbourhood Plan for a minimum of 250 dwellings.
However, we note that one of the specific issues that need to be taken into account in planning for development at Fishbourne identified in paragraph 6.65 of the Plan is "Protecting the heritage assets of Fishbourne and their setting".
We welcome the recognition and identification of this issue, but we consider that it should be included as a specific requirement in Policy AL9, to ensure that the allocation of the site or sites in the Neighbourhood Plan conforms with the National Planning Policy Framework, particularly paragraphs 184 and 194.
Add the following clause to Policy AL9;
"Demonstration that the development would not have an adverse impact on the significance of heritage assets, including listed buildings and the Fishbourne Roman site Scheduled Monument, or the character or appearance of the Fishbourne Conservation Area".
Historic England has no comments on the principle of land being allocated in the revised Chidham and Hambrook Neighbourhood Plan for a minimum of 500 dwellings.
However, we consider that Policy AL10 should include a specific requirement to ensure that the allocation of the site or sites in the Neighbourhood Plan conforms with the National Planning Policy Framework, particularly paragraphs 184 and 194.
Add the following clause to Policy AL10;
"Demonstration that the development would not have an adverse impact on the significance of heritage assets.
Historic England has no comments on the principle of land being allocated in the revised Hunston Neighbourhood Plan for a minimum of 250 dwellings.
However, we note that one of the specific issues that need to be taken into account in planning for development at Hunston identified in paragraph 6.77 of the Plan is "Respecting the setting of listed buildings and the Hunston conservation area".
We welcome the recognition and identification of this issue, but we consider that it should be included as a specific requirement in Policy AL11, to ensure that the allocation of the site or sites in the Neighbourhood Plan conforms with the National Planning Policy Framework, particularly paragraphs 184 and 194.
Add the following clause to Policy AL11;
"Demonstration that the development would not have an adverse impact on the significance of heritage assets, including listed buildings, or on the character or appearance of the Hunston Conservation Area."
According to our records, the site Land north of Park Farm, Selsey, contains no designated heritage assets. We therefore have no comment on the principle of the allocation, although we would expect its potential for non-designated archaeology to have been assessed, with reference to the Council's Historic Environment Record, in accordance with paragraph 187 of the National Planning Policy Framework which states;
Local planning authorities should maintain or have access to a historic environment record. This should contain up-to-date evidence about the historic environment in their area and be used to:
a) assess the significance of heritage assets and the contribution they make to their environment; and
b) predict the likelihood that currently unidentified heritage assets, particularly sites of historic and archaeological interest, will be discovered in the future.

This comment is without prejudice to any comments we may wish to make on any planning application that may be submitted for the development of this site.
Historic England has no comments on the principle of land being allocated in the revised Southbourne Neighbourhood Plan for a minimum of 1,250 dwellings.
However, we consider that a specific requirement should be included in Policy AL13 to ensure that the allocation of the site or sites in the Neighbourhood Plan conforms with the National Planning Policy Framework, particularly paragraphs 184 and 194.
Add the following clause to Policy AL13;
"Demonstration that the development would not have an adverse impact on the significance of heritage assets, including listed buildings, or on the character or appearance of the Prinsted Conservation Area."
Historic England has no comments on the principle of the allocation Land West of Tangmere.

However, the site is close to the Tangmere Conservation Area and a number of listed buildings, including the Grade I listed Church of St Andrew. Paragraph 194 of the National Planning Policy Framework states "Any harm to, or loss of, the significance of a designated heritage asset (from its alteration or destruction, or from development within its setting), should require clear and convincing justification". The paragraph identifies Grade I buildings as assets of the "highest significance".

Historic England therefore welcomes, in principle, clauses 5 and 8 of Policy AL14

5. Protect existing views of Chichester Cathedral spire and reduce any impact on views from within the National Park;
8. Conserve and enhance the heritage and potential archaeological interest of the village, surrounding areas and World War II airfield, including the expansion or relocation of the Tangmere Military Aviation Museum.
However, we consider that clause 8 should be strengthened to ensure that it provides adequate protection for these assets in accordance with the National Planning Policy Framework. In addition, we note that paragraph 6.95 of the Plan identifies, as one of the specific issues need to be taken into account in planning the development and site layout at Tangmere, "Conserving and enhancing the setting of the historic village (particularly the Conservation Area"). We consider that this should be included within Policy AL14.
This comment is without prejudice to any comments we may wish to make on any planning application that may be submitted for the development of this site.
Reword criterion 8 as follows:

8. Conserve and enhance the heritage and potential archaeological interest of the village, surrounding areas and World War II airfield, particularly the Conservation Area and the Grade I listed Church of St Andrew and including the expansion or relocation of the Tangmere Military Aviation Museum.
Add a new criterion as follows:
""Conserve and enhancie the setting of the historic village, particularly of the Conservation Area".
Historic England welcomes and supports clause b of Policy DM3 as part of the positive strategy for the conservation and enjoyment of the historic environment required by paragraph 185 of the National Planning Policy Framework.
Historic England welcomes and supports clauses 1 c and 2 e of Policy DM5 as part of the positive strategy for the conservation and enjoyment of the historic environment required by paragraph 185 of the National Planning Policy Framework.
Historic England welcomes, in principle, clause 2 of Policy DM13 but considers that the policy should be, in the first instance, to avoid adverse impact on the historic environment as part of the positive strategy for the conservation and enjoyment of the historic environment required by paragraph 185 of the National Planning Policy Framework. We consider that the wording used in Policies DM3 and DM5 would be appropriate.
Reword clause 2 of Policy DM13 as:
"Is located so as not compromise the essential features of nationally designated areas of landscape, historic environment or nature conservation protection".
Historic England welcomes and supports clause 1 of Policy DM17 as part of the positive strategy for the conservation and enjoyment of the historic environment required by paragraph 185 of the National Planning Policy Framework.
Historic England welcomes and supports clause b of Policy DM20 as part of the positive strategy for the conservation and enjoyment of the historic environment required by paragraph 185 of the National Planning Policy Framework.
Historic England welcomes and supports paragraph 7.129 as part of the positive strategy for the conservation and enjoyment of the historic environment required by paragraph 185 of the National Planning Policy Framework.
Many farm buildings that are now redundant for modern farming needs are likely to be of historic interest - it is acknowledged that farm buildings are generally under-represented on the National Heritage List for England. Historic England considers that Policy DM21 should include stronger protection for such buildings as part of the positive strategy for the conservation and enjoyment of the historic environment required by paragraph 185 of the National Planning Policy Framework.
Add a new criterion to Policy DM21 as follows:

"Features of architectural or historic significance are retained and, where the building forms part of a historically significant complex of buildings, consideration is given to the future use(s) of those buildings and the impact of the proposal on the integrity and character of the complex".
Historic England welcomes and supports, in principle, paragraphs 7.154 - 7.161.
However, we consider that paragraph 7.154 should be reworded to clarify the distinction between designated and non-designated heritage assets (the latter including buildings on the Local Buildings List for Chichester).
Reword paragraph 7.154 as follows:
"There are a large number of "Heritage Assets" (as defined in the National Planning Policy Framework), both designated and non-designated, in the plan area. Designated assets are Listed Buildings, Scheduled Monuments, Conservation Areas and Registered Historic Parks and Gardens. Non-designated assets include archaeological sites (although the remains may be of national significance equivalent to scheduled monuments, and which should be considered subject to the policies for scheduled monuments) and non-listed buildings which have been identified as locally important, such as those on the Local Buildings List for Chichester City and 'positive' buildings within Conservation Areas."
Historic England welcomes and supports in principle, Policy DM27 both as part of the positive strategy for the conservation and enjoyment of the historic environment as required by paragraph 185 of the National Planning Policy Framework and also as a non-strategic policy for the conservation and enhancement of the historic environment as suggested by paragraph 28 of the Framework.
However, we consider that clause e. should specify the (wholly) exceptional circumstances in which permission for a proposed development that would lead to substantial harm to (or total loss of significance of) a designated heritage asset would be granted i.e. where it can be demonstrated that the substantial harm or total loss is necessary to achieve substantial public benefits that outweigh that harm or loss, or all of the circumstances in paragraph 195 of the National Planning Policy Framework apply.

We would also welcome the policy being more detailed in terms of the considerations to be taken into account when assessing development proposals affecting the different types of heritage asset, as do, for example, Policies EH10, EH11, EH14 and EH15 of the West Oxfordshire Local Plan 2031. These policies were developed with Historic England and the Inspector that examined the Local Plan 2031 shared our concern that the historic environment policy in the Local Plan 2031 provided inadequate locally specific detailed policy guidance and considered the more detailed policies necessary for the Plan to be sound.

(However, we do acknowledge that the Inspector that examined the Key Policies development plan document considered the modified historic environment policy (Policy 47) put forward by the Council with our support was sufficient for the Plan to be sound, and that Policy DM27 in the Local Plan Review very largely repeats Policy 47).

Reword clause e. of Policy DM27 as follows;
"Development involving substantial harm to or loss of designated heritage assets will
only be granted in exceptional circumstances (wholly exceptional circumstances for
designated assets of the highest significance) i.e. where it can be demonstrated that the substantial harm or total loss is necessary to achieve substantial public benefits that outweigh that harm or loss, or all of the circumstances in paragraph 195 of the National Planning Policy Framework apply.

More details of the considerations to be taken into account when assessing development proposals affecting the different types of heritage asset. We would be pleased to work with the Council on a revised policy or policies.

Paragraph 7.195 of the Plan notes that the remnants of canals "are important early 19th Century historic features in the landscape of the coastal plain and warrant protection".
Historic England agrees with this statement, but Policy DM33 makes no mention of protecting the historic significance of the remaining canal sections.
Reword the first paragraph of Policy DM33 as follows;
"Development that makes provision of through navigation or enhancement of the Chichester Ship Canal and the Wey and Arun Canal will be supported where it meets environmental, ecological, historical and transport considerations."
Historic England welcomes and supports clause 3 of Policy DM34 as part of the positive strategy for the conservation and enjoyment of the historic environment required by paragraph 185 of the National Planning Policy Framework.

