Policy AL7: Highgrove Farm, Bosham

The imposition in the CLP of the Highgrove development on Bosham shows a total disregard for local democracy and the Neighbourhood Plan has been ignored.
Consultation with the village showed that Highgrove was the least favoured of 12 options. This shows a disregard for the recently defined Strategic Countryside Gap policy.
The site is known to be liable to rainwater flooding. The large increase in the foul water burden on a system that already regularly discharges untreated sewage into Bosham Creek would be a totally unacceptable health risk without a major increase in capacity before any building takes place.

This proposal is against the clearly declared wishes of the local community in that it would be a step towards the ultimate coalescence of Bosham and Fishbourne, and in direct opposition to CDC's policy of maintaining the distinct identity of communities by keeping them physically separate (para 5.42 of your document).
Further 'ribbon development' along the A259 is not what Bosham needs. Of far greater benefit would be to link the two halves of the village, North and South of the 259, by putting the required housing, recreation area and possibly school, into the field between Delling and Walton Lanes. It is within the AONB but if the hospice can be built there why not houses?

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

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

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

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

I set out my reasoning herewith:-

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

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

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

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

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

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

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

6.49 Development south of the A27 between Stockbridge and Fishbourne.

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

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

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


Bethwines development Traffic problems.

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

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

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

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

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

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


The A27 and A259

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

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

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

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

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

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

This policy cannot be fulfilled!!

1. There is a fundamental flaw flying in the face of due process in CDC's proposals so far as Bosham is concerned.
2. 250 dwellings is a totally arbitrary number, pulled out of the ether to fit what is perceived to be an available site.
To put the point a different way, had Highgrove Farm been 15 hectares CDC would have proposed 300 dwellings, or had it been only 8 hectares the proposal would be only 150 dwellings. This arbitrary allocation of a requirement cannot be right.
3. CDC has to prove 'need'. Where is the need for 250 more houses in Bosham? Where is the evidence?
4. If CDC can get past those hurdles, there are serious questions over these draft proposals.
5. No evidence had been provided to demonstrate that the site is capable of holding 250 dwellings, plus a school, plus public open spaces and play areas, as well as adequate on-site parking. How much area is being allocated to each? Current independent views are that the site is not big enough for all this.
6. Surely the whole point of this process is to increase the number of affordable houses? But there is no specific mention of this aim. It is critical CDC impose a binding requirement that at least 30% of the dwellings are affordable.
7. Who is to fund the building of this new school? Has Bosham Primary School confirmed it wishes to go down this route and relocate north of the A259? Are all the parents happy for their children to walk from Bosham village northwards over the A259? What is the happen to the area if the proposal to build a school is not feasible?
8. Traffic access onto the A259 at Chequers Lane, currently difficult, will become significantly more dangerous once the new Hospice is working and generating the estimated extra 500 vehicle movements each day. On top of this will be additional vehicle movements from the 50 houses to be built at Highgrove opposite Chequer Lane. To add another 250 houses at the same location begs the question: Where is the money going to come from to widen the A259 and make it safe both for traffic and everybody who will have to cross it?
S106 (or its equivalent) funds will be there, but they will also be required to fund improvements to the Fishbourne roundabout, open spaces, a new school, upgrading sewage works, possibly a pedestrian bridge or underpass, to name but a few. Where is the feasibility study for the use of community funds?
9. It is well known that the site floods, with the result that the watercourses to the south become over-whelmed which in turn leads to flooding in Bosham village. This happens on a regular basis now. Having in mind the amount of hard-standing and non-percolation which 250 houses will generate, there is a major concern about future flooding risks which will not matter to the developer, but which matters to all of us who live to the south. The writer has personal experience of fluvial flooding in June.
10. The state and capacity of Bosham's sewers are well known. The current development at Highgrove has overcome the capacity problem by funding larger capacity pipes within the present system. It is understood that this brings the pumping station almost to capacity. Before this proposal moves any further, it is essential CDC seek the views of Southern Water on the feasibility of connecting another 250 dwellings into the system, on top of the new Hospice and the 50 houses at Highgrove.
11. How is CDC going to manage such a large project in a highly sensitive area and guarantee delivery of a "high quality form of development" when they are under-staffed, I suspect under-resourced, and cannot cope with their current work load? To build yet more houses adjacent to the AONB will require specialist design input to help advise and direct the developers. What are CDC's management proposals for handling this and other developments? Just to 'muddle through' should not be acceptable. These big projects need and must be fully resourced.
12. The last time there was a public consultation on development at Highgrove, Bosham villagers decided it was the least acceptable site of many put forward in the Village Plan. Despite this, CDC decided not to support Bosham, notwithstanding that at the same time, approval was given for the building of the new Hospice in the AONB.
CDC has over the years approved many housing proposals in the AONB within the district, and Bosham should be no exception.
13. Rather than continue and extend a problem, which fly's in face of CDC stated policy of keeping the coastal villages separate with their own identities, CDC should work with the village in deciding what are its need and how best to meet them, whether they be inside or outside the AONB.
14. For a start, there are identified 'brown-field' sites available, as well as other areas, which Bosham would prefer. Should not the village have a real say it what is best for it?
At the consultation in Bosham on 7th January, CDC suggested Bosham could do this, provided its alternative proposals were for 250 dwellings, or that it explained where any shortfall in its suggestions should be sited. Not only is that an impossible task unless CDC is willing to make available the same resources as it has, but it assumes 250 dwellings is an appropriate number, which comes back to my opening remark.

