Policy AL7: Highgrove Farm, Bosham

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.

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.

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.

REP1: OBJECTION TO CRITERION 5 OF AL7 - INCONSISTENT POLICY WORDING

Bosham Parish Council is of the view that there is an inconsistency between the policies and their supporting text concerning the treatment of the landscape surrounding Fishbourne and that surrounding Bosham, particularly that part of the village north of the A259. Consequently the policy wording is not effective and will not deliver the most appropriate strategy for the site.

Policy AL10 allocates land at Chidham and Hambrook for 500 dwellings. Policy AL9 allocates land at Fishbourne for 250 dwellings. Criterion 5 of each of these policies considers issues of landscape impact when it states:

"Detailed consideration of the impact of development on the surrounding landscape,
including the South Downs National Park and Chichester Harbour AONB and their
settings. Development should be designed to protect long-distance views to the South
Downs National Park;

It is logical to include the same criterion 5 in each of these policies since both settlements are close to the South Downs National Park and the AONB. Bosham happens to occupy a location between Fishbourne and Chidham/Hambrook settlements. Bosham is similarly set between the South Downs National Park and the AONB. It is therefore somewhat surprising that criterion 5 of Policy AL7 relating to Bosham states:

"Provision of landscaping and screening to minimise the impact of development on
Bosham, and the setting of the Chichester Harbour AONB and South Downs National
Park, including views to and from the wider and surrounding area;"

The Parish Council's concern is that the wording of this criterion implies less stringent assessment and appraisal of the landscape setting related to the AL7 allocation than is the case with Policy AL9 and AL10. The criterion merely states "provision of." This is despite Bosham having an arguably more sensitive relationship to the Chichester Harbour area. The consequence of this, is that there is no policy requirement for a "detailed consideration of the impact of development on the surrounding landscape." This means that landscape proposals could be devised which merely introduce buffer planting without actually assessing what depth of planting should take place and the type of plants which are suitable. The criterion 5 wording of AL7 also does not include any requirement for proposals to be "designed to protect long-distance views to the South Downs National Park." This implies that the landscaping and design associated with the Highgrove site (AL7) will be judged against a lower threshold than with the AL9 and AL10 housing allocations. The policy is therefore not effective and neither would it deliver an appropriate design strategy for the site

It is proposed that to ensure that the plan is consistent, sound and recognises the same sensitivity as a result of the proximity of the Chichester Harbour AONB, criterion 5 be amended to state:

"Detailed consideration of the impact of development on the surrounding landscape,
including the South Downs National Park and Chichester Harbour AONB and their
settings. Development should be designed to protect long-distance views to the South
Downs National Park and Chichester Harbour. Provision of landscaping and screening to minimise the impact of development on Bosham, and the setting of the Chichester Harbour AONB and South Downs National Park, including views to and from the wider and surrounding area shall form an integral part of any application;


REP2: OBJECTION TO PARAGRAPH 6.56

This paragraph is preamble to Policy AL7 and sets out the specific issues that need to be taken into consideration when planning the development of the allocated site. In paragraph 6.65 the preamble states that:

"Protecting the separate distinct identity of Fishbourne in relationship to surrounding settlements, including Chichester City;"

This is logical since the development of 250 homes on land around this settlement could result in a design which is out of keeping with the wider character of the area. In addition, Fishbourne is close to Bosham and consideration of design needs to recognise and plan for that proximity.

In the case of Bosham, no issue relating to 'distinct identity' is raised in the supporting text. This is considered to be unsound because the settlement of Bosham has a particular distinct identity and the Highgrove allocation is on the eastern side of the village and would draw development closer to Fishbourne. It cannot be the case that Fishbourne has supporting text which seeks to protect its special identity but Bosham, with a large allocation does not. This would not deliver an effective plan due to the inconsistency and neither would it deliver an appropriate growth strategy for Bosham.