Object

Local Plan Review: Preferred Approach 2016-2035

Representation ID: 2288

Received: 05/02/2019

Respondent: Penny Kirk

Representation Summary:

S28. "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.

Full text:

"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.

Object

Local Plan Review: Preferred Approach 2016-2035

Representation ID: 2293

Received: 07/02/2019

Respondent: Mr Gordon Read

Agent: Kate Simms

Representation Summary:

Object to Apuldram and Donnington allocation on following grounds:
- DEFRA have classified this area as one of the best food production soil.
- The area is subject to flooding on a regular basis.
- Will upset the natural ecosystem and wildlife including rare species of plants within and surrounding the Chichester AONB.
- Overpressurised road usage on and off the Witterings Pennisula, and, especially at the A27 Fishbourne roundabout.
- Inadequate public transport
- Unsafe to walk to and from Chichester especially with lack of walkways under or over the A27

Full text:

Having read Policy AL6 - Land South West of Chichester (Apuldram & Donnington
Parishes), I object to this planning proposal on the following grounds:

1. The area is classified by DEFRA as GRADE ONE Agricultural Brick Earth. In other words DEFRA have classified this area as one of the best food production soil.

2. The area is subject to flooding on a regular basis.

3. The plan will upset the natural ecosystem and wildlife including rare species of plants within and surrounding the Chichester AONB.

4. The plan WILL only exacerbate the already overpressurised road usage on and off the Witterings Pennisula, and, especially at the A27 Fishbourne roundabout. Chichester already has a serious transport issue within and on the A27 which will only get worse.

5. There is inadequate public transport currently even though there is a need for it.

6. It is unsafe to walk to and from Chichester especially with lack of walkways under or over the A27.

Comment

Local Plan Review: Preferred Approach 2016-2035

Representation ID: 2306

Received: 07/02/2019

Respondent: Portsmouth Water Ltd

Representation Summary:

Policy AL6 'South West Chichester' is crossed by a large diameter main that will have to be reflected in the road layout or diverted. The proposed link road may offer an alternative route for the main.

Full text:

Spatial Vision
Portsmouth Water note that there are significant additional housing allocations to the west of Chichester and on the coastal strip. These sites will need to be assessed for water supply and funding included in the Infrastructure Charging scheme. (See Map 4.1 Key Diagram)

It is not clear what water storage capacity is being referred to in Section 3.19. Portsmouth Water will review the provision of Service Reservoirs, for day to day use, and has re-started development of a large raw water storage reservoir at Havant Thicket. The reservoir, when combined with Portsmouth Water's existing sources and enhancements to its groundwater sources, would create sufficient
surplus to support an additional flexible daily transfer of treated water from Portsmouth Water are to Southern Water without detriment to Portsmouth Water's resilience.

Southern Water requires this transfer to help meet a significant deficit in its Southampton East, Southampton West and Isle of Wight resource zones. This deficit arose after Southern Water agreed to reduce its abstraction licences on the Rivers Test and River Itchen at a public inquiry in March 2018, to help protect the environment.

It is not clear that the water demands of the Horticultural Development Areas have been assessed. It is possible that these businesses will rely on rainwater harvesting and storage but changes in licencing regulations mean that 'Trickle Irrigation' is no longer exempt from abstraction licencing.

Groundwater abstraction in the coastal plain will require an impact assessment under the Habitats Regulations. (Section 4.75)

Spatial Strategy

Policy S12 sets out how development can make effective use of existing infrastructure. Portsmouth Water agree that the siting and timing of development can assist with the economic provision of water resource infrastructure. It also states that safeguarding existing infrastructure, such as water mains and aquifers, is important. Portsmouth Water would urge developers to check for existing infrastructure and for source protection zones that may limit development options.
Water infrastructure is not funded through CIL but a separate 'Infrastructure Charge' payable for each individual house. This is designed to pay for all off-site water infrastructure such as mains reinforcements, service reservoirs and supply. Development to an agreed program will help this system work effectively.

Strategic Policies

Policy S27 'Flood Risk Management' refers to Sustainable Drainage Systems (SuDS) and the need to control surface water run-off. It should also refer to aquifer protection and the need for caution when using infiltration systems especially deep bore systems. This applies particularly when the site is in, or close to, a source protection zone.

Policy S31 'Wastewater Management and Water Quality' refers to higher standards in the Building Regulations for water consumption to reduce pollution in the harbours. Portsmouth Waters 'Water Resources Management Plan' is based on lower per capita consumption and we have an aspiration for all customer to reach 100 litres/head/day by 2050. This is no substitute for reducing overall flows
to sewage treatment works by the control of groundwater infiltration and surface water drainage.

Strategic Site Allocations

Policy AL1 'West of Chichester' does not mention water supply so we assume that the site has reverted to a conventional system with sewerage pumped to Tangmere WWTW and water supplied by us. Portsmouth Water has provided provisional designs for this system and there are no existing large diameter water mains on the site. Costs for reinforcement of the water mains will be recovered by the new Infrastructure Charge and on site mains are likely to be provided by a third
party. Information on how reinforcement of the water mains is recovered by the Infrastructure Charge can be found in Portsmouth Water's Developer Charging Arrangements on our website under https://www.portsmouthwater.co.uk/developers/.

Policy AL2 'Shopwyke' is already under construction and has a conventional water supply system with all elements provided by us. Costs are being recovered via the Infrastructure Charge and on-site charges.

Policy AL3 'East of Chichester' is a new strategic site and there are no large diameter mains crossing it. This is an old landfill and may contain material that can damage plastic pipes. On site mains may need to be protected or be more expensive to ensure water quality is maintained.

Policy AL4 'Westhampnett' Phase 1 is already under construction and account has been taken of the large diameter main that crosses the site. Phase 2 is an extension of the existing Greylingwell site but it is not clear if this has been allowed for in the design of this 'Inset Appointment'. Portsmouth Water do not own the mains and there may be a single point of supply.

Policy AL5 'Southern Gateway' is an inner city development with a good water supply system. The reference to the 'efficient use of water' is confusing because many of the other strategic development sites also drain to Apuldram WWTW. All sites need to be water efficient but not follow the example of the 'Code for Sustainable Homes'. Sites were developed in Chichester that used rainwater harvesting to meet the Code objectives but were able to use higher water use fittings such as power showers. This led to properties producing more sewage than equivalent water efficient homes. This did not achieve the objective at Apuldram. An alternative provision might be to reduce infiltration but it is not clear how this would be funded or who would carry out the work.

Policy AL6 'South West Chichester' is crossed by a large diameter main that will have to be reflected in the road layout or diverted. The proposed link road may offer an alternative route for the main.

Policy AL7 'Bosham' is situated on the old A27 and there are no large diameter mains in the area.

Policy AL8 'East Wittering' is at the extremity of the distribution system and may be expensive to supply.

Policy AL9 'Fishbourne' allocation is not site specific and it is difficult to comment on the feasibility of water supply. Any off site costs will be recovered via the new Infrastructure Charge. Portsmouth Water have public water supply abstractions in the area and development is likely to be located in a source protection zone for our Fishbourne public water supply abstraction. Under this policy, where development is in a source protection zone, the policy should also refer to groundwater quality
protection and the additional requirements when using infiltration systems in particular deep bore systems. Further guidance on Portsmouth Water's preferred approach to development relating to groundwater quality within our catchments can be found within 'Portsmouth Water's Groundwater Protection Guidance notes' which are attached to this response and also available to view on our website under https://www.portsmouthwater.co.uk/developers/groundwater-protection/.

Policy AL10 'Chidham and Hambrook' is a large site and may need to be considered in combination with 'Southbourne' and 'Bosham'. There are no large diameter mains in the area and mains reinforcements may be required.

Policy AL11 'Hunston' allocation is not site specific.

Policy A12 'Selsey' is at the extremity of the distribution system and has seen previous housing growth. Reinforcement of the water mains may need to be provided.

Policy AL13 'Southbourne' is supplied from a different distribution system to Chichester. This is a very large housing allocation and this may need to be considered in combination with 'Hambrook' and 'Bosham'. There are sufficient water resources for all the housing allocated to Portsmouth Water's area of supply. It is the location of the housing site in relation to existing trunk mains and
service reservoirs that determines the cost to supply. Local reinforcement of the water mains may be required.

Policy AL14 'Tangmere' housing allocation has increased by 30% and we may need to repeat the modelling that has already been done. There is also uncertainty about the water supply to the HDA which seems to rely on rainwater harvesting for future growth. The housing development and the HDA could have an impact on our source protection zone. Under this policy, where development is in a source protection zone, the policy should also refer to groundwater quality protection and the
additional requirements when using infiltration systems in particular deep bore systems. Guidance should be sought from Portsmouth Water's Groundwater Protection Guidance for development.

Policy AL15 'Land at Chichester Business Park, Tangmere' Portsmouth Water have public water supply abstractions in the area and the site allocation is likely to be within a source protection zone for our Aldingbourne public water supply abstraction. As above, where development is in a source protection zone, the policy should also refer to groundwater quality protection and the need for caution when using infiltration systems in particular deep bore systems. Please refer to Portsmouth Water's Groundwater Protection Guidance for further information.

Development Management

Policy DM10: 'New Employment Sites' Development proposal should be compatible with other policies in the Plan, in particular DM9 'Existing Employment Sites' to ensure that the development is otherwise acceptable. Policy DM9 states that development should 'not generate unacceptable levels of water pollution' and this should include groundwater pollution. This requirement should also be applied to Policy DM10, especially when the site is in, or close to, a source protection zone.