The plan states the intention to build a MINIMUM of 250 dwellings. We object to the term 'minimum'. The use of the word 'minimum' implies the actual number of dwellings built could be much higher than 250, and we are not given any information regarding what the maximum number of dwellings might be. This is unacceptable.

Requiring a rural parish to accept a significant housing allocation, when 84% of its land area is covered by the ever stricter protection afforded by an AONB designation, was always going to place a severe distortion on the notion of respecting and enhancing the distinctive qualities of the settlement. This document is not Town or Village Planning; it is merely the allocation of open fields to a housing estate without any real regard to either the principles of sustainable development or notions of the ancient art of 'place-making'. The former has been in recent times the entire justification of the role of state regulation and the latter was its original justification in the twentieth century. Both are spectacularly swept aside in this District-level document! We are left with a threadbare set of justifications for a bad decision.

The Bosham Association finds the 'Preferred Approach' document highly contradictory, expressing fine sentiments with respect to the principles of sustainable development, but then willfully ignoring them in the allocation of specific sites to housing estates (AL6 and 7.) Furthermore, it shows scant regard to the natural relationship that must be maintained between Downs and Harbour. These two areas, which 'enjoy' protective designations (National Park and Area of Outstanding Natural Beauty), are inextricably linked by geology, drainage, ecosystems, landscapes, and traditional land management. The background document on 'Strategic Wildlife Corridors' offers wafer thin connectivity to address these issues, aligned only as it is with narrow strips along the chalk streams . The 'Sustainability Appraisal' which is supposed to underpin the document is out of date in respect of the sewerage systems and fails to recognise the landscape assessments made by 'terra firma Consultancy' (Nov 2018) and an earlier one by Hankinson Duckett.

Moreover, the local plan review and conclusions were made before CDC had received the landscape assessment by Terra Firma. This raises two points
1. The proposed allocation at Highgrove should be reviewed in the light of the Terra Firma assessment conclusions. For example the character area in which the Highgrove site is located has been assessed as having a Medium/ low capacity. The definition of this is
"Medium / Low capacity (orange) - A low amount of development may be accommodated only in limited situations, providing it has regard to the setting and form of existing settlement and the character and the sensitivity of adjacent landscape character areas. In some cases no development would be acceptable and the reason for this is explained in the conclusion."
The final paragraph of the character area assessment states
"It is possible that some built development may be accommodated within the existing cluster of buildings and potentially to the north of Broadbridge provided it is informed by further landscape and visual impact assessment and sensitively integrated into the landscape, respecting the historic settlement pattern and local distinctiveness. Great care would be needed to be taken to avoid any landscape or visual harm ensuring the separate identities of the settlements are protected and considering valued views." (NB the Bosham Parish Neighbourhood Plan identifies valued views across Highgrove to the South Downs)
The proposed allocation at Highgrove is contrary to all of the above statements.
2. The Terra Firma assessment reaches the same conclusions as the earlier Hankinson Duckett assessment and therefore carries greater weight.

'The Preferred Approach' merely acknowledges that "The site is relatively free from physical constraints, although there are landscape sensitivities associated with the openness of the site and the views into the site from surrounding areas." (6.53) This is nothing less than a massive understatement because the site occupies the narrowest of gaps between the National Park and the Area of Outstanding Natural Beauty. The value of maintaining open countryside between (inter alia) Bosham and Fishbourne has been recognised by local people many times in the last five years when they have been given the opportunity to voice their views in an evidenced and documented manner. It was the basis of the strategic vision in the draft Bosham Parish Neighbourhood Plan, supported in a poll of over 450 local residents, expressed in no less than two planning applications for development at Highgrove Farm, attracting no less than 100 objections on these occasions. Furthermore, the allocation by CDC of the 50-unit site in the SW quarter was also opposed by the Parish Council and overwhelmingly by local people. The repudiation of site AL7 for housing development could not be more emphatic on grounds of evidence and popular choice.

A number of important policy principles derived from a fundamentally sound grasp of the spatial characteristics of the whole District are outlined in the 'Preferred Approach'; and then duly ignored. This submission identifies just how wrong the selection of AL7 is, but many of the comments also apply to AL6.

The identification of AL6&7 as sites proposed for coalescence with neighbouring historic areas threatens that which is upheld in 7.162 namely "Chichester District itself can be divided into four locally distinctive character areas: (and then inter alia)
"4. The Coastal Plain framed with the backdrop of the South Downs to the north. Characterised by a flat, open more exposed landscape with remnants of woodland and small villages connected by a network of narrow winding lanes and minor roads"
Furthermore para 7.163 states that "Within these character areas there are also several views and vistas, which should be protected in the design and layout of new development. These include views inter alia "Towards Chichester Cathedral" and "Towards the South Downs from the Coastal Plain"
Therefore, the selection of AL7 compromises two groups of views which policy professes to protect, the views are both east/west and north/south reciprocating! We are indeed in Alice in Wonderland!