The settlement or village of Bosham is comprised of two built up areas. A neighbourhood called Broadbridge to the north of the A259 and an area located around the historic harbour. Whilst physically separate, they each form part of 'the village' and are interrelated in terms of activity and service offer. The allocation of 250 new homes at Highgrove is a significant number when compared to the existing number of dwellings in Bosham. Consequently, it is important that the identity of Bosham is carefully considered when designs are drawn up. The NPPF continues to advise that design should be of a high quality and certainly this is an important issue when setting the policy context for AL7.

It is recommended that a new bullet point be added to paragraph 5.56 which states:

" Protecting the separate distinct identity of Bosham in relationship to surrounding settlements, including Fishbourne;"


REP3: OBJECTION TO CRITERION 3 OF AL7

Policies AL9 and AL10 both include criterion 3 which state:

"Provision of suitable means of access to the site(s) and securing necessary off-site
Improvements (including highways) to promote sustainable transport options;"

However, criterion 3 of AL7 states:

"Provision of a satisfactory means of access from the A259;"

Bosham is a village with two centres severed by the A259. For reasons of social cohesion and to ensure that the new development has satisfactory pedestrian links with the facilities to the south of the A259, including the small employment areas and community facilities, it is essential that some form of pedestrian crossing and other pedestrian infrastructure is installed to support the new development. At the moment the strategy being promoted by the Council cuts against social cohesion and is clearly an inappropriate strategy compared with the alternative which is to require a crossing. Criterion 3 should therefore be more appropriately worded to allow these issues to be delivered. It is recommended that criterion 3 should be redrafted to state:

Provision of primary access from the A259, consideration of an emergency access and pedestrian access to the western side of the site and securing necessary off-site improvements (including highways) to promote sustainable transport options. This would include an appropriately located pedestrian crossing and a footpath link;


REP4: OBJECTION TO POLICY AL7

Bosham Parish Council is concerned that the policy fails to give appropriate guidance on matters of environmental importance and this is contrary to the NPPF. In both policy AL9 and AL10, a criterion states:

"Demonstration that development would not have an adverse impact on the nature conservation interest of identified sites and habitats;"

However, in the case of the Highgrove allocation AL7 environmental assessments have already taken place in connection with application 17/03148/FUL and the site allocations document which allocates a smaller part of Highgrove Farm for 50 dwelling units. This research has identified a population of slow worms on the site. It is also the case that Brent Geese, a species protected under Law, have used the open fields for landing. Given that there is ecology of acknowledged importance, it is considered that to be compliant with NPPF a criterion should be added which protects the habitat and ecology of the area. This would comply with NPPF and be consistent with the way other sites have been treated. The new criterion should state:

"Demonstration that development would not have an adverse impact on the nature conservation interest of identified sites and habitats;"


REP5: OBJECTION TO POLICY AL7

Policy AL9 and AL10 include a criterion which states:

"Provide mitigation to ensure the protection of the SPA, SAC and Ramsar site at Chichester Harbour as a result of water quality issues relating to runoff into a designated site, and loss of functionally linked supporting habitat;"

Policy AL7 does not include this criterion yet the allocation is as close to the protected Harbour and water courses that flow into it as the sites promoted at AL9 and AL10. In the case of Highgrove Farm there is a drainage ditch running along the southwest corner which would need effective management to ensure hydro carbon pollutants do not enter the catchment. It is therefore inconsistent and contrary to NPPF that AL7 does not have the same criterion. A new criterion should be included which states:

"Provide mitigation to ensure the protection of the SPA, SAC and Ramsar site at Chichester Harbour as a result of water quality issues relating to runoff into a designated site, and loss of functionally linked supporting habitat;"


REP6: OBJECTION TO POLICY AL7

A consultation exercise carried out by Bosham Parish Council in December 2018 revealed widespread local concern, and photographic evidence, concerning the ability of the site to drain safely and effectively. The drainage ditch to the southwest corner regularly floods as a result of it being of insufficient capacity and poor management. There is no robust or credible evidence to suggest that this issue should not be specifically identified as a criterion in Policy AL7.