Policy DM15 'Horticultural Development' Developments at Tangmere HDA have relied on infiltration to dispose of excess surface water. This policy states that development should 'not generate unacceptable levels of water pollution' and this should include groundwater pollution. Portsmouth Water have public water supply abstractions in the area and the potential impacts must be assessed for any SUDS. The EA 'Abstraction Licencing Strategy' (ALS) may give an indication about the
availability of groundwater but it does not cover the derogation of existing supplies.

Policy DM16 'Sustainable Design and Construction' covers the use of Building Regulations to control water use. Portsmouth Water have an aspiration to reduce overall water use to 100 litres/head/day and this policy will help to achieve that aim.

Policy DM18 'Water Management' using SUDS needs to take account groundwater quality and should avoid direct infiltration into the chalk aquifer. This is especially important within the source protection zones.

Policy DM29 'Biodiversity' Portsmouth Water has legal duties to protect and where practical enhance biodiversity and has an active program of work on it's own land. This work is now expanding to include projects on other people's land in association with 'Catchment Management' activities. We would look to CDC for support in areas such as Bosham Stream, Lavant Stream and Fishbourne Stream where schemes could be developed in partnership with local housing developments.

Policy DM35 'Equestrian Development' can have a direct impact on water quality including groundwater quality. Portsmouth Water support the protection of water courses and aquifers.

Appendix 'E' Monitoring Framework

Policy S12 covers the provision of infrastructure but it is not clear how records of completed projects will be collected or stored.

Policy S26 covers biodiversity improvements and Natural England should be consulted on priorities and record keeping.

Policy S31 covers water consumption which is only available for the whole Company area in the WRMP Annual Review.

Object

Local Plan Review: Preferred Approach 2016-2035

Representation ID: 2321

Received: 17/01/2019

Respondent: Mr Robert Marson

Representation Summary:

Object to AL6 due to conflict with Policy S27 Flood Risk Management.

The proposed plan to build a link road in Apuldram/Stockbridge to service employment and residential use is contrary to the council statement related to risk of flooding especially as this area is on flood plain level 3.
Housing and Employment would be better placed around Lavant and West Broyle land outside of the SDNP as (a) CDC are absorbing housing from the SDNP (b) siting affordable housing in this area, close to where it is needed, would be more sensible and would be in line with strategic objectives.

Full text:

The proposed plan to build a link road in Apuldram/Stockbridge to service employment and residential use is contrary to the council statement related to risk of flooding especially as this area is on flood plain level 3.
Housing and Employment would be better placed around Lavant and West Broyle land outside of the SDNP especiaaly as (a) CDC are absorbing housing from the SDNP (b) siting affordable housing in this area, close to where it is needed, would be more sensible and would be in line with strategic objectives.

Object

Local Plan Review: Preferred Approach 2016-2035

Representation ID: 2331

Received: 02/02/2019

Respondent: Mr Timothy Firmston

Representation Summary:

S24. The proposed new link road from the Fishbourne roundabout tA27 to the A286 Birdham Road will have a very detrimental effect on the countryside of Apuldram, the surrounding river meadows, the medium distant view to Chichester and the long distant view to the South Downs. The planned road would have to be elevated to cross the area to mitigate the flood risk making it even more visible with traffic.

Full text:

The proposed new link road from the Fishbourne roundabout tA27 to the A286 Birdham Road will have a very detrimental effect on the countryside of Apuldram, the surrounding river meadows, the medium distant view to Chichester and the long distant view to the South Downs. The planned road would have to be elevated to cross the area to mitigate the flood risk making it even more visible with traffic.

Object

Local Plan Review: Preferred Approach 2016-2035

Representation ID: 2334

Received: 07/02/2019

Respondent: Southern Water

Representation Summary:

Local sewerage infrastructure in closest proximity to the site has limited capacity to accommodate the proposed development.

Proposals for 100 dwellings at this site will generate a need for reinforcement of the wastewater network. Southern Water will need to work with site promoters.

Connection of new development at this site ahead of new infrastructure delivery could lead to an increased risk of flooding.

Concerned over proximity to WWTW - essential operations may impact upon on the amenity of the site's future occupants - ensure layout is informed by odour assessment.

Require easement of 6m+ on site around existing infrastructure.

Full text:

Policy S31
Southern Water is the statutory wastewater undertaker within Chichester District, also supplying water to the northern area of the district, within the South Downs National Park, as well as the north eastern corner of the District outside the National Park.
Through Chichester District Council's (CDC) Water Quality Group, Southern Water has been working with CDC and other stakeholders to help identify and address river and estuarine water quality issues within the District. Southern Water has in recent years invested in solutions that have either been implemented, or are in progress. In tandem with this, an important contribution through the Local Plan will be to ensure that new development does not cause detriment to the existing situation.
By adopting higher water efficiency measures and ensuring that surface water from new development is prevented from discharging to the foul network, Southern Water believes these measures will be effective in helping to mitigate the impact of new development. This approach is supported, in conjunction with a requirement to phase development to align with the delivery of new or improved infrastructure as set out in Policy S12(5). The combination of these measures, together with those submitted for inclusion within individual site allocations which seek to prevent occupation of new development ahead of necessary sewer improvements, will contribute to reducing the risk of sewer flooding that may otherwise have
been exacerbated.

Policy AL1
Southern Water is the statutory wastewater undertaker for Chichester. Taking into account preceding work that has already taken place and existing consent at this site, Southern Water will connect development at Land West of Chichester to Tangmere Wastewater Treatment Works. The necessary infrastructure is scheduled for delivery by the end of 2020.
The existing provision within Policy AL1 relating to wastewater conveyance and treatment is noted, and was supported by Southern Water during historic consultations on the current Chichester Local Plan Key Policies 2014-2029. However, since OFWAT's new approach to water and wastewater connections charging was implemented from 1 April 2018, we have adjusted our approach accordingly. Southern Water will need to work with site promoters to understand the development program and to review whether the delivery of new infrastructure aligns with the occupation of the development, and this is reflected in the proposed amendments below.

Having regard to the above, Southern Water proposes the following amendment to Policy AL1:
Occupation of development is phased to align with the delivery of infrastructure for adequate wastewater conveyance and treatment to meet strict environmenta standards.

Policy AL2
Southern Water is the statutory wastewater undertaker for Oving Parish. Taking into
account preceding work that has already taken place at this site, Southern Water will
connect development at Land at Shopwyke to Tangmere Wastewater Treatment Works.
The necessary infrastructure is scheduled for delivery by the end of 2020.
The existing provision within Policy AL2 relating to wastewater conveyance and treatment is noted, and was supported by Southern Water during historic consultations on the current Chichester Local Plan Key Policies 2014-2029. However, since OFWAT's new approach to water and wastewater connections charging was implemented from 1 April 2018, we have adjusted our approach accordingly. Southern Water will need to work with site promoters to understand the development program and to review whether the delivery of new infrastructure aligns with the occupation of the development, and this is reflected in the
proposed amendments below.

Having regard to the above, Southern Water proposes the following amendment to Policy AL2:
Occupation of development is phased to align with the delivery of infrastructure for adequate wastewater conveyance and treatment to meet strict environmental standards.

Policy AL3
Southern Water is the statutory wastewater undertaker for Oving Parish. Taking into
account preceding work that has already taken place at the adjacent Shopwyke site,
Southern Water will connect development at Land East of Chichester to Tangmere
Wastewater Treatment Works. The necessary infrastructure is scheduled for delivery by the end of 2020.
We note the existing provision within Policy AL3 relating to the need to demonstrate capacity within the sewer network and wastewater treatment works. Southern Water supports this provision, however since OFWAT's new approach to water and wastewater connections charging was implemented from 1 April 2018, we also will need to work with site promoters to understand the development program and to review whether the delivery of new infrastructure aligns with the occupation of the development. This is reflected in the proposed additional policy provision below.

Having regard to the above, Southern Water proposes the following additional criterion to Policy AL3:
Occupation of development will be phased to align with the delivery of sewerage infrastructure, in consultation with the service provider.

Policy AL4
Southern Water is the statutory wastewater undertaker for Westhampnett and North East Chichester. Taking into account preceding work that has already taken place at this site, Southern Water will connect development at this site to Tangmere Wastewater Treatment Works. The necessary infrastructure is scheduled for delivery by the end of 2020.
The existing provision within Policy AL4 relating to wastewater conveyance and treatment is noted, and was supported by Southern Water during historic consultations on the current Chichester Local Plan Key Policies 2014-2029. However, since OFWAT's new approach to water and wastewater connections charging was implemented from 1 April 2018, we have adjusted our approach accordingly. Southern Water will need to work with site promoters to understand the development program and to review whether the delivery of new infrastructure aligns with the occupation of the development, and this is reflected in the
proposed amendments below.

Having regard to the above, Southern Water proposes the following amendment to Policy AL4:
Occupation of development will be phased to align with the delivery of infrastructure for adequate wastewater conveyance and treatment to meet strict environmental standards.

Policy AL6
Southern Water is the statutory wastewater undertaker for Apuldram and Donnington
Parishes. In accordance with this, we have undertaken an assessment of the existing
capacity of our infrastructure and its ability to meet the forecast demand for this proposal.

The assessment reveals that local sewerage infrastructure in closest proximity to the site has limited capacity to accommodate the proposed development. Limited capacity is not a constraint to development provided that planning policy and subsequent conditions ensure that occupation of the development is phased to align with the delivery of wastewater infrastructure.

Proposals for 100 dwellings at this site will generate a need for reinforcement of the
wastewater network in order to provide additional capacity to serve the development. Since OFWAT's new approach to water and wastewater connections charging was implemented from 1 April 2018, this reinforcement will be provided through the New Infrastructure charge, but Southern Water will need to work with site promoters to understand the development program and to review whether the delivery of network reinforcement aligns with the occupation of the development. Connection of new development at this site ahead of new infrastructure delivery could lead to an increased risk of flooding unless the requisite works are implemented in advance of occupation.