So what of the distinct villages surrounding the free-standing cathedral city of Chichester? The Development Strategy states:
"The starting point for housing development at Service Villages is that in principle, they are suitable places to accommodate new housing. However, consideration has been given to other factors in determining whether a settlement is a suitable location for additional housing growth, including infrastructure capacity, the existence of suitable sites and consultation responses".
We shall see how much heed is paid to all three points but especially the last. Having failed to heed any of the previous consultation responses on this site, we have little confidence that the District means what they say.

Bosham is designated a 'service village', but has already 'landed' a 'hub' function, namely St Wilfrid's Hospice by decision of the Planning Committee overruling the recommendations of professional officers. Moreover the experience over the last five years is that the District Council fails to heed 'consultation responses' as was evidenced by the Neighbourhood Plan process, the 'premature' planning application for Highgrove, the 'strategic allocation' by CDC Cabinet and most recently the actual planning application for 50 houses at Highgrove. All of these proposals attracted overwhelming opposition and all these popular local sentiments have so far been ignored. It does therefore not bode well for this current 'consultation'.

The CDC current sustainability strategy states: "The Local Plan Review strategy has been shaped by a range of factors including (inter alia):
"Environmental constraints - avoiding flood risk areas, protecting environmental designations, landscape quality, the historic environment and settlement character". We shall show that each of these elements have been belittled or ignored in the rush to find a big site for a big builder in the Parish of Bosham.

Policy S26: Natural Environment states inter alia:
"Ensuring there is no adverse impact on the openness of views in and around the coast, designated environmental areas and the setting of the South Downs National Park. See Policies DM19, DM20 and DM28." Yet the Chichester Harbour Conservancy, The South Downs National Park and the Chichester Harbour Trust among others have all expressed either strong objections or severe reservations about the allocation of this site being chosen for a housing estate.

Policy DM19: Chichester Harbour Area of Outstanding Natural Beauty (AONB) states inter alia "Either individually or cumulatively, development does not lead to actual or perceived coalescence of settlements or undermine the integrity or predominantly open and undeveloped, rural character of the AONB and its setting;"

Policy S26: Natural Environment states inter alia "Considering the quality of the agricultural land, with the development of poorer quality agricultural land being preferred to the best and most versatile land." In addition the proposed site for development (ASL7) was recorded by MAFF in 1995 as having land of 'good' or 'very good' quality (The fieldwork was conducted at an average density of 1 boring per hectare. A total of 16 borings and one soil pit were described.) Why are we losing this valuable agricultural land when food security is a rising concern?

Policy DM28 is worth quoting in full:
"Natural Environment The impact of proposals will be carefully assessed to ensure the protection, conservation and enhancement of the landscape of the Plan area. Planning permission will be granted where it can be demonstrated that all the following criteria have been addressed:
"1. There is no 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.
"2. Development recognises distinctive local landscape character and sensitively contributes to its setting and quality;
"3. Proposals respect and enhance the landscape character of the surrounding area and site, and public amenity through detailed design;
"4. Development of poorer quality agricultural land has been fully considered in preference to best and most versatile land; and
"5. The individual identity of settlements, actual or perceived, is maintained and the integrity of predominantly open and undeveloped land between settlements is not undermined."
Yet we have the decision of the Planning Committee of 19/12/18, which although challenged, decided to ignore all these considerations and give consent to the first 50 houses on the Highgrove site.

Let us remind ourselves on the significance of this 1.2km stretch between the Downs NP and the Harbour AONB, a deer, fox, badger, water vole, field mouse, hedgehog and the like currently have to hazard a main rail line and a four-lane trunk road. Avians like buntings, finches, siskins, longtailed tits, warblers, wrens, gold crests use the hedges as corridors. Habitat fragmentation stares us in the face and all for the sake of failing to protect a kilometre-wide separation.
When Julian Glover expresses the hope that these protective designations will form the hubs of networks, there has to be a rural fabric upon which the networks can function. Continuous urban sprawl is not conducive. A bad decision on AL7 cannot be undone and a vital strand of our biodiversity is unravelled forever. Harbour and Downs habitats will be divorced forever.
What is the cultural value of the Villages-City-Downs-Harbour matrix? Allocating AL7 will tear the view betwixt the ancient yews of Kingley Vale, the beech of Stoke Clump and our harbour lands and will destroy it forever. The freestanding City of Chichester set amidst distinctive surrounding villages will be replaced by sprawl already mockingly called 'Emschester'. Is this to be the legacy of District Planning in this decade?

Back in 2013 the CDC assessment (SHLAA) of the site threatened development over all 16.8 ha (41 acres) with 265 houses which by 2014 the village had rated 11th out of 11 potential sites. CDC is now proposing 300 houses plus a two-form entry primary. Such a school would cost about £8m and there is no supporting evidence of the need for it. Better space standards on the existing single-form entry primary is desirable as is a dedicated recreation area. This could be more conveniently addressed at lower cost, less disruption, whilst maintaining the geographical centrality of the school site within the village by finding an alternative site for the existing recreation ground. Yet, to our knowledge, no landowners have been approached.