The approved development of 50 houses at Highgrove (17/03148/FUL) has a significant area within the development site which is required for storm surface water balancing ponds/SuDS /underground storm water crates within the open space area. These areas occupied some 0.5ha of the 2.2ha allocated. For a 250 house scheme the requirements would be significantly higher. Any area required for drainage should sit outside of that required for open space, ecological mitigation and other community infrastructure.

It is therefore considered that some on site Suds or attenuation pond will be necessary as part of the scheme. The area necessary would need to be established through studies and would need to be independent of the overall open space requirement of the site. AL7 should link to Policy DM18 and the requirements contained in that policy.

Criterion 11 of AL9 also makes reference to securing sufficient capacity within the relevant Waste Water Treatment Works. Paragraph 5.70 states that during the life of the Plan "measures will need to be put in place at each WwTW... in order to tackle current and future water quality issues to support future housing growth." Clearly some form of criterion is essential to ensure that commencement of the development cannot occur until such works are completed. The recently completed Hospice to the south of the draft allocation within the AONB required additional foul sewer capacity upgrades in order to be occupied. In view of this evidence and the approach taken with Policy AL9, Policy AL7 should include a criterion requiring offsite infrastructure improvements to address foul sewage.


REP7: OBJECTION TO POLICY DM18 FLOOD RISK AND WATER MANAGEMENT

In view of Bosham Parish Council's representations relating to surface water flooding at AL7, it is considered that this policy should include an additional criterion making it clear that development proposals will need to outline a robust strategy for addressing surface water drainage and flood risk.


REP 8 - OBJECTION TO POLICY S31 AND APPENDIX E RELATING TO WASTEWATER MONITORING

As a result of Bosham Parish Council's representations to AL7, it is considered that S31 should be amended to include an additional criterion which makes it clear that planning permission will only be granted where enhancements to necessary foul water infrastructure occur prior to the commencement of development. On site schemes which discharge into nearby water courses should not be deemed acceptable, particularly those within proximity of the Chichester Harbour AONB. Appendix E should include a requirement that the District Council discusses Southern Water's current 5 year investment programme and only allow commencement of development when suitable infrastructure enhancements have taken place.



REP9 - OBJECTION TO POLICY DM34 - OPEN SPACE

The revised Open Space, Sport and Recreation Study including Indoor Sports Facilities and Playing Pitch 2018 has reduced the requirement for open space by almost a third across the whole district. There is no evidence and justification for this reduction. The District wide reduction in open space requirements may penalise those Parishes where an existing shortfall exists. It is not an appropriate strategy compared with the previous standards for open space. It is not based on any credible evidence to justify a change.

The information in Table 14 of the Chichester open Space Study (Main Report) September 2018 shows that Bosham has the third highest shortfall in the parishes in the District of Parks and Recreation Grounds combined. The extract of the table below shows that in every category Bosham has a significant deficiency.



It is considered that the new standards should not form the basis for the open space requirements at Highgrove Farm and that the previous standards should be retained to address the unique circumstances of Bosham.


REP 10 - OBJECTION TO LANDSCAPE CAPACITY POLICY DM28 NATURAL ENVIRONMENT AND DM19 CHAONB

The draft Landscape Capacity Study (published by Terra Firma, November 2018) concludes that The AL7 draft site allocation has only medium/ low capacity for landscape change and states "Great care would need to be taken to avoid any landscape or visual harm ensuring the separate identities of the settlements are protected and considering valued views".

At the present time the Landscape Capacity Study is in draft form only and its conclusions are currently based on a summer assessment. It would be the case that the same assessment during the winter months would yield a greater degree of landscape sensitivity. The evidence base, as currently published, is not robust and the AL7 policy wording "development of a minimum of 250 dwellings..." is not based on robust and credible evidence. The landscape sensitivity suggests that the 250 dwelling number should be a maximum cap and that the policy should be re-worded to say "up to 250 dwellings..."


REP 11 - OBJECTION TO AL7 - DENSITY AND NUMER

Bosham Parish Council has concerns regarding the policy wording which sets a minimum threshold for the number of dwellings "minimum of 250 dwellings".
Concern about the numbers of dwelling and density proposed taking account of the issues raised namely the need for onsite SUDS and drainage, a 2 form entry school, suitable landscaping and mitigation, and suitable ecological mitigation. Any development must also have regard to the character of the area and a density which reflects that of the surrounding area. There is no credible evidence to suggest that more than 250 dwellings can be achieved when all these considerations are taken into account. It is noted that Draft Policy DM3 explains at criterion 'b' that locations adjacent to sensitive locations may justify lower densities.

The policy should be reworded to ensure the 250 dwelling amount is an upper threshold.

OTHER

We support the creation of an integrated and sustainable transport plan for the District, or at the very least for the area west of Chichester. This plan should draw upon the ongoing work of the ChEmRoute group's investigations and proposals for the National Cycle Route 2 (NCN2) and be co-ordinated with WSCC with the goal of introducing high quality and separated cycle links between the villages along the A259 and Chichester. The route or routes may include a fast but safe link along the A259 aimed primarily at cyclists including commuters as well as a slower, more meandering and leisurely route north of the A259 (and perhaps the railway). To make these cycle routes sustainable they will need connections and feeder routes from new and existing developments. In developing a more ambitious and safer scheme for cyclists care must also be taken to ensure that pedestrian routes are protected too. The vision must be to ensure that both cycle and pedestrian traffic is encouraged and supported and not brought into competition with each other.

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.

See attachment

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.

We are writing concerning the proposal to allocate land at Highgrove Farm for 250 houses (and, possibly, a school).

It is a huge urban extension which distorts the whole layout of the village. It cuts into the strategic gap between Bosham and Fishbourne and severely degrades the open farmland landscape.

While we acknowledge that land south of the A259 lies within the AONB, there is land there that is within the existing village which would be much more suitable for housing.

We are strongly opposed to Policy AL7 and hope that it will be reconsidered.

As a resident of Bosham I oppose this plan . There is already a proposal to build 50 houses on this site.

The proposal to build 250 houses or more would change Bosham from a quiet historic village to a small town it would remove agricultural land, a habitat for wildlife, destroy views of the Downs and cause huge increase in traffic and noise. The Gp surgery would be overwhelmed as would the local sewage works causing further pollution in Chichester harbour.

The village submitted a neighbourhood plan the result of a lot of hard work by many villagers and a vote by the village. This Plan has been totally ignored by CDC! I wonder why we bothered!

The plan for 250 houses or more will destroy Bosham as a beautiful quiet village set in an AONB.

Highgrove Farm Development. 17/03148/FUL
I am totally against the building of either 50 or 250 houses not only for the various problems with drainage, numbers of people etc. but the main one is the fact that this area is in the Strategic Gap.

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I write to object to any further housing devlopment in the Bosham locality. I do not agree with the exisiting approval of 50 houses on the Highgrove site, but list below my objections to any additional houses currently being considered on the Highgrove site.

1. The additional application is being made in the full knowledge of local significant dismay of the original approval of 50 houses.
2. Additional houses on that site is yet another step towards joining the existing villages of Bosham with Fishbourne and Chichester District.
3. This will fundamentally change the character of the area adjacent to the A259 into a suburban landscape.
4. Additional urban facilities will then be required such as medical and social facilities - further adding to the urbanisation.
5. The area in question has poor drainage and is prone to flooding, due to the nature of the agricultural land adjacent to the A259. Additional housing will increase the flooding risk with the area in question requiring many new trees to assist in this matter.

Your consideration of these concerns is requested.

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