Southern Water has limited powers to prevent connections to the sewerage network, even when capacity is limited. Planning policies and planning conditions, therefore, play an important role in ensuring that development is coordinated with the provision of necessary infrastructure, and does not contribute to pollution of the environment, in line with paragraph
170(e) of the revised National Planning Policy Framework (NPPF) (2018).

Proximity to Wastewater Treatment Works

In addition, we note that part of the site is opposite Apuldram Wastewater Treatment Works (WTW), and our concern is that the proximity of any 'sensitive' development to the WTW, such as housing, would have an unacceptable impact on the amenity of the site's future occupants arising from the WTW's essential operational activities.

Such impacts may include odour from wastewater processing and noise and vibration from operational vehicles and equipment. Paragraph 6.3.5 of the West Sussex Waste Local Plan 2014 (p42) states that 'existing waste sites and infrastructure will be protected from inappropriate neighbouring developments that may prejudice their continuing efficient operation' and that 'sensitive' uses need to consider a buffer that will depend on 'the nature of the proposed 'sensitive' use and on the specific impacts of the current waste operation'.

Having regard to the above, it is important that the layout of any development scheme should be informed by an odour assessment, to ensure there is adequate separation between sensitive new development and the WTW. This approach is further supported by The Institute of Air Quality Management (IAQM) 'Guidance on the assessment of odour for planning', paragraph 2.1 which states that 'the planning system has the task of guiding development to the most appropriate locations: ideally, significant sources of odour should be separated from odour-sensitive users of the surrounding land (sensitive receptors) [...].
New proposals for such developments may require an odour impact assessment to be
submitted'.

Existing infrastructure

We have also made an initial assessment of this site and ascertained that Southern Water's sewerage infrastructure crosses the site, which needs to be taken into account when designing the layout of any proposed development. An easement width of 6 metres or more, depending on pipe size and depth, would be required, which may affect site layout or require diversion. This easement should be clear of all proposed buildings and substantial tree planting.

Having regard to the above, Southern Water proposes the following additions to Policy AL6:
Occupation of development will be phased to align with the delivery of sewerage infrastructure, in consultation with the service provider.

The development layout must provide sufficient distance between Apuldram Wastewater Treatment Works and sensitive land uses, such as residential units, to allow adequate odour dispersion, on the basis of an odour assessment to be undertaken in consultation with Southern Water.

Layout of the development must be planned to ensure future access to existing sewerage infrastructure for maintenance and upsizing purposes.

Policy AL7

Southern Water is the statutory wastewater undertaker for Bosham Parish. In accordance with this, we have undertaken an assessment of the existing capacity of our infrastructure and its ability to meet the forecast demand for this proposal. The assessment reveals that local sewerage infrastructure in closest proximity to the site has limited capacity to accommodate the proposed development. Limited capacity is not a constraint to development provided that planning policy and subsequent conditions ensure that occupation of the development is phased to align with the delivery of wastewater infrastructure.

Proposals for 250 dwellings at this site will generate a need for reinforcement of the
wastewater network in order to provide additional capacity to serve the development. Since OFWAT's new approach to water and wastewater connections charging was implemented from 1 April 2018, this reinforcement will be provided through the New Infrastructure charge, but Southern Water will need to work with site promoters to understand the development program and to review whether the delivery of network reinforcement aligns with the occupation of the development. Connection of new development at this site ahead of new infrastructure delivery could lead to an increased risk of flooding unless the requisite works are implemented in advance of occupation.

Southern Water has limited powers to prevent connections to the sewerage network, even when capacity is limited. Planning policies and planning conditions, therefore, play an important role in ensuring that development is coordinated with the provision of necessary infrastructure, and does not contribute to pollution of the environment, in line with paragraph 170(e) of the revised National Planning Policy Framework (NPPF) (2018).

Having regard to the above, Southern Water proposes the following addition to Policy AL7
(new text underlined):

Occupation of development will be phased to align with the delivery of sewerage infrastructure, in consultation with the service provider.

Policy AL9

Southern Water is the statutory wastewater undertaker for Fishbourne Parish. We note that the spatial distribution of the allocated 250 dwellings will be determined through a revision of the Fishbourne Neighbourhood Plan. Until sites are determined Southern Water is unable to carry out an assessment of the impact of development on the local sewer network.
However, in order to minimise flood risk and other impacts on the environment, sewer capacity will need to be considered, as well as wastewater treatment capacity.

Having regard to the above, Southern Water proposes the following amendment to Policy AL9 (new text underlined):

Ensure sufficient capacity within the sewer network and relevant Wastewater Treatment Works before the delivery of development as required.

Policy AL12

Southern Water is the statutory wastewater undertaker for Selsey Parish. In accordance with this, we have undertaken an assessment of the existing capacity of our infrastructure and its ability to meet the forecast demand for this proposal. The assessment reveals that local sewerage infrastructure in closest proximity to the site has limited capacity to accommodate the proposed development. Limited capacity is not a constraint to development provided that planning policy and subsequent conditions ensure that occupation of the development is phased to align with the delivery of wastewater infrastructure.

Proposals for 250 dwellings at this site will generate a need for reinforcement of the
wastewater network in order to provide additional capacity to serve the development. Since OFWAT's new approach to water and wastewater connections charging was implemented from 1 April 2018, this reinforcement will be provided through the New Infrastructure charge, but Southern Water will need to work with site promoters to understand the development program and to review whether the delivery of network reinforcement aligns with the occupation of the development. Connection of new development at this site ahead of new infrastructure delivery could lead to an increased risk of flooding unless the requisite works are implemented in advance of occupation.

Southern Water has limited powers to prevent connections to the sewerage network, even when capacity is limited. Planning policies and planning conditions, therefore, play an important role in ensuring that development is coordinated with the provision of necessary infrastructure, and does not contribute to pollution of the environment, in line with paragraph 170(e) of the revised National Planning Policy Framework (NPPF) (2018).

Having regard to the above, Southern Water proposes the following addition to Policy AL12 (new text underlined):

Occupation of development will be phased to align with the delivery of sewerage infrastructure, in consultation with the service provider.

Policy AL13

Southern Water is the statutory wastewater undertaker for Southbourne Parish. We note that the spatial distribution of the allocated 1,250 dwellings will be determined through a revision of the Southbourne Neighbourhood Plan. Until sites are determined Southern Water is unable to carry out an assessment of the impact of development on the local sewer network, however, in order to minimise flood risk and other impacts on the environment, sewer capacity will need to be considered, as well as wastewater treatment capacity.

Having regard to the above, Southern Water proposes the following amendment to Policy AL13 (new text underlined):
Ensure sufficient capacity within the sewer network and relevant Wastewater Treatment Works before the delivery of development as required.

Policy AL14

Southern Water is the statutory wastewater undertaker for Tangmere. Taking into account preceding work that has already taken place at this site, Southern Water will connect development at this site to Tangmere Wastewater Treatment Works. The necessary infrastructure is scheduled for delivery by the end of 2020.

The existing provision within Policy AL14 relating to wastewater conveyance and treatment is noted, and was supported by Southern Water during historic consultations on the current Chichester Local Plan Key Policies 2014-2029. However, since OFWAT's new approach to water and wastewater connections charging was implemented from 1 April 2018, we have adjusted our approach accordingly. Southern Water will need to work with site promoters to understand the development program and to review whether the delivery of new infrastructure aligns with the occupation of the development, and this is reflected in the
proposed amendments below.

Having regard to the above, Southern Water proposes the following amendment to Policy AL14:

Occupation of development will be dependent on the provision phased to align with the delivery of infrastructure for adequate wastewater conveyance and treatment to meet strict environmental standards.

Support

Local Plan Review: Preferred Approach 2016-2035

Representation ID: 2360

Received: 05/02/2019

Respondent: West Sussex Local Access Forum (WSLAF)

Representation Summary:

Opportunities for the provision of green infrastructure links to the wider countryside within these Policies are welcomed. It is particularly relevant to the Coastal Plain where the current provision of multi-user routes is very limited. Improvements in this area would comply with the objectives of the West Sussex Rights of Way Management Pan 2018-2028.

Full text:

Para 3.2 bullet points 5, 9 & 10 - these objectives are supported
The Local Plan Strategic Objectives
Para 3.19 Health & Well-Being bullet point 1 - this objective is supported
Policy S18 Integrated Coastal Zone Management for the Manhood Peninsula : Objective 5 - while the objective is supported it should apply to all Non-Motorised User (NMU) activity. This could best be achieved by ensuring at least one multi-user route is provided around and through developments linked to the existing Public Right of Way (PRoW) and wider access networks.
Design : Policy 20 bullet point 5 - the objective is supported but should recognise that this includes multi-use PRoW for the use and benefit of all.
Planning for Health and Well-being Para 5.9 - this objective is supported but should encourage all NMU activity not limited to walking and cycling.
Transport Infrastructure
Para 5.15 - the inclusion of bridleways is welcomed but there should be specific inclusion of PRoW
Para 5.16 - the wording is misleading as the provision of bridleways on the Coastal Plain is very limited, restricting access for cyclists and equestrians. Upgrading suitable PRoW to bridleways would improve access for all NMUs and contribute to the West Sussex Transport Plan (2011-2016) to improve safety for all road users.
Policy S23 : Transport and Accessibility bullet point 8 - inclusion of PRoW is welcomed
Policy S32: Design Strategies for Strategic and Major Development Sites
Bullet points b, e & g - the aims of these are welcomed but any new routes are linked from new developments to the wider PRoW and access networks
Policy AL1 : Land West of Chichester
Para 4 - this development provides an opportunity to improve access links to the wider access network
Para 10 - there is an opportunity here to provide a multi-user PRoW for all NMUs
Policy AL2: Land at Shopwyke (Oving Parish)
Para 9 - any bridge should be for all NMUs, including equestrians, to reinstate the route severed when the A27 was re-aligned.
Policies AL3 - AL14 - opportunities for the provision of green infrastructure links to the wider countryside within these Policies are welcomed. It is particularly relevant to the Coastal Plain where the current provision of multi-user routes is very limited. Improvements in this area would comply with the objectives of the West Sussex Rights of Way Management Pan 2018-2028.