Instead, we know from previous proposals that Barratts want to allocate a space on which others could build and pay for a school at the extreme NE of the site next to the railway line. This site would be almost as far as possible from the historic core of the village, whose heritage value has hitherto benefitted so many pupils at the school since 1896 when it first occupied its present site. It is one of the features of our local acculturation that makes village identity distinctive. It is a location from which most homes, as well as church, manor, mill and quay can be reached on foot, a centre for sorties from school.

The ultimate embarrassment of the document must be the statement that after a peripheral estate of 300 houses is completed, irreversibly narrowing the gap between distinctive villages, the District Council will consider introducing a policy to prevent 'gap-filling'! It says:
"5.42 The countryside also performs an important role in providing a setting for the plan area's settlements. Maintaining the individual identities of communities is an important priority for the Council. The most obvious way of achieving this is keeping them this is keeping them physically separate from each other and areas outside of the plan area e.g. Emsworth to the west and the Coastal West Sussex Urban Belt to the east. Development over recent years has tended to cause some merging of settlements. The Council considers that designating areas between settlements as countryside gaps to be kept free of urbanising development may be an appropriate way of seeking to prevent further loss of local identity. A study of the potential for introduction of gaps between various settlements across the plan area is currently underway. Should the results of this study support the case for introducing such gaps, then this provision will be included within the next iteration of this Plan."

So what to make of that? What words best describe the CDC approach? Contradictory, confused, disingenuous, devious, insincere, hum-bug, perfidious?

Did the District consider all the options? Well no, not really. One option that seems privileged in 'The Preferred Approach' was addressed in the revamped sustainability appraisal
The new sustainability appraisal notes:
"4.6.5 Option 2 - Focus on the East / West Corridor Here the vast majority of new development is focussed to the west of the City along the A259 and railway corridor, with no provision at Tangmere or Hunston and very limited development on the Manhood Peninsula. This reduces some of the negative impacts of Option 1 on the Manhood (as does Option 1A) but without some of the advantages that come from a more even distribution around (and close to) Chichester City. The additional 750 homes near to the railway line will help mitigate the additional distance to travel into Chichester City for some, but not all households. There is also an increased risk of impacts due to the development becoming out-of-scale to the existing form and facilities of the settlements and also cumulative landscape and biodiversity impact as the settlements in this area begin to coalesce leaving smaller gaps between them."[Emphasis added]
This observation has been ignored or disregarded. One starts to wonder why these background documents have been commissioned at public expense, when they are steadfastly ignored.

The sustainability appraisal re-states that the Headroom at Harts Farm WWTW is still 400 despite the council being notified that since this figure was estimated in 2013, there have been a further 148 connections and an additional 50 with the approval of 50 units at Highgrove Farm. The details of the consented connections since 2013 are listed below for connection to the Harts Farm WwTW:
Bosham Hoe and Smugglers Lane 90 with a potential of another 30
Westwinds, Station Road /Arnold Way 4
Spindlewood, Bosham Lane 1
Oyster Mews, Bosham Lane 4
(St) Benedict's, Bosham Lane 2
Whitwell House, Taylors Lane 1
South of Harbour Way. Taylors Lane 2
Fire Station Site, Critchfield Road 3
Church Farm Meadow, Bosham Lane 5
Next to Sailaway, Main Road 1
St. Wilfrid's Hospice - equivalent of 25
East Ashling 10
Total additions consented 148
Highgrove consent 19/12/18 - 50
On this basis, there could only be a maximum headroom of 200 unless Southern Water makes yet another revision of their evidence base as they did at the last moment for the application considered on 19/12/2018. Reliability of their methodologies is being sorely tested. Moreover, this takes no account of the state of the groundwater, the porosity of the sewer-pipes and the infiltration of storm water into the whole system necessitating discharges (under licence) of untreated sewage into Chichester Harbour. The SA takes no account of this documented and ever-present threat to a precious environment, which is supposedly protected under SSSI, RAMSAR, SNC and SPA designations. There are also bathing water directives that have to be considered.

The SA simply lacks detailed knowledge of groundwater and drainage conditions. This leads it to state blithely that SuDS systems are appropriate when they are not. In particular, it ignores the very high watertables, which exist on land to the east of Ratham Lane and on Highgrove Farm fields. Yet the developers had in their possession a report (Land at Highgrove Farm, Main Road, Bosham
Flood Risk Assessment Aug 2014 for Barratt Homes by www.paulbashamassociates). Among its conclusion were the following:
"8.6 The Landmark Flood Data shows that there is the possibility of a very high water table. This was borne out by a site visit, where standing water was observed in the south-west corner. Considering this, infiltration is unlikely to be suitable for draining the site.
8.7 Given that infiltration is unlikely to be suitable, a drainage strategy has been prepared based on positively draining all hard surfaced areas, restricting the outflow to greenfield run-off rates, and attenuating the excess water within oversized pipes, a cellular storage system with the central area of POS, and a balancing pond in the south-west corner. Due to the level nature of the site, surface water has to be pumped from the cellular storage system to the remainder of the system further south.
8.8 Outfalls into the ditch will be restricted via Hydrobrakes to existing greenfield run-off rates - 5.11l/s for a 1 in 1 year storm, 13.8l/s for a 1 in 30 year event, and 19.1l/s for a 1 in 100 year event. A complex Hydrobrake system will manage these outfalls."