DM15 Horticultural Development - there is an opportunity within the Runcton area to enhance and upgrade routes for NMUs should the land be used for housing at a later date.
Policy DM23 Green Infrastructure
Para 7.185 - the examples should specifically include PRoW.
Bullet point 4 - more positive wording to recognise the improvement proposals could make to the access networks is preferred.
Policy DM34 Open Space, Sport and Recreation.... - the aim to retain, enhance, enhance access and increase the quantity and quality of PROW and the links to them is supported. This would be of great benefit to all NMUs is all new routes/links are multi-user.

Object

Local Plan Review: Preferred Approach 2016-2035

Representation ID: 2374

Received: 04/02/2019

Respondent: Birdham Parish Council

Representation Summary:

AL6 is situated immediately adjacent to the Chichester Harbour AONB.
This site should be moved to the east of the city, where there are already substantial commercial developments.
This disregard for the Chichester Harbour AONB is further evidenced by the proposal to build a link road between the Fishbourne Roundabout and the A286. This road will be within 300 metres of the AONB and will be elevated because of the low lying ground which it crosses.

Full text:

Strategic site AL6 is situated immediately adjacent to the Chichester Harbour AONB. This cannot possibly meet the requirements of Policy DM19. The commercial part of this site is located between the Fishbourne and Stockbridge roundabouts, two of the most congested and polluted roundabouts on an already congested road, which contravenes Policy DM8: Transport, Accessibility and Parking. The location of this site should be moved to the east of the city, where there are already substantial commercial developments. Another possible location is around the Goodwood Race Track, which would act as a noise barrier to protect local housing in the area.
This disregard for the Chichester Harbour AONB is further evidenced by the proposal to build a link road between the Fishbourne Roundabout and the A286. This road will be within 300 metres of the AONB and will be elevated because of the low lying ground which it crosses. This will ruin the view of the Cathedral from the harbour and generate large amounts of noise and pollution, thus disturbing the harbour, and further cut off the harbour from the city.

Object

Local Plan Review: Preferred Approach 2016-2035

Representation ID: 2375

Received: 04/02/2019

Respondent: Mrs Clare Gordon-Pullar

Representation Summary:

DM18. 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.

Full text:

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.

Object

Local Plan Review: Preferred Approach 2016-2035

Representation ID: 2376

Received: 04/02/2019

Respondent: Mrs Clare Gordon-Pullar

Representation Summary:

DM3. Landscape buffers are used a justification for not putting forward suitable development sites to the north and east of Chichester. Why is there no suggestion of landscape buffers to the sites to the south and southwest? The untested AL6 is not given the same protection so there would be no buffer between Chichester and the AONB. It would be further damaged by a raised road.

Full text:

Landscape buffers are used a justification for not putting forward suitable development sites to the north and east of Chichester. Why is there no suggestion of landscape buffers to the sites to the south and southwest? The untested AL6 is not given the same protection so there would be no buffer between Chichester and the AONB. It would be further damaged by a raised road.

Object

Local Plan Review: Preferred Approach 2016-2035

Representation ID: 2377

Received: 04/02/2019

Respondent: Mrs Clare Gordon-Pullar

Representation Summary:

S27. Proposed development in SW Chichester should be avoided as it is in a flood plain.

Full text:

Proposed development in SW Chichester should be avoided as it is in a flood plain.

Comment

Local Plan Review: Preferred Approach 2016-2035

Representation ID: 2416

Received: 07/02/2019

Respondent: South Downs National Park Authority

Representation Summary:

Policy AL6 (Land South-West of Chichester (Apuldram and Donnington Parishes)) should address the important opportunity to secure a safe off-road connection between the Centurion Way and Salterns Way as the two flagship and largely safe off-road multi-user trails linking Chichester with (respectively) SDNP and Chichester Harbour AONB. We would welcome the opportunity for further dialogue and joint working on this matter with CDC.

Full text:

The SDNPA and all relevant authorities are required to have regard to the purposes of the South Downs National Park (SDNP) as set out in Section 62 of the Evironment Act 1995. The purposes are 'to conserve and enhance the natural beauty, wildlife and cultural heritage of the area' and 'to promote opportunities for the understanding and enjoyment of the special qualities of the national park by the public.' The Authority would appreciate reference to Section 62 being added to
paragraph 1.31 of the draft Plan.

Duty to Cooperate

As set out in our previous response, the SDNPA has a set of six strategic cross-boundary priorities.
I would like to take the opportunity to again highlight these which provide a framework for ongoing Duty to Cooperate discussions:
* Conserving and enhancing the natural beauty of the area.
* Conserving and enhancing the region's biodiversity (including green infrastructure issues).
* The delivery of new homes, including affordable homes and pitches for Gypsies, Travellers and Travelling Showpeople.
* The promotion of sustainable tourism.
* Development of the local economy.
* Improving the efficiency of transport networks by enhancing the proportion of travel by sustainable modes and promoting policies which reduce the need to travel.

Conserving and enhancing the natural beauty

We welcome the requirement in policies S26 (Natural Environment) and DM28 (Natural Environment) to ensure that development proposals have no adverse impact on the openness of views and setting of the SDNP. It is noted that a substantial amount of new homes are proposed on the A259 corridor between Emsworth and Chichester. This is a sensitive stretch of land in the coastal
plain between the coast, the south coast railway and the A27. This corridor provides the connection, including intervisibility, between the protected landscapes of the South Downs National Park and Chichester Harbour AONB, for example views of the channels within the Harbour from the Trundle and Stoke Clump.
We note the intention of identifying settlement gaps and look forward to seeing the evidence base and the proposed gaps in the Regulation 19 iteration of Chichester Local Plan Review 2035, particularly as to how they will contribute to safeguarding the relationship between the SDNP and Chichester Harbour AONB. We would welcome the opportunity to work with CDC on this matter.

Locations identified for development

Development in the CDC Local Plan Review 2035, particularly along the A259 (policies AL7 Highgrove Farm Bosham, AL9 Fishbourne Parish, AL10 Chidham and Hambrook Parish, AL13 Southbourne Parish) corridor, have the potential to deliver a significant cumulative adverse impact on the setting of the National Park and its important relationship with the Chichester Harbour AONB.
We consider that the policy wording for the A259 corridor Strategic Site Allocations could be more robust and proactive with regard to conserving and enhancing the National Park. In particular, it could provide more active direction to applicants in order to ensure adverse impacts are minimised locally, and in relation to the National Park. For example, with regard to green infrastructure, each of the
A259 Strategic Site Allocation policies (AL7, AL9, AL10 and AL13) include a criteria requiring the provision of green infrastructure, and we would suggest this could be re-worded as follows: 'Identify opportunities are taken for and secure the expansion and provision of multifunctional green infrastructure into the wider countryside and protected landscapes of the South Downs National Park, and Chichester Harbour AONB, including between settlements and facilities.'

Reference to considering and minimising impact on the SDNP in each of the A259 Strategic Site Allocation policies (AL7, AL9, AL10 and AL13) is welcomed, for example criterion 5 of policy AL9:
Fishbourne Parish. However, this could be usefully re-worded to ensure that developers do not create a scheme and only consider the impact afterwards. Wording to direct people to 'respect and respond to the National Park landscape, its setting and purposes prior to development design' avoids the risk of relying upon ill-informed and inappropriate mitigation measures This matter could also be usefully
addressed in relevant Strategic and Development Management policies elsewhere in the Local Plan concerning design, landscape, and the South Downs National Park. We would be happy to work with CDC on this matter.

We note Strategic Policy S32, which requires proposals for housing allocations and major development sites to be accompanied by a site-wide design strategy. We would strongly encourage masterplans and development briefs for each allocation (or settlement where the sites are to be allocated through a Neighbourhood Plan) to come ahead of applications and demonstrate positive design interventions which respond directly to landscape/SDNP sensitivities. We would be happy to be involved in shaping these as consultees in order to achieve the best quality scheme. These interventions could be written in to the policy wording.

There is an opportunity for allocation policies to seek to deliver the joining up of existing, and/or improvements to, the network of RoW (Equestrians, Cyclists and Pedestrians) to enable and encourage access into the National Park in accordance with the National Park's Second Purpose.
Further comments on specific allocations:
* Policy AL1 (Land West of Chichester) - We welcome the consideration of the Centurion Way in criteria 10. However, we would ask for stronger policy wording to explicitly state that development must not adversely affect, and preferably enhance usability of, Centurion Way connecting Chichester with the SDNP.
* We note that Policy AL4 (Land at Westhampnett/NE Chichester) still refers to Lavant Valley greenspace but we query if this is likely to be secured now based on planning applications submitted. We would suggest that criteria 12, last sentence, could also refer to securing offsite improvements/upgrades for cycleway links
* Policy AL6 (Land South-West of Chichester (Apuldram and Donnington Parishes)) should address the important opportunity to secure a safe off-road connection between the Centurion Way and Salterns Way as the two flagship and largely safe off-road multi-user trails linking Chichester with (respectively) SDNP and Chichester Harbour AONB. We would welcome the opportunity for further dialogue and joint working on this matter with CDC.
* We welcome criterion 5 of policy AL14 (Land West of Tangmere). It is a sensitive site due to the impact on clear views of the site from important locations in the SDNP such as the Trundle and Halnaker Hill. We therefore ask that criterion 5 is expanded to emphasise and address the sensitivity of the site
Specific wording comments on other policies/paragraphs:

We have the following comments on the following specific paragraphs:
* Para 2.29 (challenges and opportunities facing the Plan Area): We suggest that the 7th bullet point should say 'Protect and enhance the character of the area including the Chichester Harbour AONB and the setting of the SDNP'.
* Policy S20 (Design): As mentioned above regarding the A259 Strategic Site Allocation policies, we consider that the wording of this policy could be more proactive by including wording to direct people to 'respect and respond to the National Park landscape, its setting and purposes prior to development design'.
* Policy S25 (The Coast): Paragraph 5.44: We suggest adding 'serves to provide important scenic views from the water across to the SDNP which should be conserved'.
* Policy S26 (Natural Environment): We suggest deleting reference to 'openness' and to include reference to views from and to the National Park.
* Policy S32 (Design Strategies for Strategic and Major Development Sites): We suggest that the policy requires such design strategies to be informed by landscape character and the sites landscape context. We also suggest that criteria h. includes a requirement to state maximum building heights.
* Policy DM17 (Stand-alone Renewable Energy): The policy requirement for demonstrating no significant adverse impact upon landscape or townscape character is welcomed. We request reference is also made specifically of views of the SDNP.
* Policy DM19 (Chichester Harbour AONB): We request criterion three also identifies the relationship by way of intervisibility between the AONB and SDNP.
* Policy DM22 (Development in the Countryside): Further to comments on the A259 Strategic Site Allocation policies and S20 (Design), we consider that the wording of this policy could be more proactive by including wording to direct people to 'respect and respond to the National Park landscape, its setting and purposes prior to development design'.
* Policy DM23 (Lighting): The reference to the South Downs International Dark Skies Reserve is welcomed. However, proposals that aren't immediately adjacent to the Reserve may have significant adverse impact, for example due to the site's particular visibility within the landscape or sky glow; we suggest that wording is amended to reflect this.
* Policy DM32 (Green Infrastructure): We suggest that this policy could benefit from specifically citing that green infrastructure should be 'multifunctional'. We also recommend reference to opportunities to make better green infrastructure connections in line with Lawton Principles of 'bigger, better, more joined up', to ensure these spaces can function and therefore deliver benefits.

Conserving and enhancing the region's biodiversity (including green infrastructure).

The SDNPA welcomes the approach taken by CDC to identify green infrastructure and habitats networks as cross boundary issues in paragraph 1.26 of the Plan. The SDNPA looks forward to continuing to work with CDC on green infrastructure matters particularly as your Plan is progressed to pre-submission.

We note that an open space study has been prepared and this could be linked up with other work into a wider green infrastructure approach incorporating the identified strategic wildlife corridors, areas for natural flood management, PROW and connections between the settlements, protected landscapes and the stations, landscape views/settlement gaps and some land management guidelines
for these really important areas. This would be particularly useful to inform development proposals in the A259 corridor.

Policy SD30 - Strategic wildlife corridors

The SDNPA very much welcomes and supports the inclusion into policy of wildlife corridors which traverse the district connecting the two protected landscapes of the Chichester Harbour AONB and the SDNPA.

It is important to note that there is no corresponding policy within South Downs Local Plan, currently at examination, to continue protection of the wildlife corridors within the SDNP. We have concerns that it is unlikely to be sufficient for the corridors just to reach the SDNP boundary. We also note that several of the corridors appear to be quite narrow, especially to the east of the City, and we query whether they are substantial enough to perform the intended function.

We note the detailed evidence outlined in the background paper and the SDNPA would like to work with CDC on the continued development of the strategic wildlife corridors, in particular with regard to their connection points with the National Park and how we can work together on robustly delivering this strategic cross boundary objective.

Ebernoe Common, The Mens, and Singleton & Cocking Special Areas of Conservation

The SDNPA has been working together on technical advice to facilitate sustainable development within proximity Ebernoe Common, The Mens, and Singleton & Cocking Special Areas of Conservation, which are designated for their populations of Bechstein and barbastelle bats. The draft Sussex Bat Special Area of Conservation Planning and Landscape Scale Enhancement Protocol was published in 2018 in the Core Document Library as part of the South Downs Local Plan Examination. The Protocol is based on published data which identifies key impact zones, one of 6.5km and one of 12km, around each of the three SACs. It also sets out avoidance, mitigation, compensation and enhancement measures to inform and be addressed by development proposals. Parts of the Chichester District Local Plan area are within these key impact zones. These zones have been incorporated into policy SD10 of the South Downs Local Plan and the policy has not been modified by the Inspector as a result of the examination in public. The SDNPA would welcome the opportunity for further discuss with CDC and Natural England on this work.
Solent Recreation Mitigation Partnership

Both CDC and the SDNPA are members of the Solent Recreation Mitigation Partnership (SRMP) (also known as Bird Aware Solent) which has provided a strategic mitigation solution to address potential harm to the protected habitat at Chichester Harbour and ensuring compliance with the Habitats Regulations. We note that the SRMP mitigation solution is reflected in Policy DM30 and we look forward to continuing to work with CDC and other members of the SRMP on this matter.
With regard to paragraph 7.185 we suggest reference to the Medmerry Realignment be a new bullet point: 'Medmerry realignment, which is intertidal habitat created in 2013 to compensate for historic losses across the Solent to SSSI and Natura 2000 sites'.
We also suggest the following wording amendment to paragraph 7.187: '...This is particularly relevant to Chichester and Langstone Harbour and Pagham Harbour and the impact of recreational pressure on the birds that use these Special Protection Areas. Any negative impacts that the development may have should will be weighed against the benefits of the proposal. This may include looking at whether the assets are surplus to requirements, if the proposal impacts on a small area or corridor or if a wider need exists for the development and there is no alternative location....'

The delivery of new homes, including affordable homes and pitches for Gypsies,
Travellers and Travelling Showpeople

Policy S4: Meeting Housing Needs
The SDNPA welcomes the uplift to the housing target to address unmet need arising in that part of the SDNP within Chichester District (estimated at 44 dpa at the time the last Statement of Common Ground was agreed in April 2018). The provision of 41 dpa broadly meets this need.
We note that the Objectively Assessed Need is calculated only for the area outside the SDNP using the 'capping' method set out in the Government's standard methodology (the currently adopted target of 435 dwellings per annum plus 40% = 609) - this is helpful as it makes a clear distinction between the assessed need for Chichester District Local Plan area and that for the SDNPA, notwithstanding
the Duty to Cooperate.

Policy S5: Parish Housing Requirements 2016-35
We support identification of parish specific housing requirements providing certainty to local communities. This is the same approach as we have taken in the South Downs Local Plan.

Affordable housing
We note that there is a need for 285 affordable homes per annum (source: HEDNA) which underlines the need for a strong policy which seeks to maximise affordable housing delivery. This high level of need is common to the wider sub-region and is an issue relevant to the wider housing market area.
The SDNPA supports CDC's approach of taking opportunities arising from new residential development to contribute to the supply of affordable housing, to meet local needs in terms of type and tenure (paragraph 4.35). In this respect, it is important that the whole plan viability testing currently being undertaken should fully reflect Planning Practice Guidance on viability, such that as high as possible a percentage of affordable housing is sought. We also support the positive approach to Community Land Trusts (CLTs) as a mechanism for delivering affordable housing (paragraph 4.45). Chichester District Council may also wish to note that SDNPA has, subject to main modifications consultation, received the go-ahead from its Local Plan Inspector for unmodified inclusion of Strategic Policy SD28: Affordable Housing in the South Downs Local Plan. This includes a lower threshold than that advised in Government policy, and also seeks on-site affordable housing from small sites below the 11 threshold stipulated in Government policy.

Policy S7: Meeting Gypsies, Travellers, Travelling Showpeoples' Needs
The SDNPA supports the principle of the policy and whilst noting the significant need arising. It is not clear whether the intention is to allocate sites to meet the need in a separate DPD. Paragraph 4.49
refers to 'the forthcoming DPD' and policy S7 to sites being allocated in a Site Allocation DPD 'where there is a shortfall in provision'. Has this work already been triggered by the scale of need? The policy and associated text could be clearer on this matter.
We would like to highlight that there is limited capacity within the National Park to allocate sites for Gypsies and Travellers through DtC, given significant landscape constraints. We suggest that the coastal authorities and SDNPA continue to work closely with regards addressing the need.

Improving the efficiency of transport networks by enhancing the proportion of travel by sustainable modes and promoting policies which reduce the need to travel
The SDNPA supports in principle Policy S23 (Transport and Accessibility). In particular, we support emphasis on encouragement of use of sustainable modes. We suggest explicit support in the text for improving links into the National Park, particularly by sustainable and active transport modes.
Allocation policies should also should seek to deliver the joining up of existing, and/or improvements to, the network of Public Rights of Way.

SDNPA notes reference in the policy to a coordinated package of improvements to the A27 Chichester Bypass, as well as to a new road from the Fishbourne roundabout. The SDNPA would urge that any such schemes be fully assessed, including streetlighting, for potential adverse impacts on landscape where there is a relationship with the National Park and its setting. Any such impact will
need to be mitigated, and opportunities taken to enhance green infrastructure networks and public rights of way networks. CDC may wish to consider whether the Policy S23 should include additional wording to reflect these principles.

Centurion Way
The SDNPA supports the reference to Centurion Way in paragraph 7.185 in relation to Green Infrastructure & resistance to dissection of green movement corridors. There are opportunities to improve these links, for example, suggest explicit reference to protecting and enhancing the Centurion Way. The reference to Salterns Way is also supported. Centurion Way and Salterns Way are two flagship off-road routes for the SDNP and AONB respectively and do not currently benefit
from safe off-road connection. The SDNPA would strongly support policy to secure this connection and would welcome opportunities to discuss this further and work jointly with CDC on this strategic issue.

With regard to Strategic Policy S14 (Chichester City Transport Strategy) we request that the SDNP is included in the penultimate bullet point as a destination for strategic cycle routes.

Transport evidence
We would highlight that the transport assessment carried out to inform the South Downs Local Plan.
This indicated a potential severe impact on the Petersfield Road / Bepton Road / Rumbolds Hill junction in Midhurst of additional development in the town, in the context of junctions already becoming overcapacity due to background traffic growth, for example, . arising from strategic development in neighbouring planning authorities.
A review of the CDC Transport Study of Strategic Development indicates significant traffic growth arising from Scenario 1 (the preferred strategy). It is not clear from the study how this will impact on the A286 towards Midhurst, which in turn could have a critical impact on junction capacity at Midhurst.
SDNPA may seek further assurance that such potential impacts have been looked at, and appropriate mitigation sought.
Other comments
Page 16 - Local Plan area map: Request clarification whether the Local Plan area includes the following two properties, as not clear from the Local Plan Area map: Stedlands Farm, and The Stable/Little Stedlands, Haslemere GU273DJ
We would like to wish you well in the progression of your Local Plan and would welcome further discussion and joint working on the strategic cross boundary matters raised.

Attachments:

Object

Local Plan Review: Preferred Approach 2016-2035

Representation ID: 2478

Received: 20/02/2019

Respondent: Fishbourne Parish Council

Representation Summary:

Object to proposals for AL6 on grounds of:
- link road
- views/landscape impact
- impact on environment

Full text:

See attachment

Object

Local Plan Review: Preferred Approach 2016-2035

Representation ID: 2556

Received: 07/02/2019

Respondent: Chichester Harbour Trust

Representation Summary:

Object:
impact on buffer between AONB and Fishbourne Channel
impact on landscape views
impact of proposed link road - pollution and visual, landscape character, pollution

Do not believe Southern Water have demonstrated sufficient capacity at Apuldram WWTW to accommodate devt.

Full text:

We object to the allocation site at Highgrove Farm, Bosham with approximately 13 ha of open countryside allocated to a minimum of 250 houses.

This development in the countryside directly conflicts with policy S24 Countryside and Policy S26 the Natural Environment; which clearly states there should be no adverse impact on the openness of views in and around the coast, designated environmental areas (i.e. the AONB) and the setting of the South Downs National Park. The proposed development at Highgrove Farm directly contradicts these policies.

We strongly believe that this development would cause irretrievable harm to the landscape character, setting and context of Chichester Harbour AONB and the intervisibility with the South Downs National Park. We feel that the measures proposed within the policy would not be able to sufficiently mitigate for the damage this development would cause.

Object

Local Plan Review: Preferred Approach 2016-2035

Representation ID: 2570

Received: 04/02/2019

Respondent: Birdham Parish Council

Representation Summary:

Object to AL6:
- conflicts with DM19
- impact on traffic
- impact on AONB
- impact of link road - views of cathedral
- flood risk

Full text:

Birdham Parish Council objects to the following aspects of the Local Plan Review 2019-2035.
1. This plan is based on building 650 houses per year, 609 for the Plan Area, and 41 from the South Downs National Park. Not a single sentence in the entire plan tries to justify the increase from the Adopted Plan figure of 435, to this new figure, an increase of 49%. The adopted plan explained at length the difficulties of balancing the environmental and infrastructural constraints with the need to build houses. Considerable justification should be needed to increase the housing requirement so much, and none is provided. This figure must be revisited.
2. This plan is based on a figure of 609 houses per year, an uplift of 40% on the current annual delivery, which is the maximum allowed, as Chichester District Council have an Adopted Local Plan. If an Adopted Local Plan had not been in place the HEDNA (GL Hearn) calculates the District increase in housing for demographic growth to be 517 houses p.a, based on the 2014 Household Projections. This figure includes the South Downs National Park. There has been an updated 2016 based Household Projection, which decreases the forecast housing required nationwide over the next 25 years by 24%. This means that the latest available household growth projection growth over the plan period is likely to be in the order of 392 houses p.a. The South Downs National Park are planning to supply 84, leaving 308 needed for demographic growth in the Plan area. Even adding the ridiculous 51.5% multiplier for earning/house price ratio still only gets to 466 houses per year. It is most unlikely that 609 houses are going to be needed every year until 2035. The Plan should be more realistic and reflect this fact.

3. There is a fundamental unfairness in the Local Plan Review, in that the South Downs National Park is treated as more worthy of protection than the Chichester Harbour AONB, Pagham Harbour SPA and Medmerry designated SPA, which has led to an imbalance in the way the whole plan has been developed. This is made very clear by the proposal to accept an allocation of 41 houses per year from the South Downs National Park. This proposal should be rejected. The South Downs National Park covers 1796 sq. km, has 39 villages and towns listed in its local plan, including substantial towns like Petersfield, Midhurst, Lewes and Petworth, The National Park needs to build its own share of houses, otherwise it will become fixed in a time warp. The Duty to Co-operate should work both ways.
4. A Plan housing figure of 650 houses p.a. will make it extremely difficult to show a 5 year land supply. CDC have only just managed to prove a 5 year supply based on 435 houses p.a. Without a 5 year land supply, the whole point of a local plan is moot.
5. Strategic site AL6 is situated immediately adjacent to the Chichester Harbour AONB. This cannot possibly meet the requirements of Policy DM19. The commercial part of this site is located between the Fishbourne and Stockbridge roundabouts, two of the most congested and polluted roundabouts on an already congested road, which contravenes Policy DM8: Transport, Accessibility and Parking. The location of this site should be moved to the east of the city, where there are already substantial commercial developments. Another possible location is around the Goodwood Race Track, which would act as a noise barrier to protect local housing in the area.
6. This disregard for the Chichester Harbour AONB is further evidenced by the proposal to build a link road between the Fishbourne Roundabout and the A286. This road will be within 300 metres of the AONB and will be elevated because of the low lying ground which it crosses. This will ruin the view of the Cathedral from the harbour and generate large amounts of noise and pollution, thus disturbing the harbour, and further cut off the harbour from the city.
7. Birdham Parish Council objects to the housing allocation proposed for the Western Manhood Peninsula generally (the section of the peninsula accessed by the A 286), and Birdham in particular. The Adopted Local Plan 2014-2029 states in Para. 4.9 "More limited new development is proposed for the Manhood Peninsula, in recognition of the significant transport and environmental constraints (including flood risk) affecting the area. Policies for the peninsula follow the principles of Integrated Coastal Zone Management, which seeks to protect the area's sensitive environment and adapt to climate change." For these reasons, the total number of houses for the Western Manhood was set at 330 by 2029, a target that has already been greatly exceeded. Now, another 600 houses (Donnington 100, Birdham 125, West Wittering 25, Bracklesham 350) are proposed, and the transport and environmental constraints, which have not changed in the slightest from the adopted plan, are simply ignored.

8. These environmental constraints are:
i. Proximity to the Chichester Harbour AONB Pagham Harbour SPA and Medmerry
designated SPA
There are no accepted proposals to improve traffic flow on the A27, apart from some improvements to junctions. Proposals very similar to these were roundly condemned during the Highways England A27 consultation process. The improvements which will have to be funded by the developers will take 15 years to complete at a rate of one junction every 3 years.
This means 15 years of disruption and delays.
iii In addition, the A286 is an extremely busy road at all times, but especially during the summer, when it becomes completely gridlocked. There have been 2 traffic fatalities in Birdham on the A286 in the last 2 years. There has been a considerable loss of jobs from the peninsula over the last few years, so most residents of newly built houses will be using the A286 to travel to work, increasing the burden on the road. In addition, the majority of secondary school pupils need to travel into Chichester, using the A286. All that attend Sixth Form College from the Peninsula have to travel into Chichester. This accounts for in all at least 1000 students.
iv There is considerable pressure on primary (junior) school places on the peninsula.
v The sewerage network is close to capacity, with sewerage overflows not uncommon in wet weather.

9. The Western Manhood's requirement for affordable housing is fully met, we understand.
10. In the first 4 years of the adopted Local Plan Birdham has provided 94 (79 in Neighbourhood Plan, 15 windfall) houses built, under construction, or with planning permission, 88% more than our requirement of 50. If we are required to build another 125, we would have a total increase of 220, which is an increase of about 33% on our pre Adopted Plan housing total. The total district requirement, using the proposed figures, seems to us to be about 20% for the whole district. It seems to us as unreasonable that Birdham should accept more than its share of the District burden, especially as these houses would have to be built within a few hundred metres of the Chichester Harbour AONB, a very small AONB already under enormous pressure. It seems to us that a reasonable number of houses for Birdham to be allocated in the review period would be 50, as that would keep our village's growth in line with the district as a whole.
11. Para 17 of the Adopted Local Plan 2014-2029 stated that because the Tangmere Water Works upgrade would only be operational from 2019, the proposed strategic allocations in the Chichester/Tangmere area were not expected to be deliverable until after 2019. To compensate for this, the Plan strategy sought the early release of housing land in areas where wastewater capacity was available, i.e. the Manhood Peninsula. Building on the Peninsula was front loaded for this reason. In the event that it is decided to retain the proposed numbers in the Plan Review, the requirement to build should be deferred until there improvements to the A27 have been implemented.

Conclusion
Birdham Parish Council object to the proposal to build 650 houses per year in the Plan area. The request to take 41 houses from the SDNP should be refused.
In addition, the Plan figure of 609 should be revisited in the light of the 2016 Household Projections, and the environmental and infrastructural constraints highlighted in the Adopted Plan.
Site AL6 should be moved, and any plans to build a link road should be abandoned
Birdham Parish Council objects to the proposal to build 600 houses on the Western Manhood Peninsula, due to the lack of a credible plan to improve the transport network, and environmental constraints outlined in the 2014 Plan.
Additionally, we object to the proposal to build 125 houses in Birdham, on the grounds that this is a greater share of the overall burden than average, in an environmentally sensitive area that straddles the AONB border.