The Sustainability Appraisal undertaken by CDC to underpin the Plan Review also ignores the landscape consultant assessment (Terra Firma) of the Highgrove site as having the following type of sensitivity (to quote again):
"Medium / Low capacity (orange) - A low amount of development may be accommodated only in limited situations, providing it has regard to the setting and form of existing settlement and the character and the sensitivity of adjacent landscape character areas. In some cases no development would be acceptable and the reason for this is explained in the conclusion"

The justification for a new two-form entry primary school - what is the evidence of need? There are no scheduled annexes to justify this assertion. The Bosham Parish Neighbourhood Plan team extensively canvassed ideas for a replacement school and canvassed alternative more central sites. At that time, staff and parents were content with the existing single-form entry school and its current location in the heart of the village and within walking distance of all the historic built assets of the medieval core. A new school at Highgrove would be car-dependent adding to congestion as is evidenced already with the current school parking/drop-off problems in Walton Lane and the intense traffic congestion surrounding larger schools e.g. the Bourne Community School in Manor Road/Park Road, Southbourne. In addition, a primary school adjacent to a busy railway line is far from desirable. Furthermore should the existing school site become redundant, and then it will surely go for more housing (which has not been counted contributing toward the Objective Assessment of Housing Need). It would be far better to address the question of bespoke playing fields and environmental education through the conversion of the current recreation ground to exclusive school use. It would then be possible to allocate of a new recreational area to replace it whilst at the same time addressing the net shortage of public recreational space for size of the Bosham's population, which was identified in the Neighbourhood Plan.

In conclusion, when we turn back to the criterion used in the original Bosham Parish Neighbourhood Plan for the selection of suitable sites for housing we find that the Highgrove proposal scores amongst the worst of sixteen sites surveyed in the Neighbourhood Plan preparation. What were those criteria? They were:

1. Bio-diversity
2. Flood/Sewerage Risk
3. Transport
4. Landscape & Heritage
5. Village character
6. Best use of land,
7. Employment and economy,
8. Energy and climate change, mitigation.
9. Access and provision of services,

Thus we see that not only does the Highgrove site spectacularly fail on many objective criteria, but it also fails to make a contribution to that vital concept of good town and country planning, that of place-making, being instead a mere land allocation for a peripheral housing estate. The District Council may be exercising its power in this matter under the provisions of the Town and Country Planning Act, but what it is doing is manifestly not town and country planning.
This is submitted on behalf of the Bosham Association, an amenity body (registered charity) representing about 450 local residents.

I write especially with regards to bosham as that is where I live but overall I am concerned about the sheer number of houses proposed mainly due to the impact of the increased cars. I already choose not to seek employment to the areas east of Chichester due to the sheer weight of traffic there is getting past the city. There is no clear road improvement strategy to manage the already heavily congested roads. Another 1000 plus houses and associated cars will only exacerbate the traffic issues and reduce the desirability of living and visiting the area.
I also do not see any clear funding plan for increasing health services for all the extra people. With an increasing elderly local population this needs addressing.

With regards to the Highgrove site in bosham my concerns include:

1) I understood that a water study noted how the rain water from the downs runs into Highgrove fields which would cause concerns around flooding if the area is built upon. How would this be managed?

2) when there is no funding or appetite from the council to build new schools. How would a two level entry school be built ?
Also where is the evidence that a two level entry school is required ?
Taking the school out of the heart of the village will increase car use and change the atmosphere of the village.
Also if the school is moved out of its current site no doubt the council would see the land for even more houses this increase the housing density in the village. This needs to be made a clear intention for people to be made aware of.

3) the housing you will be build is likely to overpriced for local young people who are generally already out priced by the low wages compared to house prices in the area. This does not solve the housing crisis.

On a slightly difderent note, what is the council planning to do about the changing city centres?
There will be more opportunity in the city centre as retail changes. Maybe use some of the empty shops for housing or reduce the rates to encourage shops back in. Whatever is decided the council needs to be proactive in responding to the changes to ensure this is still a desirable place to live and visit.

Specifically regarding Bosham, the five-fold increase in homes allocated to the Highgrove site (from 50 to 250) does not take any account of the view of the local community as expressed in the Bosham Parish Neighbourhood Plan. Of 11 options considered in the plan, the last three (Highgrove 50 dwellings, 100 dwellings and 250 dwellings) we the least favoured.

This is is far too large a development to be accomodated here.

If more housing is needed I fully support the proposals for Policy AL7: Highgrove Farm, Bosham. The most important thing is to avoid any new development on green field sites within the AONB in order to preserve the iconic nature of the village of Bosham, as far as possible. It is essential that provision is made for a two-form entry primary school.

Even considering the building of 250 homes within this AONB would be an unmitigated disaster, totally ruining the landscape and overwhelming the infrastructure of this already vulnerable village. My home has already flooded twice and sewage has emerged from a manhole immediately outside my home. The services in this area simply cannot cope with this scale of urbanisation. Any development on Highgrove Farm should be limited to a maximum of 50 dwellings. Bosham is a village of character and historic importance to be protected and nurtured. Far more appropriate sites are available and the over-development of Highgrove Farm is unacceptable.

the land is grade one/two agricultural.
There is no waste water management plan (drainage, sewerage) which is a fundamental issue for the community already the system is not coping.
There are real fears that building will significantly increase flooding (on and offsite) due to the high water table.
There would be considerable loss to eco-systems and wild life corridors, resulting in habitat fragmentation.
It would severely damage the setting of the National Park, the AONB generally
It would lose the distinctiveness of the settlements of Fishbourne and Bosham
There is no thought as to how to satisfactorily relieve present traffic issues, never mind future congestion and resultant diminution of air quality.

The land is grade one/two agricultural.
There is no waste water management plan (drainage, sewerage)
There are real fears that building will significantly increase flooding (on and offsite) due to the high water table.
There would be considerable loss to eco-systems and wild life corridors, resulting in habitat fragmentation.
It would severely damage the setting of the National Park, the AONB generally
It would lose the distinctiveness of the settlements of Fishbourne and Bosham
There is no evidence (in the Document) to justify the proposed two form entry (420 number) primary school
There is no thought as to how to satisfactorily relieve present traffic issues, never mind future congestion and resultant diminution of air quality.

Do not build 300 houses on agricultural land that preserves the gap between Fishbournecand Bosham . The proposed infrastructure cannot support this development and the services are inadequate

I believe that this land needs to stay as agricultural because:
The land is grade one/two agricultural.
There is no waste water management plan (drainage, sewerage)
There are real fears that building will significantly increase flooding (on and offsite) due to the high water table.
There would be considerable loss to eco-systems and wild life corridors.
It would lose the distinctiveness of the settlements of Fishbourne and Bosham
There is no thought as to how to satisfactorily relieve present traffic issues, never mind future congestion and resultant diminution of air quality.

My objections are supported by the following considerations:

1. The land is grade one/two agricultural.
2. There is no waste water management plan (drainage, sewerage)
3. There are real fears that building will significantly increase flooding (on and offsite) due to the high water table.
4. There would be considerable loss to eco-systems and wild life corridors, resulting in habitat fragmentation.
5. It would severely damage the setting of the National Park, the AONB generally
It would lose the distinctiveness of the settlements of Fishbourne and Bosham
6. There is no evidence (in the Document) to justify the proposed two form entry (420 number) primary school
7. There is no thought as to how to satisfactorily relieve present traffic issues, never mind future congestion and resultant diminution of air quality.
8. Generally speaking, we are altering the area in so many countless ways that very soon we will have a conurbation from Chichester to Portsmouth.

The land is Grade One agricultural land and should be used for food growing. The field is totally waterlogged most winters and will be difficult to drain as it is so flat. There is no reason to suppose that Southern Water will be able to deal with the sewage from the 50 houses which were given planning permission in December let alone the additional 200 now suggested. There is a serious danger of Bosham joining up with Fishbourne (large number of houses suggested there) to form 'Emschester East'. The A259 cannot possibly cope with the additional traffic.

Highgrove is a totally inappropriate site for an additional 250 dwellings on top of the 50 already approved. There are many reasons for this:

- there is no waste water management plan and not enough capacity
- the high water table could lead to additional flooding
- it would severely damage the setting of the National Park, the AONB generally and there would be considerable loss to eco-systems and wild life corridors, resulting in habitat fragmentation.
- the distinctiveness of the settlements of Fishbourne and Bosham would be lost

Given that the planning application for 50 houses at Highgrove Farm was approved despite the many detailed and well-reasoned objections from both local residents and 'official bodies' - it is hard to see that objections for the inclusion of a further 300 houses on Highgrove Farm in the Local Plan Review will hold any weight.
However, I object to the further loss of agricultural use for this land, for the following reasons:
1. The issue of Waste Water Management that was raised when the Bosham Neighbourhood Plan was put together still hasn't been addressed.
2. The issues of future flooding once the field has been 'paved over', and the loss of valuable existing eco-systems have not been adequately addressed.
3. The development of a further 300 houses on this site will put huge extra strain on local facilities - namely roads, health services, shops, schools etc...
4. A further 300 houses on this site is too many.
It is therefore vital that full consideration is given to all the issues mentioned in clause 6.56 on the CDC portal before a decision is made to change the land at Highgrove Farm from agricultural use to housing.

I am emailing to raise objections to the proposed development of two hundred and fifty new houses on Highgrove Farm, Bosham. There are several reasons why I would like to object to this development, which I will outline below.

Firstly, there is the issue of infrastructure. As a regular user of the A259 in the morning, I have no doubt that the extra traffic from the three hundred new residences (including the fifty already planned) will bring the Fishbourne Roundabout to a gridlock. There is so much proposed development to the south and west of Chichester that this is bound to have a knock on detrimental effect to the already overloaded A27 and surrounding roads. With no proposed road infrastructure change, the traffic at junctions will build up and this then has implications for pollution levels. There will already be considerable extra traffic along this road with the opening of the new hospice, which I do not object to because it serves a much needed purpose in the area. However, with the average family now owning two cars, there are potentially six hundred more cars idling on one road and this is not going to be good for the environment or any of the people who live in the area.

My second concern is the increased pressure that three hundred new homes will put on the sewerage system and water transport network. Bosham already has an extremely high water table and only a few years back, during a period of rain, the local pub was severely flooded and had to be closed for over a year. Drainage on the site is not sufficient and as a long time resident of Bosham, I am concerned by the amount of standing water that accumulates in the Broadbridge and Highgrove area and on the farmland during even short periods of rain. I cannot see how building on this land will make this problem go away. In addition to this, by allowing this development you will be adding to the burden on a sewerage system designed for a small village. This is sure to cause future problems.

Further to this, there is the certain destruction of large areas of natural beauty and wildlife habitat. Whilst I understand that there is a pressure to build homes for the future, adding three hundred houses to one small area and closing the gap between Fishbourne and Bosham is not the way forward. Has any consideration been given to other sites of smaller developments on other pockets of land that will not compromise the beauty, air quality or distinctiveness of the village?

Finally, as a local teacher, I have grave concerns about the idea of relocating the school. It is not the size of the school but the location which worries me. By relocating to the farm, there will be an influx of children having to cross the busy A259. If a child lives in old Bosham, there will be a much longer journey, some of it without pavement and a major road to cross - one the will be potentially much busier, due to the three hundred new homes. You may suggest that lights, a crossing patrol or a zebra crossing are the answer here but these will just add to the congestion and air pollution. Also what will become of the building of the current school - more houses?

There is considerable opposition to this development in the area and I think it would be shortsighted to develop on farmland without considering smaller areas of brownfield land that could be developed.

Thank you for taking the time to read my email and I hope you consider this development and choose to stop it from happening.

I am a full-time 2 decades Bosham resident and fully support the comments made on my behalf by the Bosham Asdociation. Namely I don't agree with change of use from Agricultural land; there is no waste water management plan and the local capacity is already stretched; increased danger of flooding due to already high water table (climate change too); loss to eco-systems & wildlife corridors - we see a lot of wildlife here moving between the Downs and the coast; threat to setting of AONB and National Park; unwanted merging of adjacent villages & loss of open spaces invetween; no justification for new primary school; no plan to cope with increased traffic on already congested road especially at junctions with A27 in Chichester & Emsworth.

1. Loss of grade one/two agricultural land. BREXIT?
2. No drainage/sewerage management plan.
3. It is inevitable that building on a flood plain will significantly increase flooding (on and offsite).
4. There would be considerable loss to eco-systems and wild life corridors, resulting in habitat fragmentation.
5. It would lose the strategic gap between the settlements of Fishbourne and Bosham.
6. Where is the evidence (in the Document) to justify the proposed two form entry primary school.
7. There would be significant increase in traffic and air pollution and no sustainability plan on an already overloaded system.

I would like to add my comments regarding the proposed developments proposed for Highgrove farm near Bosham:
1. I am particularly concerned about how to maintain an inclusive feel for this development - it just adds to the feeling of one long urbanisation between Chichester and Emsworth. No only is the strategic gap reduced but there seems to be little provision made for cyclist or walking links to the main village. This means the reliance on cars and even more traffic to the village.
2. There is no point in having a lovely harbour with no wildlife corridors into the South Downs - there seems to be no cohesive approach to development.
3. Why is there no consideration of sites closer to the village (for instance behind the bed shop) - where a resident could feel part of the community.
4. As above the idea of putting a school so far out will only add yet more traffic and the loss of the feeling of going to a village school.
5. All development should stop until the Chichester by-pass issue is resolved - every road is now a rat run trying to avoid direct routes that are so busy and jammed.
6. Even if all the above is not a reason to reject the plan - what can be done to ensure that the development includes giving something to the community - I am thinking - nice paths to walk on through planted wildlife corridors. Wouldn't it be great to be able to walk on what was essentially farm land (with minimum birdlife - as is common these days) and have sparrows nesting and starling roosts. How about a village pond? Or even a play park for kids? All developments need to be environmentally improved - houses which include bat roosts and opportunities for nesting/roosting birds . hedgehog friendly gardens - something good to add!
7. I have heard worries about sewerage (I would hope that this is a technical issue which the water companies can deal with) and regarding flooding - this will only be an issue if the houses are too many - the gardens too small and the shared space not generous enough (ie paved road and nothing else). Please try to make this a development to be proud of!

The decision to allocate 50 houses was contentious, to expand this to 250 is illogical.
Every planning application in the Bosham/Chichester Harbour area is quite rightly subject to great scrutiny: The population wish to preserve or improve this special area. This doesn't mean no development but it does mean planned and sensitive development.
This development is not sensitive:
1. It is part of lazy planning that allows infill and ribbon development. Citizens want defined communities. The development from Littlehampton to Brighton is an example which we do not want to emulate.
2. Chichester Harbour is already threatened by sewage discharges. Is there MANDATED provision to stop this and increase the capacity of the sewage system?
3. The whole area is sensitive to flooding. Rising sea levels are a threat. How will this housing cope with a rising sea level and water table?
4. How will the overcrowded and already inadequate transport system cope with the extra traffic?
5. How will it cope without further huge environmental disruption and damage?

No mitigation addressed for the increased transport issues on the A27/A259 that a minimum of 250 dwellings would bring. Unless this is adequately addressed in future iterations of the plan , I will raise this with the inspector at the appropriate time.

This land is at or below the 5 meter contour and therefore at risk from effects of sea level rises as a consequence of global climate change. It is therefore unsuitable for development as housing and schools

I write to object to any increased housing over and above the current approval of 50 houses on the Highgrove site.

The approved allocation of 50 houses was taken in spite of the full knowledge of the objections from the residents of Bosham. These objections still stand - The A259 cannot cope at the moment let alone the A27 which has no sensible solution to the horrendous traffic jams around Chichester. The increase of an additional 250 houses at Highgrove will without doubt produce an urban extension of suburban Chichester leading westward to Havant and Portsmouth.

Objecting to the use of this land for housing because:
1. loss of agricultural land that could be used to supply locally grown food
2. Coalescence of Bosham into Fishbourne and loss of distinction between the two
2. Danger of increased flooding due to existing high water table and drainage issues in the surrounding area
3. Environmental impacts, on wildlife, and the large increase of traffic on A259 and local roads
4. Impact on the AONB and the setting of the National Park, both the views towards and from it.
5. Lack of suitable local infrastructure

I write this email to object to the planning application by David Wilson Homes on Highgrove Farm, Broadbridge, Bosham on the following grounds:

1) The proposed development would go against the stated wishes of the people of Bosham as documented in the consultation documents for the draft Neighbourhood Plan, in which Highgrove Farm was viewed as the least desirable site for development in the parish. To build here therefore, would be a negation of local democracy and an insult to a population that worked hard to select appropriate locations for house-building within the parish.

2) There remain within the parish, brownfield sites which should be prioritised for any necessary house building, before any greenfield sites (especially grades 1 and 2 agricultural land) are considered. Examples being the disused, decaying Burnes shipyard and Bullock Barns just off the A259. Permitting the current application would be a clear, unambiguous statement that Chichester District Council prioritises the desire of developers to maximise profits (by minimising the cost of construction incurred in having to clear brownfield sites), above the needs of local communities and the environment.

3) Building on Highgrove would lead to a diminution of the strategic gap betwween Bosham and Fishbourne an outcome opposed by the residents of both communities and indeed an outcome opposed by Chichester District Council itself as can be seen in the Bosham Village Design Statement adopted by the CDC in December 2011. ("This designation envelops both the Broadbridge settlement policy area (SPA) and the Bosham SPA to its north and east and is intended to prevent the coalescence of existing settlements into a continuous urban sprawl".)

4) The number of dwellings proposed and the nature of their design (town houses in a single estate) are not suitable for a rural development, especially one that is sited between a national park to the north and an AONB to the south, especially when the options for more suitable developments exist in the parish.

I sincerely hope that Chichester District Council will not approve this completely unsuitable application on a site rejected by the people of Bosham. Bosham has shown itself willing to allocate land for the building of new homes within the parish. The location and nature of new construction should always take place with the consent and support of the people who live and love the communities of which they are part, and any level of government which claims to be 'representative' should not ride roughshod over the needs and opinion of those communities as Chichester District Council would certainly be doing if this application is approved.

These comments reference two important engineering aspects are directed towards the Planning Inspector and concern the acknowledged high water table across the selected land and the potential additional provision for effluent / grey water treatment.
1. Recent studies have concluded that static pumps will be required to deal with excess surface water. Calculations are now required to verify potential volumes - any developer should be required to build this provision into his/her bid.
2. The hydraulics calculations for carrying effluent / grey water from 50 + 250 = 300 new houses need to be undertaken by an independent specialist consultant who can advise upon the engineering requirement and recommend a potential solution with headline costs. In my opinion, it is unsafe for CDC to simply 'take Southern Water's word for it.' It will be money well spent to enlist independent verification of their statement at this early stage. The last thing the residents of Bosham and other shore side villages wish to see is untreated effluent in Chichester Harbour.

I wish to object, in the strongest possible terms to the proposal of 250+50 new homes for Highgrove Farm Bosham.

My main objection is the state , already of the ROADS! As somebody that commutes eastwards daily for work, the MISERY, and frankly, shame, which is the A27 around Chichester,and the gridlock on planning for it's re-routing cannot be stated strongly enough.

If residents attempt to go the back routes, to avoid the traffic chaos, via the Funtington Road on cold dark winter nights , they risk falling down potholes in the poorly maintained minor roads.

It is cynical of the developers, Wilson Homes to have mooted , originally, 50 houses. Everybody was well aware that this would never be restricted to 50 homes. If the field beyond Highgrove is developed, it is only a matter of time , of course, before the field on the Brooks lane side is developed --500 more?

Add to this the increased traffic associated with the newly built Hospice and we will have depressingly high levels of congestion on the roads (259 and A27) and no provision for it's alleviation; as has been excellently illustrated by the hubris associated with re-routing the A27 through Chichester.