Attachments:

Comment

Local Plan Review: Preferred Approach 2016-2035

Representation ID: 2574

Received: 06/02/2019

Respondent: Earnley Parish Council

Representation Summary:

Concerns over:
- link road and traffic congestion
- flood risk
- agricultural land
- contradicts DM28
- impact on AONB and SDNP
- bird grazing area

Full text:

The South Downs National Park occupies approximately 70% of the land area of Chichester District. The remaining 30% includes Chichester City with fairly limited opportunity for major housing sites. The remainder of CDC land area includes Chichester Harbour AONB, which is a RAMSAR site and SSI, Pagham Harbour which has SPA status and Medmerry which is designated as a potential SPA. For Government to require CDC to raise its Local Plan allocation from 435 dwellings p.a. to 609 dwellings p.a. (i.e. by 40%) and then expect CDC to accommodate a further 41 dwelling p.a. from the SDNP is wholly unreasonable. This is particularly so when many Parishes in the SDNP have expressed concern about the sustainability of their communities due to the lack of housing for their younger generation.

For the Manhood (3.11) "emphasis will be mainly upon protecting and enhancing the special qualities of the coast and its rural hinterland" and there is a "need to adapt to the potential impacts of climate change and sea level rise" (4.122).
The total housing numbers for the Manhood parishes is 950, and the plan also seeks to provide new employment opportunities "to reduce out-commuting". It also acknowledges the Manhood has "Significant areas at risk from coastal erosion and flooding, which is further accentuated by a high water table and poor land drainage" (4.121). Residents would add to this a barely adequate sewer system. In view of these factors it is hard to see how the plan's housing objectives can be achieved without building on a considerable area of prime agricultural/horticultural land which is surely one of the "special qualities of the coast and its hinterland" which the plan is "protecting and enhancing" (3.11). Development in East Wittering Parish is further constrained by its settlement area adjoining and spilling over into the parish of West Wittering whose allocation is just 25 dwellings.

The existing adopted plan recognised the problems of large-scale development on the Peninsula. The Western Mannhood's allocation of 330 homes (up to 1929) has already been exceeded. It is hard to see how a further 600 homes can be justified when the previously identified problems have not been mitigated and have been made worse by the development which has already taken place.

The plan acknowledges the "unique character" of the peninsula, and its tranquil nature. Each development lowers the physical attractiveness and uniqueness of the area, while the only road with "major" noise impact identified in the Peter Brett Transport Study is Bell Lane, passing through the Somerley Conservation Area. No significant deterioration of air quality is recognised; how can this be, even with an increase in the proportion of electric/hybrid private vehicles, if commercial development is envisaged, especially that south of the A27 close to residential Stockbridge?

A further disincentive to living, working, and holidaying on the Manhood is the difficulty of access, which gets worse as the A27 traffic increases, as it must do with further large-scale development along the East-West corridor. The planned mitigation in the form of a Stockbridge by-pass is at best a short-term solution, improving the problems with the Stockbridge Road roundabout. But any commercial development in the same area, south of the A27, would further raise traffic levels attempting to reach the A27 from the new route. So
at worst, if the proposed commercial development at AL6 is taken into consideration, the proposed new Link Road from the western end of the by-pass to Birdham Road is likely to create a new "Vinnetrow Road" situation at the Fishbourne roundabout.

The proposed industrial / housing development at AL6 is largely within an area of agricultural land prone to flooding: it is close to the R. Lavant and susceptible to further damage from rising sea-levels. AL6 does not mention these major risks, though AL4 specifically mentions the need to avoid the flood-plain of the Lavant in relation to Madgwick Lane. Further, such a development contradicts DM28, there being "adverse impact on the openness of the views in and around the coast, designated environmental areas and the setting of the South Downs National Park"; and the tranquil and rural character of the area. Salterns Way cycle route would be alongside the development; the much prized peacefulness of the route and the views of the cathedral and Downs would be destroyed. Furthermore, AL6 is adjacent to Chichester Harbour which as previously mentioned is not only an AONB but is a RAMSAR site and SSI. There is evidence of Winter grazing by migratory birds in the area designated as AL6.

Traffic levels within the Manhood are already such that heavy commercial vehicles choose to use country lanes which were not built for the capacity, while the transport of agricultural/horticultural produce, particularly on the B2145, and the movement of agricultural machinery has a significant impact on journey time. Further housing and commercial development will require mitigation on the Peninsula itself.

Turning to the Brett Transport Study and the Appendix dealing with Air Pollution, given what they say in 3.2.22 and particularly in 3.2.23, it is staggering that in 3.2.24 they make their glib 'standard' statement when we know already that 4.1% of deaths in Chichester are due to PM2.5 pollutants from vehicle emissions.

How can 3.2.24 consider future vehicle uncertainties ref 3.2.22, if they are uncertain? There is no risk analysis in the Brett report to support the assertion that: the report is 'an appropriately conservative assessment.' The real risk to lives in this area is too significant to be dealt with in this superficial way.

In considering alternative industrial / housing sites to AL6, AL4, which is included in the current CDC Local Plan, is ideal. It is recognised that this has been withdrawn from the HELLA; consideration should however be given to using compulsory purchase powers to acquire this site for industrial use. Most airports / airfields in the UK have industrial area on their boundaries.
The Peter Brett Transport Study estimates that the cost of mitigation measures at £68m, this level is clearly way beyond the level at which it could be funded by developer contributions. Without defined future funding plans, housing development should be phased in line with actual funding.

It is encouraging to see the proposed introduction of "wildlife corridors" to the east and west of Chichester linking the Downs with Pagham and Chichester Harbours respectively. However they should not be positioned where they conflict with 5.24 which addresses the possibility of an A27 northern relief road. They should also be wider at the coastal end: the two to the east of the city could even be joined to form one.

As the plan recognises the international importance of the two harbours and the Medmerry Realignment for wetland habitat (2.25), it would be a positive step to designate a protected area to link Chichester and Pagham Harbours in the same way.

Earnley Parish Council is pleased that small-scale Horticultural Development will still be focussed on the two former LSA sites in Almodington and Sidlesham, and applauds DM21, which sets out the conditions for redevelopment of buildings in the countryside, where currently there seems to be a presumption in favour of housing.

Currently there is a demographic imbalance on the Manhood and in CDC in general. Locally we are all aware of the need to provide accommodation which attracts younger people into the area and gives our own young people the opportunity to make their homes here. How can this happen? To use the term "affordable housing" is a deception. In an area with such high market-rate housing, "affordable" is simply not affordable. In a holiday area, the rental market is limited and distorted by the high number of holiday lets; there is no guarantee that new housing would not benefit tourists rather than prospective residents. The proposed Plan is, of course, moulded and constrained by government policy, but there is nothing in it which comes close to solving this part of our "housing crisis".

To sum up, Earnley Parish Council:
* Is opposed to the scale of development proposed for the Manhood Peninsula
o Believes this level of development to be unsustainable
o Believes it to be incompatible with maintaining the rural character of the area and the mixed nature of the local economy
* Finds the mitigaton propsed for the A27 to be insufficient and ineffective
* Is opposed to the AL6 development
* Is concerned by the increases in air and noise polution
* Urges CDC and WSCC to consider more closely the social housing needs of the area

Object

Local Plan Review: Preferred Approach 2016-2035

Representation ID: 2635

Received: 04/02/2019

Respondent: Mr Mike Dicker

Representation Summary:

- Site not suitable for employment. This should be located at site south of Goodwood.
- Site better suited to a park and ride.
- Link road rejected by previous consultation.
- Wastewater impact on Apuldram WWTW.

- Testing has not been conducted
- Unable to provide proposed usage
- No concrete proposal, just suggestion of need for link road
- No mention of view of cathedral and SDNP
- No mention of level 3 floodplain
- No mention of impact to river Lavant and biodiversity


See attached for full detail.

Full text:

Full detailed submission for the Local Plan and supporting evidence is attached.

The representations attached to this submission reflect a high level summary of the detailed submission and do not contain the full level of detail received.

High level comments received:

a. The transport study conducted by Peter Brett Associates (PBA) is not fit for purpose and needs to be rewritten. The scope set for PBA is far too constraining and counters the democratic process agreed by the council to seek alternative routes.

b. Many of the documents are inconsistent and in their current form smack of inconsistency and bias. Reasons for excluding some strategic sites are not consistently used for other sites.

c. Many of the evidence documents are not present or are not complete for this consultation. These will need to be re consulted when they are complete.

d. CDC should not be accepting the unmet housing need from the South Downs National Park (SDNP). They should also be going back to government to insist that until certainty is provided on the A27 this area can not accommodate future housing and or employment space.

e. The proposed link road was resoundly rejected last time it was proposed by Highways England. CDC need to respect the voices that rejected what is option 2 by stealth. Particularly as the PBA report states that the building of the link road will offer other "strategic options". This will not be tolerated locally.

Attachments:

Object

Local Plan Review: Preferred Approach 2016-2035

Representation ID: 2770

Received: 07/02/2019

Respondent: Sussex Wildlife Trust

Representation Summary:

SWT objects to this allocation as no evidence is provided to demonstrate the development, in particular the new road, can be achieved without significant harm to the environment e.g. Lavant Marsh LWS and chalk stream that runs through the site. site falls within Impact Risk Zone for the Chichester Harbour SSSI.
In the absence of adequate survey data to assess the impact of this proposal on biodiversity and demonstrate that measurable net gains to biodiversity are achievable the site should not be allocated. Ucceptable for the provision of this crucial environmental information to be left until planning application stage.

Full text:

See attachment

Attachments:

Object

Local Plan Review: Preferred Approach 2016-2035

Representation ID: 2776

Received: 07/02/2019

Respondent: MR William Sharp

Representation Summary:

Objection on grounds that: extensive areas of Greenfield have been sacrificed for development; no acknowledgment of potential severe adverse impact on Salterns Way or wildlife corridor west of Chichester; development on the other side of roads cannot be characterised as an extension to the city; cavalier attitude to rural setting - rural areas should be preserved; Link road may not prove necessary; bus services at discretion of developer are not a long-term traffic mitigation measure.

Full text:

See attachment

Attachments: