Policy AL8: East Wittering Parish

I strongly object to any more large developments in this area as we have already delivered many hundreds of new homes and there are still more either under construction or for which planning approval has been given.
Traffic & emergency services are struglling to cope now. The sewage, water, education and medical infrastructures are already buckling. Enough is enough.

Also map B1 in Appendix B is completely wrong. It shows East Wittering as a "Non Rural/Urban" area. By any measure this is an inaccurate description. I would argue strongly that by far the biggest use of the area is as Agricultural land; most of it Grade B. Even Natural England classify it as "Agricultural - Very Good" I have attached a document in support of this argument and a quick visual inspection by the Inspector when he/she carries out the review will confirm this.

The peninsula cannot sustain any more housing. The only road in and out cannot cope as it is during busy periods and grinds to a total halt in summer. There are empty shops, closed banks and post office. You have to wait 3 weeks for a doctors appointment as it is. Crime has increased, police declined.

East Wittering/Bracklesham is a relatively inaccessible small coastal settlement with no secondary or higher education provision, few employment opportunities and no access to the railway network. Most importantly it has only one unreliable road connecting it to any settlement offering these important facilities.The A286 linking East Wittering to Chichester is frequently gridlocked throughout the year to the extent that St Richards hospital recommends its consultants not live in the village due to the unreliability of residents reaching the hospital within 30 minutes.Its small-scale low-key seaside village character is an inherent and important aspect of its attraction to tourists.

Needs explicitly mention cycle provision both linking Medmerry with East Wittering and links to Salterns Way. In this way a suitable extension can be made to NCN 88 which can then cover the whole of the Manhood Peninsular.

Please find below the comments from East Wittering and Bracklesham Parish Council to the Local Plan Review consultation.The council submitted an extensive response to the Local Plan consultation in 2014 (appendix 1, attached), expressing our concerns in a number of critical areas;

* Traffic impacts on the local road network
* Lack of capacity at the A27 Stockbridge Road junction
* Air quality impacts for Donnington residents
* Impact on the rural nature of the area
* Damage to the unique character of the village, which would adversely impact the tourism sector
* Lack of capacity in local primary schools
* Lack of secondary school and further education facilities
* Limited capacity within the sewerage and foul water network

We still feel that all of these objections remain valid and unaddressed. With the recent announcement that improvements to the A27 have been scrapped for the foreseeable future, we feel that they are even more pertinent.

In addition, we have significant concerns about the minimum indicative housing numbers allocated against our Parish. According to the 2011 census, there were 2,255 households in East Wittering & Bracklesham. Since that time, we have already seen a number of new developments completed, adding over 200 new properties to the village. An additional 350 homes will mean that we have experienced population growth of over 25% within a time period of less than 10-15 years. Such a large influx of people without corresponding infrastructure improvements and dedicated community development support risks the fundamental character, nature and cohesion of the community.

We also question the methodology used when assessing sustainable locations for strategic development. East Wittering & Bracklesham is designated as a settlement hub, largely for historic reasons that no longer apply. We no longer have any banks (having previously had four), all of our major local employers (including Richardsons Holiday Park and Credowan Engineering) have closed and there are now no significant local employers within the Parish. We have one medical centre, which is shared with West Wittering residents, and one primary school, as do the neighbouring villages of West Wittering and Birdham. The village centre incorporates the Parish boundary with West Wittering, splitting retail businesses across the two parishes. We contend that we are now no more than a large service village, with no greater or lesser advantages than other adjacent villages within the area.

We think that on this basis, the presumption that East Wittering and Bracklesham is the most sustainable location on the South-West Manhood is unsound. There are potential viable developments sites within the Southern Manhood that should be considered ahead of greenfield development within East Wittering & Bracklesham. The site of the former Earnley Concourse has been falling into ever greater dereliction and disrepair for several years and provides a viable brownfield development site, which could contribute significant housing numbers within the local area. There are also numerous green fields to the West of Church Road in West Wittering which have currently not been included within the HELAA, which could be suitable for additional development.

Whilst we appreciate that the District Council have to find space for new housing within very constrained circumstances, we do not support the current approach, which will see large-scale development fundamentally changing the nature and character of our community, when there is scope to mitigate the impact by more equally sharing the load across all communities. If there was a sustained focus on incorporating affordable, secure-tenure rental property within a wider range of developments it would provide the added benefit of increasing the vitality and sustainability all villages on the Manhood by supplying essential housing for local residents and young people who are increasingly forced out of their communities by a lack of affordable housing.

Resident of West Wittering

350 dwellings are too many for this location because of poor road access into Chichester.

I appreciate that the housing numbers proposed in the LPR have been imposed by central government, but for CDC to refer to the housing target numbers as minimums appears seriously flawed. This will surely encourage developers to submit plans for greater numbers than might otherwise be the case. It also makes it very difficult for local communities to resist further development when the "minimum" figure has been reached. The housing numbers imposed are already greater than the district can reasonably bear, so for CDC to set minimum targets is doing a great disservice on all counts, and particularly on environmental grounds.

Chichester district already suffers from insufficient road capacity and the plans for the A27 junctions and link road will not solve the problem. The junction changes will not solve the lack of road capacity for through and local traffic, and restricting right-hand turning at junctions will make local journeys more difficult. The proposed AL6 link road would direct more traffic off the A27 on to the A286, one of the most congested roads in the district, providing access to some of the most popular tourism destinations on the Manhood Peninsula. For this reason alone it should be resisted.

I am concerned that East Wittering/Bracklesham have been classed as a "settlement hub". The definition of a settlement hub should include good access to the main road network, the rail network, employment and secondary and higher education facilities. These villages do not have easy access to these services, being situated in a "cul-de-sac", on the congested A286. They are essentially rural, seaside communities which rely heavily on tourism for their economy and it is their rural nature which attracts so many visitors. The 350 minimum homes proposed for these two villages would have severe implications on all aspects of the local infrastructure, particularly the roads.

Living off Bell Lane in Somerley, I would like to draw your attention to the findings of the Peter Brett Transport Study for the LPR. It states that the forecast for the increase in road noise arising from a further 350 homes in East Wittering/Bracklesham along the length of Bracklesham Lane, the B2198, is "major". Bracklesham Lane leads into Bell Lane as it passes through the Somerley Conservation Area and it is vital that mitigation measures should be taken to reduce the effects of the additional traffic noise, preferably in the form of a speed limit reduction to 30mph. The accident rate on this road is already higher than average, including fatalities.

Selsey, another "settlement hub", has been badly affected by excessive suburban development in recent years with no improvement to its local infrastructure. The further extensive housing numbers proposed for this fishing and seaside village risk undermining its attraction to tourists. It is important that development of these seaside communities is carefully designed and limited in numbers to prevent over-suburbanisation. It should also be recognised that the geography of the peninsula means that access to and from the coast will always be restricted and subject to severe congestion. Additional housing on the Manhood Peninsula will only worsen this unresolvable situation and must be considered with caution to maintain its attractiveness to tourists who contribute so greatly to the economy of the Chichester district.

The Manhood Peninsula is also one of the last remaining rural hinterlands on the south coast plain. It contains several internationally designated habitat sites which are among the most important wildlife areas in the Chichester district. CDC should consider strengthening the ICZM to recognise the international importance of the peninsula, further safeguarding its environment and associated green tourism. The provision of wildlife corridors are probably more important here than anywhere else in the district. In addition, the AL6 proposed link road and commercial development would be adjacent to internationally designated habitat sites, cross two flood zones, and impair significant views of the cathedral and the Downs, contrary to CDC's ICZM policy. This proposed road appears to fail on all counts.

In conclusion, therefore, I would ask CDC to abandon proposals for the AL6 link road and junction changes on the A27, which are a waste of money, and instead urge the government to invest in a long-term, sustainable solution for the A27 so that the district is more able to accommodate the increased housing numbers being imposed on it. I would also like to see the minimum housing target numbers changed to maximum and remove East Wittering/Bracklesham as a settlement hub for the reasons set out above.

There is mention of pressures on traffic in the summer months and at peak time but no mention of how the plan is going to mitigate this. Only going to be made worse by the increase in housing by at least 350 dwellings.Unless this is adequately addressed in future iterations of the plan, i will raise this with the examiner at the appropriate time.

There are several reasons why this area should not be developed. 1. The land is at or below the 5 meter contour and therefore at risk of flooding as a result of sea level rise as a consequence of global climate change. 2. The area has already had larger areas of new housing which require time to be integrated into the community. 3. The roads on the Manhood peninsular are already over loaded and access to the rest of the world via the A27 is poor.

East Wittering/Bracklesham is a relatively inaccessible small coastal settlement with no secondary or higher education provision, few employment opportunities and no access to the railway network. It is positioned at the bottom of what can only be described as a cul-de-sac, squeezed by the sea to the south and the A27 to the north.

Any accessibility to access important facilities - senior schools, sports centres, and places of employment is via the A286 to the A27. This one road is unreliable, it is gridlocked throughout the high tourism season. Add to that, when there is an accident and subsequent road closures, households only diversionary routes are country lanes not built for high traffic volumes- an example being the serious and distressing accident on Saturday 2/2/2019 at around 11am. There were two further subsequent accidents on the country lanes and no household could get to or from East Witterings without queuing in heavy traffic. Please see attachment google map taken at 14:00 on 2/2/2019.

This area contributes to the £141m annual tourism revenue from the Manhood Peninsula by attracting holiday makers and the ever increasing stay vacation economy with Its small-scale low-key seaside village character and being in the close vicinity of protected local natural wildlife areas and the blue flag beach.

Many of the new developments are promoted by developers to Londoners for second homes. What is needed is affordable housing for the local community out priced from the local housing market. Merely building homes is not the answer. A focus has to be on affordable housing for the local community.

Common sense dictates that building more homes on a cul-de-sac, on land which is close to sea level and considering the Environment Agency stating that climate change is causing sea levels to rise, with one escape route via the congested A286; this is a humanitarian disaster just waiting to happen.

Any further housing developments within this Plan area are ridiculous. However if CDC's hands are fully tied by Westminster as the District's Leader has stated alongside his Cabinet Member for Planning, replace 'a minimum of 350 dwellings' with a 'maximum of 350 dwellings' and ensure that any development is in keeping with the seaside village character on which the area's economy depends

Policy AL8 in Para 7 should include the Chichester Harbour AONB and its designations, with Pagham and Medmerry
(It is mentioned twice in the preceding Para 6.58)

I wish to object to the plan for a minimum of 350 additional dwellings in East Wittering Parish.
I understand the need for additional housing provision. However there are a number of issues with this proposal:
1. The chronic traffic congestion on the peninsula in the summer months.
The proposed Stockbridge link road from the Fishbourne roundabout on the A27 to the A286 Birdham Road (policy AL6) will do nothing to solve the traffic congestion on the peninsula, during the rush hours throughout the year, especially in the mornings when traffic queues back up along the A286 to get onto the A27, and in the summer when a large volume of vehicles carrying day visitors to and from West Wittering beach leads to traffic queues along the length of the A286. The link road will only shift the traffic congestion on the peninsula, not help to reduce it or manage it better.

2. The lack of employment opportunities within the immediate area necessitating residents to travel into Chichester and beyond for work, adding to the traffic congestion.
There are very few employment opportunities in East Wittering and Bracklesham. This means that additional housing will lead to more vehicle journeys up to the A27 as new residents travel to work outside the area.

3. The lack of facilities in Bracklesham and the loss of facilities in East Wittering village.
Bracklesham is currently without a Post Office. It has one general store. There is no pharmacy or GP surgery.
East Wittering has now lost all its bank branches, together with the cashpoints they provided. There is only one cashpoint (outside Tesco) that is available 24/7. For banking, local residents, visitors and businesses either have to use the Post Office, or travel into Chichester. In a survey of local issues that I conducted in East Wittering and Bracklesham for the Liberal Democrats (but
please note that I am making this submission in my capacity as a private individual) at the end of 2018 (with close to 2000 copies distributed), the top concern was the closure of the banks in East Wittering and the lack of enough cashpoints. We have not yet had a summer season since the last bank (Lloyds) closed. The summer sees a huge influx of visitors staying in the caravan and camping sites and holiday rental properties and second homes in the area. There is still a high demand for cash in the local economy.
As residents have to travel to Chichester to go to their bank, it is likely they will do their shopping there as well or online instead of in East Wittering village.
More senior residents may not be able to or want to do online banking or shopping and will be disadvantaged if local facilities decline further due to this move to use facilities in Chichester instead. There are no practical ideas in the plan to halt this decline in local facilities. This should be an integral part of any plan to put in additional housing in the area.

4.The scarcity of public transport in the evenings and the cost.
The scarcity of buses in the evening and at weekends already leads to more vehicle journeys. It is also isolating for local residents who do not have cars. The cost of bus transport for those who do not have free bus passes is more than the cost of driving into Chichester and parking so this only encourages more car journeys.

Item 7 refers to adverse effect on Pagham Harbour SPA and Ramsar. There is no mention of Chichester Harbour AONB with SPA. SAC, SSSI and Ramsar protection

The British Horse Society (BHS) is the UK's largest equine charity and equestrian membership organisation and the governing body for recreational riding. Its charitable objects include the promotion of equestrian safety, particularly on roads, and equestrian access to bridleways and other off-road multi-use routes for the public benefit. On behalf of The Society I would like to make the following comments:

Chichester Local Plan Review 2016-2035 Preferred Approach

The Society's priority when commenting on this document is to try and ensure that the policies and wording in the text include commitments to support and protect vulnerable road user groups, including equestrians (West Sussex Transport Plan, page 32, para 1.4.5), from the dangers they face on local roads due to the inevitable increase in traffic on these roads brought about by planned housing development.

The Plan area covered is home to a large number of equestrians, who bring significant economic benefits, especially to rural communities, but unless they have access to a safe network of bridleways, byways, and other off-road informal recreational routes which they can use daily, the dangers to horse riders will increase, and the industry will struggle to survive.

Policy S18: Integrated Coastal Zone Management for the Manhood Peninsula (page 68)
Equestrians on the Manhood Peninsula feel increasingly unsafe on the local roads they have always used, where the speed and volume of vehicles has grown considerably, and will do so even more as a result of the proposed housing development. There are now more than 500 horses kept in the area (Manhood Riding Club count) in private stables, livery yards, and the local Riding School (at which the Chichester Group of Riding for the Disabled is based).

We would, therefore, absolutely support objective 5 of this Policy "Improve infrastructure to support sustainable modes of transport, especially cycle ways, bridleways and footpaths, including the National Coastal Footpath ".

We would suggest the best way to do this is to ensure that at least one multi-use route (bridleway) is provided through, or around the fringe of developments, which can also serve as a green corridor for leisure and recreation and, and benefit health and well-being, wildlife and biodiversity. These routes can form the basis of a safe non-motorised user (NMU) network and link with existing public rights of way (prow) where possible.

Policy S20: Design (page 74)
Bullet point 5 - wording is supported "incorporates and/or links to high quality Green Infrastructure and landscaping to enhance biodiversity and meet recreational needs, including public rights of way."
However, it is important as mentioned above that this incudes 'multi-use' public rights of way for the benefit of all.

Transport Infrastructure
Para 5.15 - very good to see "bridleways" included in this para.
Para 5.16 - The wording "There is an extensive public rights of way network across the plan area... is misleading. The wording implies that this prow network is available to all users, whereas on the Coastal Plain the prow network consists almost entirely of footpaths, which are not available for use by cyclists and equestrians. Upgrading appropriate/suitable prow to bridleways would contribute to the West Sussex Transport Plan (2011-2026) aim of "improving safety for all road users", mentioned in para 5.18.

Policy S23: Transport and Accessibility
Bullet point 8 - Our view is that the objective "improving safety for all road users", should be included in the actual Policy wording, not just in the accompanying text. However, it is good to see 'public rights of way' included, which need to be multi-use bringing safety benefits for all vulnerable road users.

Countryside and Countryside Gaps (page 82)
Para 5.37 - Absolutely agree the plan area's countryside is an important and diminishing resource, and the Council's aim to protect the countryside from the urbanising impacts of development is welcomed. For existing and future residents, the opportunity to enjoy 'informal recreation' (walking, cycling, horse riding) in the countryside is important for leisure, health, and well-being. The Council needs to take a very active role in ensuring that any development provides benefits, most likely in the way of safe, off-road multi-use routes(green links), and the mention of this in para 5.40 is welcomed.

Policy S32: Design Strategies for Strategic and Major Development Sites (page 92/93)
The references in Point b, "movement and access arrangements and Green Infrastructure provision", in Point e, "community leisure and recreation facilities as appropriate", and Point g, "contain a Green Infrastructure framework to ensure that public and private open space standards are met, relate well to each other and to existing areas and that the new spaces are safe, convenient, accessible and functional" are welcomed.
However, it is important that leisure and recreational routes, and new prow connect to the wider countryside for public benefit, and are not just contained within a development. There are many examples in the county where new routes have been created across or on the fringe of a development, which link to a wider network of recreational routes. The National Planning Policy Framework (NPPF), para 98, states "Planning policies and decisions should protect and enhance public rights of way and access, including taking opportunities to provide better facilities for users, for example by adding links to existing rights of way networks"

Policy AL1: Land West of Chichester (page 96)
Point 4 - whilst welcoming the provision of "open space and green infrastructure", this development provides an excellent opportunity to improve links to the wider countryside, in particular to BW 270 and Park Lane (which should be formally dedicated as a prow).
Point 10 - An "appropriate landscaping buffer", is also an excellent opportunity to provide a multi-use prow (bridleway), for the safety and enjoyment of all vulnerable road users, which as a 'green corridor, would also contribute to green infrastructure.
We would also request that when looking at 'key landscaping' of the Centurian Way (CW), the issue of upgrading this to a multi-user path where possible, to include equestrians is considered, so that they can also benefit from a safe and secure off-road environment. The CW is the only disused railway line in the county that is not available for use by all NMUs. The Worth Way and Downs Link are fully multi-use, and are highly valued and well used.

Policy AL2: Land at Shopwyke (Oving Parish) (page 99/100)
Point 9 - Despite repeated requests for the proposed bridge connection across the A27 at Coach Road (a route used by all NMUs until it was severed when the A27 was realigned) to also be made available for equestrian use, it would appear from the Policy wording that horse riders continue to be excluded, despite the large numbers of horses kept in the Oving area.

At present, riders have to box their horses over the A27 to access the safe network of bridleways and riding routes in the National Park, which is a situation contrary to the aims and objectives set out in this Plan. In order to gain maximum benefit from bridge infrastructure, it should be made available for as many users as possible.

Policies AL3 to AL14
All of these Policies require opportunities for the provision of green infrastructure with links to the wider countryside to be explored, and these are welcomed and supported. Creating new routes and links is especially important on the Coastal Plain, where an off-road multi-use path network would be of great benefit to all NMUs.

The West Sussex Rights of Way Management Plan 2018-2028 has Objectives (page 3) which include:
2. Improve path links to provide circular routes and links between communities.
3. Improve the PRoW network to create safe routes for both leisure and utility journeys, by minimising the need to use and cross busy roads.
4. Provide a PRoW network that enables appropriate access with minimal barriers for as many people as possible.
5. Promote countryside access to all sections of the community enabling people to confidently and responsibly use and enjoy the countryside.

The Plan also states in Improvement schemes (page 13), that "A starting point for new schemes will be to consider who could benefit from a new route, such as walkers, cyclists, horse riders and the disabled, and be as inclusive as possible, often the aim will be to achieve at least bridleway status.

Policy DM32 Green Infrastructure (page 199)
It is disappointing that the wording (on page 197/198) omits to mention that prow (footpaths, bridleways, byways), are defined by Natural England, and also recognised nationally, as multifunctional 'green corridors', and are therefore part of GI. Providing a multi-use (walker, cyclist, equestrian) prow or recreational route around the periphery would comply with NPPF, para 98, as mentioned above.
It is good to see public rights of way, and bridleways mentioned in Point 4 of the Policy, although the wording "do not lead to the dissection of the linear network" appears to be rather negative, much better to tell someone what they should do "The proposals protect, and contribute to the improvement of ........"

Policy DM34: Open Space, Sport and Recreation .... (page 204)
We support the aim to "seek to retain, enhance, improve access and increase the quantity and quality of....rights of way including improvement of links to them." This will be of great benefit to all NMUs.

Point 1 - Excellent to see requirement for development to contribute to new links to the existing rights of way network, which should be multi-use wherever possible.
Also support the aim to secure on-site provision secured via S106 agreements to provide (amongst other things) links to the existing rights of way network to meet any identified shortfalls in the local area, and would request in line with the WS RoW Management Plan that these links will be "as inclusive as possible, often the aim will be to achieve at least bridleway status."

Development in East Wittering/ Bracklesham should not be permitted to commence until a Highways England scheme for the relief of A27 has been implemented. The parameters of the Traffic Study are such that traffic congestion on A286 West Manhood has not been surveyed and growth factors not related to the approved and draft local plans are not considered. Tourism and traffic accidents cause complete logjam on local roads, isolating coastal communities. Long term improvements for access to Chichester and A27 is vital infrastructure for further development on West Manhood. Junction improvements are not the answer.

I wish to object to the number of houses identified in the Local Plan. Bracklesham and East Wittering have already had their quota. The houses that are being built now are not for local people, most of them are too expensive as there is no work in the area. These houses will be sold as second homes or holiday lets. The Sewerage Works cannot cope with all the extra dirty water and if we get heavy rainfall it spills out into the Harbour.
The A27 is still proving to be a problem and before long if we get more houses (most of whom will have at least two cars) the whole of the access to the A27 will grind to a halt. It already takes almost an hour at peak times to get from Bracklesham to the Chichester roundabout. Some of our local businesses have had to cancel clients in Chichester as it is not worth their while as they have to spend so much time getting there and back. The main road from Chichester to the Witterings and Bracklesham is to all intents and purposes a cul de sac.
The new proposed road from Fishbourne to Birdham will make the situation worse, especially when the West Wittering beach traffic arrives in the Summer. It will also take away a wildlife area.
The Doctors Surgery is already overloaded as it is the only one for a very large area and it is almost impossible to get an appointment, especially when we get the visitors in the Summer.
The three local schools are already full and if all these houses are built, presumably as they are mainly large houses they will have more children in them.
If all the spare land is used up on housing, what happens if we get a situation where we need to grow our own food. This is an agricultural area which is also a holiday area and as such should be allowed to stay that way. It is about time Chichester stood up to Westminster and said 'Enough is Enough!

As the review has pointed out at 6.57, there is 'significant traffic congestion' on the road to Chichester and also that there are 'relatively few employment opportunities'. The combination of the two means that there will be increased congestion from people travelling off the Manhood to go to other places of work. The medical centre is already under pressure trying to cope with the existing number of patients. Whilst cycle and footpath provision is identified in the village - these need to be improved along the main roads, where cyclists hold up traffic and are a danger to themselves and drivers.
It is likely that many of the properties will be bought as second homes since this is a popular holiday destination.

Development in East Wittering/ Bracklesham should not be permitted to commence until a Highways England scheme for the relief of A27 has been implemented. The parameters of the Traffic Study are such that traffic congestion on A286 West Manhood has not been surveyed and growth factors not related to the approved and draft local plans are not considered.
Tourism and traffic accidents cause complete logjam on local roads, isolating coastal communities. Long term improvements for access to Chichester and A27 is vital infrastructure for further development on West Manhood. Junction improvements are not the answer.

I agree that East Wittering has potential to accommodate at least 350 houses. To retain the village character of the settlement I consider that two separate sites should be allocated and that their layout should be informed by the needs of the settlement as identified by residents through the Neighbourhood Plan.

Negative impact on internationally protected habitats at Chichester and Pagham Harbours, and Medmerry.
Road infrastructure insufficient and a major challenge to mitigate for peak times.
Tourism economy may be undermined if there is too much development on the Manhood peninsula with gridlock for visitors.

Why build so many homes when there is little employment, the surgery is too busy, public transport to the city of Chichester is hindered by the traffic on the A27? Building family homes will increase the traffic to Chichester as it will create more cars commenting for work.
I agree with the need for housing for the elderly, so developers should be encouraged to build a few decent new and modern bungalows.

AL8 overall mentions that the road infrastructure is not currently able to manage demand (especially on beach days!) yet no mitigation proposals are included in this element of the plan. The proposed extra housing will increase this burden and measures need to be put in place.

AL8 overall mentions that the road infrastructure is not currently able to manage demand (especially on beach days!) yet no mitigation proposals are included in this element of the plan. The proposed extra housing will increase this burden and measures need to be put in place. Unless this is adequately addressed in future iterations of the plan I will wish to raise this with the examiner at the appropriate juncture.

I am writing to STRONGLY OPPOSE to the proposal of the developments throughout the areas in Chichester.
I attended the consultation and it is unbelievable what I have seen using a picture of what I am assuming is the beautiful houses in the grounds of the Cathedral high lighted and labelled neighbourhood planning. if only this was the case, a pretty picture has been used to disguise what is being planned but without any concrete decisions we are only been told of the likelihood such as 'at least' the 100 homes for the Donnington area. My fear is what does the council mean by homes 100? (flats, maisonettes, houses). Why would we want a country park that would be no consolation for what the council is taking away from us when we already have the green fields, the wildlife, the peace and tranquillity, The proposals for employment is another objection I am making, for families to move into the area to enable them to work we would need a vast improvement in the infrastructure of Chichester to facilitate that, buses to take them to work. medical provisions such as doctors Nhs dentists and schools, education has limited resources, as it is we can hardly provide a good standard for the children with such a short fall in investment and not one new school has been mentioned in all the plans, Chichester council are dreaming, all they see is the £ signs. Affordable housing is also another fact that the council has no idea about what young people can afford when buying their own homes Chichester is far too conservative to understand that along with mortgage they have to run car/cars due to lack of bus services and indeed the lack of fair prices in fares.
Now for the proposed so called road improvements they have taken the plans from H E and included them in the plans which would then come back to haunt us having the road around us, they have a nerve to think that people could possibly live with ongoing traffic from behind ,the side and indeed the front of our homes. The proposed housing up in the Wittering area could be an additional 700 cars coming our way each and everyday, how could the council even think that we could live with that, Then with the changes for the Stockbridge roundabout , The A27 proposal was rejected and funding lost. The council believe they can slip it in through the back door and use the already rejected plans. We will loose the farm, the the greenery for what ? a traffic controlled roundabout, with limited access through no right turns and more commercial traffic. without a doubt some of us will develop ill health caused by the build up of the fumes, we do not know either what kind of commercial, employment establishments will be behind us or what noise impact this will have if we are ever able to sit in the garden if these plans are approved. I am also considering the residents that would be living in these new estates. My other question is why on earth would a flood plain be considered for building either around or alongside. The council can not confirm where any of these homes will be built in Apuldram, this is a total waste of money in their fancy posters and booklets, they are not even aware that in the areas they are submitting that the actual land owners would be prepared to sell to them.
I hope you consider what I have written, as I am both angry and so very sad that councillors can sit and plan all this, its obvious there is no consideration for the existing residents, their well being including, the time and money that they have invested in their homes, The A27 fiasco and concrete city,proves they are making a huge mistake that will ruin Chichester for ever, living in the new over populated areas we will have lost everything we hold dear and which we care and maintain . I would also add that w/c 7/1/19 the government was being held responsible for lack of action to cut emissions in areas, evidence of this was sighted on a young child's DEATH CERTIFICATE, is this what Chichester believes could NEVER happen here? I assure you in the very near future it will happen if these plans go ahead, forget social care there will be an increase for medical and mental health care if people are forced to live in an 'inner city' like Chichester.
I can not be the only person very afraid of what these planners have in mind, funny that they choose only the south side of the county.
One more very important point how dare you make the objection procedure so very complicated and time consuming this is a prime example that Chichester has no regard to the residents and believe that using tactics like this will enable their plans to get through.

We need to safeguard those areas of natural beauty in our area. This is not only to protect the aesthetic beauty of our surroundings but also to encourage visitors to the area to see this has a place to visit and return to, this provides a economic boost to our area.
This location is inappropriate as its environmental impact far outweighs its suggested benefit. Its a flood plain. Any developments need to take into account the impact on the immediate surroundings. The use of agricultural land is short sighted and impacting not only our economy but our capability. The adjacency to the Chichester Harbour AONB will have a destructive effect in terms of pollution caused especially from a suggested link road, already objected to under the A27 rejected proposals.

Policy S17:
This policy appropriately highlights the environmental sensitivity of the location within the Chichester Harbour AONB and the proximity of the Chichester Harbour
SAC/SPA/Ramsar, however, there is no mention of the Core and Supporting Areas on the Thorney Island which are within the SWBGS.

As per the SWBG strategy, Core Areas are considered essential to the continued function of the Solent waders and brent goose ecological network and have the strongest functional-linkage to the designated Solent SPA in terms of their frequency and continuity of use by SPA features. We strongly urge that development proposals which are likely to affect these non-designated sites are referenced within the policy.

Policy S26
We welcome Policy S26 and support its intention to protect and enhance the natural
environment of the Plan Area. There is however is no specific reference to designations within the policy and or the supporting text (para 5.51).
The specific conservation designations relevant to the Chichester Local Plan in respect of both international and national designations should be detailed within the Local Plan.

The inclusion of site designations; SPAs, SACs, SSSIs etc. rather than 'biodiversity of the site'. We would also recommend the outcome of the net gain consultation to be referenced in Policy S26 and reflected in the regulations 19 draft

Policy AL6
The policy for this housing allocation appropriately highlights the need to provide
mitigation to ensure the protection of the adjacent SPA, SAC, SSSI and Ramsar at
Chichester Harbour. However, the land in this policy is across the road from site 'C23' in the Solent Brent Goose and Wader Strategy (SWBGS) and has been designated as a 'Candidate area'.

As per the SWBG strategy, development proposals which are likely to affect these sites will need to undertake survey work to confirm the site's classification prior to assessing off-setting and mitigation requirements. We urge that reference to this is made within the policy.

Policy AL8
We note that allocation AL8 is proposed to be delivered through a review of East
Wittering Neighbourhood Plan (NP), which will allocate sites to meet the housing figure. The District Council have therefore not identified any sites at this stage.
The lack of detail as to where these sites (or site) will be located raises concerns given the sensitivity of area and the potential of conflict with the legislation protecting the designated wildlife interests. This also raises questions around the deliverability of the Chichester Local Plan given this allocation is roughly 10% of the overall housing target and there is currently no indication of time frames of the NP review. It could also impact on the Council's ability to undertake a sound Habitats Regulations Assessment of the Local Plan.

If the Parish are to take a lead in identifying new development site(s), attention must be drawn to the details of the Solent Waders and Brent Goose Strategy and the Solent Recreation Mitigation Partnership to ensure suitable sites are identified that do not conflict with the designated site interests.

The RSPB would like clarification as to whether the sites identification process is expected to be competed in time for the submission of the Local Plan, and if not what measures are being taken to ensure that this approach will not affect the overall deliverability of the plan?

Policy AL9
We note that allocation AL9 is proposed to be delivered through a review of Fishbourne Neighbourhood Plan (NP), which will allocate sites to meet the housing figure. The District Council have therefore not identified any sites at this stage.
The lack of detail as to where these sites (or site) will be located raises concerns given the sensitivity of area and the potential of conflict with the legislation protecting the designated wildlife interests. This also raises questions around the deliverability of the Chichester Local Plan given this allocation is roughly 10% of the overall housing target and there is currently no indication of time frames of the NP review. It could also impact on the Council's ability to undertake a sound Habitats Regulations Assessment of the Local Plan.

If the Parish are to take a lead in identifying new development site(s), attention must be drawn to the details of the Solent Waders and Brent Goose Strategy and the Solent Recreation Mitigation Partnership to ensure suitable sites are identified that do not conflict with the designated site interests.

The RSPB would like clarification as to whether the sites identification process is expected to be completed in time for the submission of the Local Plan, and if not what measures are being taken to ensure that this approach will not affect the overall deliverability of the plan?

Policy AL12
The RSPB would like to express concern over the potential impact site allocations AL12 could have on brent geese. Since 2017 the Pagham Harbour reserves team and SOS have been working together, carrying out brent geese surveys around Pagham Harbour since 2017, with the aim to map out how wintering brent geese are using land off the designated sites and to distinguish if these sites are functionally linked to the SPA.

This site is close to the Pagham Harbour SPA (approximately 350m) and over the last 10 years Sussex Ornithological Society (SOS) have recorded over 900 records of birds at Park Farm and Church Norton Greenlease, of which include brent geese.
This area currently falls outside of the SWBGS and therefore would not be picked up by this strategy. Until we have a full understanding of what fields are used by brent geese we will oppose any development on fields potentially used by them for foraging.

Policy AL13
We note that allocation AL13 is proposed to be delivered through a review of Southbourne Neighbourhood Plan (NP), which will allocate sites to meet the housing figure. The District Council have therefore not identified any sites at this stage.
The lack of detail as to where these sites (or site) will be located raises concerns given the sensitivity of area and the potential of conflict with the legislation protecting the designated wildlife interests. This also raises questions around the deliverability of the Chichester Local Plan given this allocation is roughly 10% of the overall housing target and there is currently no indication of time frames of the NP review. It could also impact on the Council's ability to undertake a sound Habitats Regulations Assessment of the Local Plan.

If the Parish are to take a lead in identifying new development site(s), attention must be drawn to the details of the Solent Waders and Brent Goose Strategy and the Solent Recreation Mitigation Partnership to ensure suitable sites are identified that do not conflict with the designated site interests.

The RSPB would like clarification as to whether the sites identification process is expected to be completed in time for the submission of the Local Plan, and if not what measures are being taken to ensure that this approach will not affect the overall deliverability of the plan?

We have seven comments to make about the above plan:


Strategic Site Allocations
We are concerned by Strategic Site Allocations AL3 and AL12, and would also like to bring to your attention some matters about Strategic Site Allocations AL6 and AL8.

1. Strategic Site Allocation AL3
Drayton Gravel Pit is in the south-east corner of the AL3 site, just north of the railway line. We believe that this Pit is a good site for birds, although because of access difficulties it is under-recorded. Certainly the two nearby New Drayton House Gravel Pits, on the south side of the railway line, are recognised to be excellent sites for birds, to the extent that SWT recognises them as an LWS candidate-site because of their importance for birds, particularly water birds. This is because several pairs of Common Pochard are recorded as breeding annually on these two Pits south of the railway line. (Common Pochard is a duck whose breeding numbers nationally have fallen so low that it is monitored by the Rare Breeding Birds Panel - despite its name breeding birds are far from common, and the breeding population at these Pits is over one half of one percent of the national breeding population). Also more than 100 species of bird have been recorded on this site during the last 10 years which is 25% of all the species ever recorded in the whole of East and West Sussex.

Given that the Local Plan proposes building 650 houses on site AL3 north of the railway line we believe that wildlife and house building could both be accommodated if a buffer zone (ideally of 50 metres) could be established around the shores of Drayton Pit in which no development or landscaping took place. If such a buffer zone were protected to allow it to remain wild then it should provide the wildness that waterfowl would need to successfully breed.

We understand that even with such a buffer zone put in place around the Gravel Pit this site should still be able to accommodate 650 new houses.

2. Strategic Site Allocation AL6
It is noted that the western side of this site abuts the Chichester Harbour AONB and the River Lavant Marsh LWS (whose eastern boundaries are Apuldram Lane and the road to BIrdham), and lies close to the boundaries of the Chichester Hbr SPA/SAC/ SSSI/RAMSAR site.

It is also noted that condition 6 of Policy AL6 states that development must
Provide mitigation to ensure the protection of the adjacent SPA, SAC, SSSI and RAMSAR at Chichester Harbour.

We believe it would not be acceptable if the SPA/ SAC/ SSSI/ RAMSAR site, or indeed the AONB or LWS, were in any way affected by the development of AL6 and that the only mitigation measures that should be required are recreational mitigation measures. To make this clearer we would like to see condition 6 reading as:
"Ensure the protection of the adjacent SPA, SAC, SSSI and RAMSAR site at Chichester Harbour, the AONB and the River Lavant Marsh LWS. This should include mitigation measures to avoid recreational disturbance"

We welcome the penultimate paragraph of policy AL6, namely that
Proposals will have to demonstrate that sufficient capacity will be available within the sewer network, including waste water treatment works, to accommodate the proposed development.

3. Supporting habitat for the Pagham Hbr SPA/SSSI/RAMSAR
Before commenting on Strategic Sites AL8 and AL12 below it is appropriate to address the supporting habitat that is required for the birds cited in the designations of the Pagham Harbour SPA and SSSI, because if the supporting habitat no longer becomes available to the cited birds they will go, and Pagham Harbour could then lose its European SPA designation.

The SSSI citation states "The numbers of wintering Pintail, Ringed and Grey Plover and Black-tailed Godwit regularly reach 1% of British Populations, and the site is of International Importance for wintering Ruff and Brent Geese". Of these species Brent Geese is particularly important from a planning point of view, as it alone feeds primarily outside the Pagham Hbr SPA - mostly on fields of autumn planted (winter) wheat which is widely grown around the Manhood peninsula (the other species all primarily feed within the SPA).

WeBS records show that the wintering Pagham Harbour Dark-bellied Brent Geese population varies between 2100 and 3000 birds a year, and is relatively stable. Significant numbers build up in November, and stay around to late February/early March. Typically by late March only a handful remain. One ha of winter wheat can support 2200 Brent Geese for a day and assuming an average population of 2600 birds are present for up to 100 days a winter, plantings of 118 ha of winter wheat are needed to sustain this population over the winter.

Much more than 118ha of winter wheat is planted every year on the Manhood Peninsula, but:-
a) Bird scaring devices, such as roped off fields, are extensively used on winter wheat fields, especially between Siddlesham and Selsey, so that Brent Geese are denied access to a large proportion of the fields planted up with winter wheat.
b) Brent Geese are wary birds so they need buffer zones between the fields on which they are grazing and humans (and their dogs).

Because of the above the Pagham Hbr wintering Brent Goose population could easily come under pressure if development is not planned for in a way that avoids development on fields that are known to have been used by them to forage on. In many instances we recognise that land owners have better knowledge of where they forage than SOS or RSPB, as birders tend to watch birds within the Medmerry and Pagham Hbr RSPB Reserves, rather than in the surrounding fields. An example of the consequences of lack of bird records of where Brent forage is that in Arun DC fields along Pagham Road were allocated for housing development (Arun Planning application P/140/16/OUT) because there were no records of Brent Geese foraging on them. It now turns out that in 2018/19 up to 3000 geese a day (the majority of the 2018/18 Pagham Hbr Brent population) have been recorded foraging on winter wheat in these fields over a 7 week period - which is probably near the maximum number of geese that these fields can support.

This winter SOS have taken over from RSPB a project to map the foraging fields that are used by the wintering Pagham Harbour Brent Geese, as this has not been mapped by the SWBGS, but this project needs to run for several more years. Until we have a full understanding of what fields (suitably planted) are used by the wintering Brent Geese we will oppose any development on fields potentially used by them for foraging, as we just do not currently have the data to hand to fully understand the consequences of allowing such development around Pagham Hbr and Medmerry. In addition to the fields where we record Brent Geese foraging (such as the South Pagham site in Arun DC) we regard any fields planted with winter wheat which farmers take the expense and trouble to erect bird scaring devices on, as fields that have probably been used by foraging wintering Brent Geese in the past and could be suitable for use by them in the future.

When we have gathered such information about where they forage and what suitable fields have bird scaring devices we then need to agree with affected parties, including Natural England and Chichester DC, what steps need to be taken to ensure sufficient acreage is protected to provide foraging for future generations of overwintering Dark-bellied Brent Geese.

From what we can see the needs of the Internationally important Pagham Hbr Dark-bellied Brent Geese population for access to suitably planted fields may not have been adequately addressed in allocating strategic sites for development.




4. Strategic site AL8
We note that this policy requires The East Wittering Neighbourhood plan, which includes Bracklesham Bay, to produce proposals for a minimum of 350 new houses, and that the settlement boundary may be adjusted to accommodate these.

The RSPB Medmerry Nature reserve lies immediately to the east of Bracklesham Bay. It has no formal conservation protection, so we feel that it is important that it is protected through the planning system.

Recognising this we would like to see point 7 of policy AL8 rewritten. It discusses two very separate matters, the impacts of more housing causing recreational disturbance in the Pagham SPA/Ramsar site and the Medmerry realignment, and the impact of development on functionally linked supporting habitat.

Firstly, we welcome the fact that point 7 talks of providing mitigation for the impacts of recreational disturbance arising from this development and believe in this respect that this should not be a case of "mitigation if required", but that it must be a condition attached to the development of any more houses in East Wittering/Bracklesham Bay.

Secondly, given the comments we have made in 3 above, we believe that all supporting habitat must be protected if development is to be allowed. We are not opposed to the development of 350 more houses in this area but we are totally opposed to such development having an impact on either of the two RSPB reserves, or on the fields used by the wintering Brent Geese and waders that underpin the conservation citations for Pagham Harbour.

We would therefore like to see two paragraphs replacing point 7 in Policy AL8, so that it reads:
7a) Demonstration that suitable mitigation measures will be put in place to ensure that development will not create recreational disturbance that will have an adverse impact on the Pagham Hbr SPA/Ramsar and Medmerry realignment sites.
7b) Demonstration that development will not occur on any land that can be shown to be functionally linked supporting habitat for the birds on these two RSPB reserves.

5. Strategic Site AL12
SOS has over 900 records of birds at Park Farm during the last 10 years (the site of AL12) and at Church Norton Greenlease. We also note that the site of AL12 is sown this winter with winter wheat and that it is roped off to scare away Brent Geese, suggesting that it is a known site used by them in winter. We strongly oppose this site (or indeed any site on the east side of Selsey Road between Siddlesham and Selsey) being allocated for development. It is just too close to Pagham Harbour, and building on the east side of the road could directly affect the SPA.

If 250 houses are to built north of Selsey then we would much prefer to see them built on the west side of Selsey Road, as the busy Selsey Road does form a natural protective barrier around the western side of the SPA. This would alleviate any additional pressure being created on the Church Norton part of the Pagham Hbr SPA, which is already coming under pressure because of recent or planned housing developments at the northern end of Selsey.

Policy 30 Strategic wildlife corridors
6. We welcome the strategic approach of designating wildlife corridors between the Chichester Harbour SPA and the SDNP, and applaud Chichester DC on this initiative. However, we note that Policy 30 says that

Development proposals within, or in close proximity to, strategic wildlife corridors will be granted where (three things) can be demonstrated:

We have no problems with condition 3, and would reluctantly accept condition 2. However, we do have concerns with condition 1, namely
1. There are no sequentially available sites outside the wildlife corridor

For a start we have no idea what a "sequentially available site" is. And secondly we do not see how any circumstances can be permitted that allows any development to occur within a Strategic Wildlife Corridor (other than those that satisfy condition 3 of this policy) that would not result in the destruction of the corridor. It's only going to be acceptable to wildlife as a corridor if it is not built upon. And any process of actually building anything will particularly affect its ability to serve as a wildlife corridor during the building process.

7. The four western corridors look like realistic corridors - at least on the small-scale maps within the Local Plan. However, the absence of an ability to enlarge the on-line maps means that we are not able to comment on their suitability in detail. Moreover the Y-shaped eastern corridor (Map S30b) shows that this corridor is extraordinarily narrow in places, so much so that its effectiveness looks questionable. A link to your Strategic Wildlife Corridors background paper would have been helpful, but unless there is something in this document elaborating the detailed reasons for the precise boundaries of these corridors as shown on maps S30a and S30b, then our comment would be that the corridors in S30b look far too narrow in places to provide the "non-disturbance" security for wildlife required of an effective wildlife corridor.

West Sussex County Council Officer Level Response
Introduction
The Chichester Local Plan Review Preferred Approach sets out how the future development in the District will be shaped, excluding the area within the South Downs National Park, up to 2035. It includes the overall development strategy as well as relevant strategic policies to meet the future needs of the area and development management policies to help guide development over the plan period. The Local Plan helps to:
* choose where the development goes;
* protect the character and beauty of the area;
* provide job and housing opportunities so that children can continue to work and live locally;
* support and help to boost the local economy;
* help residents to maintain healthy and active lifestyles; and,
* make sure that there is adequate services, travel options and community facilities.

The Chichester Local Plan was adopted in July 2015. At that time, the Local Plan was approved, but the Government Inspector said that it had to be reviewed again within five years, to make sure that sufficient housing was planned to meet the needs of the area.

The first part of the review process was carried out in June 2017 with an Issues and Options consultation, in which comments were invited regarding the overall development strategy and possible development locations. The Local Plan Review: Preferred Approach is the second stage of the process. It sets out the proposed development strategy and policies for the area to meet future needs.


West Sussex County Council Officer Level Comments
This note sets out West Sussex County Council's (WSCC) officer response to the consultation on the draft Chichester Local Plan Review Preferred Approach. It highlights key issues and suggested changes to which Chichester District Council (CDC) is requested to give consideration. We will continue to work with CDC in preparation of the Local Plan Review and the Infrastructure Delivery Plan regarding WSCC service requirements in order to mitigate planned development.


Minerals and Waste
A steady and adequate supply of minerals and the achievement of sustainable waste management can help to achieve a District or Borough Council's goals in relation to the economy, housing, transport, communications, strategic infrastructure and the environment. Therefore, District and Borough Local Plans should recognise the importance of minerals and waste issues as relevant to the scope of their overall strategies.

We welcome the reference to the adopted Minerals and Waste Local Plans and safeguarding in the document and the requirements in policies where a site is located within a minerals safeguarding area, or near to a safeguarded waste site. There are some missing references to safeguarding of minerals and waste sites for some of the proposed allocations, set out below and request that these references are added. It is also requested that 'Joint' is added into the references for the Joint Minerals Local Plan through the document.

Policy W23 of the Waste Local Plan applies to all Districts & Boroughs, regarding waste management within development and should be referenced in the Chichester Local Plan Review.

AL3 East of Chichester
The site is to the north of the Fuel Depot site allocation in the Waste Local Plan (Policy W10) for a built waste facility as part of a comprehensive redevelopment of the site (including complimentary non-waste uses). The East of Chichester allocation is the land to the north, bisected by the railway line, of the Fuel Depot. Reference should be made to giving consideration to the allocation, and therefore its safeguarding.

AL4 Westhampnett/North East Chichester
Reference should be made to minerals safeguarding, for consistency with other allocations, as within the sharp sand and gravel safeguarding area.

AL5 Southern Gateway
Reference should be made to the mineral infrastructure safeguarding policy M10 as within 200m of the Chichester Railhead.

AL6 South-West of Chichester
Reference should be made to the mineral infrastructure safeguarding policy M10 as within 300m of the Chichester Railhead.

AL7 Highgrove Farm Bosham
Remove reference to minerals safeguarding as the site is not within the safeguarding or consultation area.

AL12 Park Farm Selsey
Reference should be made to minerals safeguarding as site is within the sharp sand and gravel safeguarding area.

Neighbourhood plan allocations
Sites are yet to be allocated though neighbourhood plans. It is considered that the Joint Minerals Local Plan and Waste Local Plan are referenced, particularly with regards to safeguarding policies (M9, M10 and W2) and these documents and policies are given detailed consideration when allocating sites. Development at, adjacent or proximal to existing waste or mineral sites / infrastructure should be the subject to consultation with WSCC.


Connectivity and Sustainable Travel
The County council has worked with the District Council on the preparation of the transport evidence base study undertaken by Peter Brett Associates for the District Council. The recommended transport mitigation strategy, as assessed using the Chichester Area Transport Model has been demonstrated to be capable in principle to prevent the development from resulting in severe residual cumulative impacts on the highways and transport network. However, the recommended strategy has several risks to deliverability and acceptability associated with it, which require further work to be undertaken to demonstrate that the strategy can be implemented in its current form to provide the forecasted mitigation to travel conditions.

There are three locations where new highway alignments are proposed outside of existing highways boundaries. Two of these may include significant earthworks or structures to be delivered, being Stockbridge Link Road and Terminus Road diversion. The cost of the mitigation strategy exceeds a figure which could reasonably be supported by the value of the proposed development developer contributions alone, therefore the delivery of the strategy will depend upon securing of external grant funding to top up developer contributions. WSCC will work with the District Council in supporting and or applying for funding, the District Council needing to secure Highways England to support funding applications for A27 improvements. The proposed junction designs for the A27 Stockbridge and Whyke roundabouts include bans to well used right turn movements off the Chichester A27 bypass which result in significant forecast changes to traffic flows on local roads in the south of Chichester and on the Manhood Peninsular.

There is a need to ensure the land outside the highway boundary is available and the plan should set out how this land will be acquired to deliver the measures, it may be that a commitment to use, if required, and therefore reference to CPO be made in the policy.

Funding for the mitigation strategy is uncertain. It is considered that the Plan should set out how it will deal with this uncertainty. This could include trigger points in the monitoring framework to trigger a change of approach or alternative options to deliver the required development.

These factors mean that feasibility work is necessary to be undertaken prior to Plan submission, to reduce as far as practicable risks to costs, land take, impacts and deliverability of the proposed transport strategy in order to show that the strategy can be implemented within the plan period and that the funding strategy will be sufficient to meet the design requirements. In particular the following will need to be addressed:

* Statutory undertakers equipment under the roads junctions to be impacted.
* Extent of earthworks required to create a vertical and horizontal alignment compliant with design standards. Design audit to identify any required departures from standard.
* Designing for drainage and flooding issues, including compliance with the WSCC LLFA Policy for the Management of Surface Water, November 2018.
* Designs for structures to cross watercourses - Stockbridge Link Road
* Design should include suitable provision for rights of way and footway crossings
* Scoping for whether and at what level further Environmental Impact Assessment will be required.
* Stage 1 Road safety Audit, designers response report and resulting amendments to designs.
* Land take required after feasibility level designs have been developed and availability of required land.
* Wophams Lane - impacts of forecast changes to flow patterns to take B2201 southbound traffic on requirements for highway width, alignment, footway provision and junctions with A286 Birdham Road and B2201 Selsey Road; design solution required.
* Quarry Lane, Kingsham Avenue /Road, Terminus Road; impacts of forecast flow changes on highway users, residential and commercial frontagers and measures to manage through traffic whilst maintaining local access

Sustainable transport measures will also be required to mitigate planned development. These will be identified through more detailed assessments of sites including pre-application consideration. Funding will need to be identified through development and other sources as well in some cases.

Public Rights of Way
There is support for the Local Plan Review's approach to Public Rights Of Way (PROW), not just for the potential to impact on existing public off-road access but also the opportunity it brings to enhance this access for the benefit of future residents, communities and visitors. PROW deliver benefits for personal health and wellbeing; sustainable transport; reduction of air pollution and road congestion; are able to support local economies; and they connect communities.
WSCC PROW welcomes several aspects of the Vision statement, which give support to the protection and enhancement of the PROW network, and provision of safe and convenient off-road access opportunities for residents and visitors:

* Pursue a healthy lifestyle and benefit from a sense of well-being supported by good access to education, health, leisure, open space and nature, sports and other essential facilities;
* Live in sustainable neighbourhoods supported by necessary infrastructure and facilities;
* Move around safely and conveniently with opportunities to choose alternatives to car travel.

The Local Plan Strategic Objectives offer further support to enhance off-road access, particularly to 'Encourage healthy and active lifestyles for all, developing accessible health and leisure facilities and linked green spaces'. However, the objective to 'Achieve a sustainable and integrated transport system through improved cycling networks and links to public transport' should recognise walking also as an important mode for many people; some strategic enhancements will significantly improve walkers' safety and convenience.

It is considered that West of Chichester the A259 could act as a corridor for increased volumes of non-motorised access, particularly cycling. Improvement of the existing on-road facility and development of a various 'feeder' routes to connect with the many settlements, perhaps using quiet lanes in places, would encourage cycling particularly to be a natural alternative to vehicle use. Policy S18: Integrated Coastal Zone Management for the Manhood Peninsula, gives regard to such an ambition in stating it will 'Improve infrastructure to support sustainable modes of transport, especially cycle ways, bridleways and footpaths, including the National Coastal Footpath'.

The National Planning Policy Framework (NPPF) Open Space and Recreation, para 97b) states:
the loss resulting from the proposed development would be replaced by equivalent or better provision in terms of quantity and quality in a suitable location.
The NPPF para 98 also states:
Planning policies and decisions should protect and enhance public rights of way and access, including taking opportunities to provide better facilities for users, for example by adding links to existing rights of way networks including National Trails.'
There is support for Policy S20: Design, that recognises these requirements in stating development 'is well connected to provide safe and convenient ease of movement by all users, prioritising pedestrian and cycle movements both within the scheme and neighbouring areas and ensuring that the needs of vehicular traffic does not dominate at the expense of other modes of transport, or undermine the resulting quality of places' and 'incorporates and/or links to high quality Green Infrastructure and landscaping to enhance biodiversity and meet recreational needs, including public rights of way'.


Education
As the local education authority, WSCC has the statutory duty to ensure that there is a sufficient supply of suitable school places to meet statutory requirements for early years, primary, secondary and sixth form provision (including up to age 25 for those with special educational needs and/or disabilities). Education infrastructure, or contributions to provide infrastructure, will be required in order to mitigate proposed development. We will continue to work with CDC in preparation of the Local Plan Review and the Infrastructure Delivery Plan regarding education and other service requirements in order to mitigate planned development.

The table below sets out the primary, secondary school and sixth form requirements to mitigate proposed development. SEE ATTACHMENT FOR TABLE

AL1 Land West of Chichester

It should be noted that phase one of this development will provide the primary school with the core of the building being built to the specification for a 2 form entry (FE) school and 1FE teaching accommodation. Phase 2 as per 6.10 on page 93 should include expansion of the primary school for the further 1FE of teaching accommodation.

AL2 Land at Shopwhyke (Oving Parish)

No update to original response for this allocation is required.

AL3 Land East of Chichester - previously South of Shopwhyke

At the current time pupil place planning indicates that there is insufficient space within the primary schools that serve this proposed development. Further capacity would be required to accommodate the development. Land for a 1 FE expandable to 2FE and pro rata share of the build costs would be required.

If numbers were to increase on the east side of the city, education provision will need to be reviewed, potentially a further 1FE may be required including land provision, this could be in the form of an expansion or a new school being built capable of expansion to 3FE.

At the current time pupil place planning indicates that there would be expansion capacity to accommodate the child product from this proposed development for secondary aged pupils. Contributions would be required for expansion of secondary schools if feasible and required.

At the current time pupil place planning indicates that there would be expansion capacity to accommodate the child product from this proposed development for sixth form pupils. Contributions would be required for expansion of the provision if feasible and required.

AL4 Land at Westhampnett / North East Chichester

The remaining 200 dwellings will impact on the education provision in the area, financial contributions towards expansion of existing or pro rata costs towards the expansion of the school within AL3.

At the current time pupil place planning indicates that there would be expansion capacity to accommodate the child product from this proposed development for secondary aged pupils. Contributions would be required for expansion of secondary schools if feasible and required.

At the current time pupil place planning indicates that there would be expansion capacity to accommodate the child product from this proposed development for sixth form pupils. Contributions would be required for expansion of the provision if feasible and required.

AL5 Southern Gateway

At the current time pupil place planning indicates that there would be sufficient space or expansion capacity to accommodate the child product from the strategic allocation of 350 dwellings in the Southern Gateway. However, consideration should be given to the cumulative impact of housing in the area Land South West of Chichester (AL6) to allocate land within the area for a 1FE expandable to 2FE primary school. Pro rata financial contributions towards the build costs would be sought from developers to mitigate their impact.

At the current time pupil place planning indicates that there would be expansion capacity to accommodate the child product from this proposed development for secondary aged pupils. Contributions would be required for expansion of secondary schools if feasible and required.

At the current time pupil place planning indicates that there would be expansion capacity to accommodate the child product from this proposed development for sixth form pupils. Contributions would be required for expansion of the provision if feasible and required.

AL6 Land South West of Chichester (Apuldram & Donnington Parishes)

It should be noted that the primary education provision in this area is either in Chichester City Centre which means crossing the main A27 or by travelling south towards the peninsula. Consideration should be given to the cumulative impact of further housing in the area along with the Southern Gateway allocation (AL5) to allocate land within the strategic allocation site for a 1FE expandable to 2FE primary school. Pro rata financial contributions towards the build costs would be sought from developers to mitigate their impact.

At the current time pupil place planning indicates that there would be expansion capacity to accommodate the child product from this proposed development for secondary aged pupils. Contributions would be required for expansion of secondary schools if feasible and required.

At the current time pupil place planning indicates that there would be expansion capacity to accommodate the child product from this proposed development for sixth form pupils. Contributions would be required for expansion of the provision if feasible and required.

AL7 Bosham

The current primary provision serving the area is at capacity, expansion of the school on its existing site is not possible. As part of the strategic allocation, it is proposed that land for a 2FE primary school be provided. The strategic allocation of 250 dwellings in isolation does not require a new school to be built. Certainty over the land allocation and sufficient funding will be key drivers in realising this proposal.

AL7, AL10 and AL13 are all within the same school planning area, the cumulative total of the strategic allocations brings forward a requirement for c3 forms of entry additional school places. The Local Plan, as currently drafted, indicates an oversupply of school places which could affect the viability of all the schools in the planning area.

Expansion of the secondary school may be possible. Contributions would be required for expansion of secondary schools if feasible and required.

AL9 Fishbourne

The primary school serving the area is currently at capacity, expansion of the school may be possible, feasibility / options appraisals would need to be undertaken.

At the current time pupil place planning indicates that there would be sufficient space or expansion capacity to accommodate the child product from this proposed development for secondary aged pupils. Contributions would be required for expansion of primary and secondary schools and sixth form if feasible and required.

AL8 East Wittering

At the current time pupil place planning indicates that there would be sufficient space or expansion capacity to accommodate the child product from this proposed development.

Contributions would be required for expansion of primary and secondary schools if feasible and required.

AL10 Chidham and Hambrook area

The current primary provision serving the area is at capacity, expansion of the school on its existing site is not possible. As part of the strategic allocation, it is proposed that land for a 2FE primary school be provided. Certainty over the land allocation and sufficient funding will be key drivers in realising this proposal.

AL7, AL10 and AL13 are all within the same school planning area, the cumulative total of the strategic allocations brings forward a requirement for c3 forms of entry additional school places. The Local Plan, as currently drafted, indicates an oversupply of school places which could affect the viability of all the schools in the planning area.

Expansion of the secondary school may be possible. Contributions would be required for expansion of secondary schools if feasible and required.

AL11 Hunston

Any development within this area cannot currently be accommodated in the existing primary school at North Mundham. Further capacity would be required to accommodate the development, CDC will need to work with WSCC to determine how additional capacity in the area could be accommodated if land is to be allocated.

At the current time pupil place planning indicates that there would be sufficient space or expansion capacity to accommodate the child product from this proposed development for secondary aged pupils. Contributions would be required for expansion of secondary schools and sixth form if feasible and required.

AL12 Selsey

Further capacity would be required to accommodate the development. Contributions (and possibly land if required) would be sought to meet the pupil product from the development in the most appropriate form once this can be clarified.

At the current time pupil place planning indicates that there would be sufficient space to accommodate the child product from this proposed development for secondary aged pupils. Contributions would be required for expansion of secondary schools if feasible and required.

AL13 Southbourne

At the current time pupil place planning indicates that there is insufficient space within the primary schools that serve this proposed development. Further capacity would be required to accommodate the development. Land for a 2form entry expandable to 3FE primary school and pro rata share of the build costs would be required.

AL7, AL10 and AL13 are all within the same school planning area, the cumulative total of the strategic allocations brings forward a requirement for c3 forms of entry additional school places. The Local Plan, as currently drafted, indicates an oversupply of school places which could affect the viability of all the schools in the planning area.

Expansion of the secondary school may be possible. Contributions would be required for expansion of secondary schools if feasible and required.

AL14 Tangmere

The current allocation of 1,300 dwellings will bring forward the requirement for land for a 1FE expandable to 2FE and financial contributions would be sought to meet the pupil product from the development in the most appropriate form once this can be clarified.

At the current time pupil place planning indicates that there would be sufficient space or expansion capacity to accommodate the child product from this proposed development for secondary aged pupils. Contributions would be required for expansion of secondary schools and sixth form if feasible and required.

Footnote: - if all of the proposed sites were to come forward the secondary school and sixth form provision would be full in the Chichester Planning Area. Expansion of the secondary schools in the Chichester Planning Area to cater for the increased demand would need to be sought from the academy sponsors, where appropriate and the Local Authority.


Lead Local Flood Authority
The Lead Local Flood Authority (LLFA) is concerned about the approach being taken with regard to ensuring potential wastewater treatment for proposed new sustainable development.

Paragraph 8 of the NPPF states:
8. Achieving sustainable development means that the planning system has three overarching objectives, which are interdependent and need to be pursued in mutually supportive ways (so that opportunities can be taken to secure net gains across each of the different objectives):

a) An economic objective - to help build a strong, responsive and competitive
economy, by ensuring that sufficient land of the right types is available in the
right places and at the right time to support growth, innovation and improved
productivity; and by identifying and coordinating the provision of infrastructure;

Paragraph 20 of the NPPF states:
20. Strategic policies should set out an overall strategy for the pattern, scale and quality of development, and make sufficient provision for:
a) housing (including affordable housing), employment, retail, leisure and other commercial development;
b) infrastructure for transport, telecommunications, security, waste management, water supply, wastewater, flood risk and coastal change management, and the provision of minerals and energy (including heat);

In the LLFAs view, the Local Plan Review is not setting out an overall strategy for the pattern, scale and quality of development in relation to arrangements for wastewater management. The LLFA considers that CDC needs to go further in incorporating within the Local Plan Review how this provision is being made.


Additional Policy Comments

Policy S12: Infrastructure Provision
Support the requirement that all development must provide or fund new infrastructure, facilities and services required, both on and off-site (including full fibre communications infrastructure) as a consequence of the proposal. The explicit reference to full fibre communications infrastructure is supported as this will provide gigabit-capable and future-proofed services to all development, existing and new. The reference to provision of facilities and services on and off-site is also supported as in the case of broadband for example, all development will be adequately equipped with the necessary infrastructure installed for the purposes of connecting to full fibre gigabit-capable broadband services. This policy supports the County Council's aim for increased digital infrastructure that will provide for gigabit-capable broadband and future technologies such as 5G.

Support the reference to safeguarding educational facilities under section 3 of the policy.

The policy includes the requirement to 'Facilitate accessibility to facilities and services by a range of transport modes'. PROW can offer vital access means for walkers and cyclists, such as for employment land use (e.g. commuting by bicycle) and in support of the high street, both for employees and customers. IT is considered that this Policy, also Policy S13: Chichester City Development Principles, should aim to encourage such access to be the natural and preferred modes of access, thereby helping achieve the benefits previously described. It is noted Policy S14: Chichester City Transport Strategy, does acknowledge cycling and walking and lends support to their improvement.

The supporting text, paragraph 4.81 makes reference to the Strategic Infrastructure Package (SIP). It is requested that this wording is removed and replaced with West Sussex County Council identifies service infrastructure requirements necessary to support new and existing communities, where strategic development and growth is proposed in Local Plans. These are required to deliver the County Council's statutory responsibilities, strategic objectives and current policy and feed into the preparation of the Infrastructure Delivery Plan.


Policy S13: Chichester City Development Principles
This policy, like policy S12, it is considered should aim to encourage such access to be the natural and preferred modes of access, thereby helping achieve the benefits previously described. It is noted Policy S14: Chichester City Transport Strategy, does acknowledge cycling and walking and lends support to their improvement.


Policy S23: Transport and Accessibility
The policy and supporting text paragraphs 5.15 - 5.33 refer to Transport Infrastructure. Understandably much consideration is given to the A27 around Chichester; however, in addition to seeking new infrastructure from new development, it is recommended support in principle is given to maximising the value of existing infrastructure so as to facilitate off-road user modes accessing either side of the A27.


S24: Countryside
Supporting text paragraphs 5.34 - 5.43, acknowledges 'it is necessary to provide for the social and economic needs of small rural communities, and enable those who manage, live and work in the countryside to continue to do so'. It is recognised in para 7.205, supporting text to policy SM35 Equestrian Development, the high numbers of liveried and stabled horses. A considerable network of businesses are supported by such a high equine population, and in addition to financial value within the local community there is considerable benefit in terms of health and wellbeing of individuals. It is suggested that Policy S24: Countryside, could recognise this specifically.


S27: Flood Risk Management
Supporting text paragraph 5.54, requested amendments underlined - as a consequence of the rise in sea levels and storm surges, parts of the plan area will be at increased risk from coastal erosion, groundwater, fluvial and/or tidal flooding. Hard defences may not be possible to maintain in the long term, therefore development needs to be strongly restricted in areas at risk to flooding and erosion, whilst ensuring that existing towns and villages are protected by sustainable means that make space for water in suitable areas. Development must take account of the policies of the relevant shoreline management plan

Supporting text paragraph 5.58, requested amendments underlined - Built development can lead to increased surface water run-off; therefore new
development is encouraged to incorporate mitigation techniques in its design, such as permeable surfaces and Sustainable Drainage Systems (SuDS). Where appropriate, SuDS should be used as part of the linked green infrastructure network to provide multiple functions and benefits to landscape quality, recreation and biodiversity. This can be achieved through habitat creation, new open spaces and good design. SuDS should be designed to help cope with intense rainfall events and to overcome any deterioration in water quality status. In determining the suitability of SuDS for individual development sites, developers should refer to guidance published by the Lead Local Flood Authority (LLFA): West Sussex LLFA Policy for the Management of Surface Water: https://www.westsussex.gov.uk/media/12230/ws_llfa_policy_for_management_of_surface_water.pdf and, if necessary, seek further advice from the Lead Local Flood Authority LLFA.

S27 policy text requested amendments underlined for section 1 - a. through a sequential approach, taking into consideration all forms of flooding, it is located in the lowest appropriate flood risk location in accordance with the NPPF and the Chichester Strategic Flood Risk Assessment (SFRA); and

S27 policy text requested amendments underlined for section 2. Sustainable drainage systems (SuDS) will be required on major developments (10 or more dwellings or equivalent) and encouraged for smaller schemes. SUDS should be designed into the landscape of all new development and should be included as part of a District wide approach to improve water quality and provide flood mitigation. A site-specific Flood Risk Assessment will be required for sites within or adjacent to areas at risk of surface water flooding as identified in the SFRA. There should be no increase in either the volume or rate of surface water runoff leaving the site.

S27 policy text requested additional bullet point as number 4 - Clear management arrangements and funding for their ongoing maintenance over the lifetime of the development should be proposed. Planning conditions and / or obligations will be used to secure these arrangements.

S27 policy text requested amendments underlined for section 2, but would be section 5 - Development should not result in any property or highway, on or off site, being at greater risk of flooding than the 1 in 100 year storm return period, including an allowance for climate change.


Policy S29: Green Infrastructure
The Green Infrastructure policy is welcomed, including provision of new Green Infrastructure as an integral part of the development at Strategic Development Locations. It is recommended that measures are put in place to secure the long term management of such Green Infrastructure.


Policy S30: Strategic Wildlife Corridors
The identification of Strategic Wildlife Corridors and inclusion of a policy to safeguard them from development is welcomed. It is recommended that CDC promotes positive conservation management within these corridors to maximise their contribution to maintaining and enhancing biodiversity. As stated in Section 5.66, 'These corridors do not stop at the plan area boundaries.' Thus, it is recommended that CDC works in partnership with Chichester Harbour Conservancy and The South Downs National Park Authority to ensure that these Strategic Wildlife Corridors continue to provide effective corridors and connectivity across the wider landscape.

Section 5.66 refers to four Strategic Wildlife Corridors connecting Chichester Harbour with the South Downs National Park but it is noted that there is no mention of the Strategic Wildlife Corridors to the east of Chichester which connect Pagham Harbour with the South Downs National Park (as seen in Policy Map S30b). It is also noted that the maps referred to in Section 5.66, Maps 5.1 & 5.2 are missing.

WSCC and CDC promoted a Mitigated Northern Route for the A27 at Chichester as the preferred option, subject to the inclusion of important mitigation measures that are needed to make the scheme acceptable in environmental terms and the 'full southern route' as a reasonable alternative. Both routes could impact on the identified Strategic Wildlife Corridors. As currently drafted, Policy S30 would seem to prevent a mitigated northern route from coming forward in the future. Therefore, the District Council should consider whether the policy is overly restrictive (for example should it refer to 'significant adverse impacts' or 'unacceptable adverse impacts'?) and how it would be applied if a northern route for A27 were to come forward in the future.


Policy S31: Wastewater Management and Water Quality
S27 policy text requested amendments underlined for section 3, this - Where appropriate, development should contribute to the delivery of identified actions to deliver infiltration reduction across the catchment. Where appropriate development should contribute to the delivery of identified actions to deliver a reduction in the level of infiltration of groundwater into the sewer system.


Policy AL1: Land West of Chichester
AL1 policy text requested additional bullet point as number 8 - Increase capacity to attenuate surface water on site, thereby reducing the discharge flows off the site below current rates and reducing the risk of flooding to residential areas downstream.

AL1 policy text requested additional bullet point under 15 as 15 b- Provide mitigation for any loss of watercourse habitat resulting from culverting for highway provision in the development;

AL1 policy text in supporting 'improved cycle and pedestrian routes linking the site with the city, Fishbourne and the South Downs National Park', a new key link for cycling will be to Salthill Road, thereby enabling cyclists to benefit from the existing bridge crossing of the A27 for journeys to and from the west.


AL2: Land at Shopwyke (Oving Parish)
The policy acknowledges need 'for foot/cycle bridge across A27 to Coach Road'. There is also need for equestrian users to cross the A27 and WSCC PROW has received several enquiries seeking support for such infrastructure. Consideration could be given to the proposed bridge providing for all three modes.


AL3: East of Chichester (Oving Parish)
AL3 supporting text requested amendments underlined for paragraph 6.22 - The site is identified for 600 dwellings, however, there may be potential to deliver a large strategic development of 1000 dwellings, subject to further evidence, including the testing of additional growth on the local highway network and capacity of the site to provide flood risk attenuation for the increased housing density. The site should be master planned as a whole, and delivered through a phased development over a ten year period. Although the site is physically separated from the city by the A27 Chichester Bypass, the development should form a planned extension to the city, forming a new neighbourhood. This will involve opportunities to provide new facilities to serve the wider local community with good off-site access, particularly by walking and cycling to existing local facilities and facilities in the city.

AL3 policy requires exploring integrated green infrastructure with other strategic sites to the north east of the city, Tangmere and the wider countryside. It is considered that future residents will have expectations for provision of safe and convenient links towards Oving and also across the railway to link to the A259 cycle path and PROW south of the A259. It is considered that the policy should be strengthened to ensure such provision.


Policy AL4: Land at Westhampnett/North East Chichester
AL4 policy text requested amendments underlined for section 3 - Open space and green infrastructure, including a linear greenspace with public access along the Lavant Valley.

Taking into account the site-specific requirements, proposals for the site should satisfy the following requirements:

Policy AL4 policy, it is welcomed that 'provision should be made for green links to the South Downs National Park and Chichester City.' Safe and convenient walking and cycling to Lavant, from where people will access the South Downs, will provide for sustainable transport use.


Policy AL5 Southern Gateway
AL5 supporting text requested amendments underlined for paragraph 6.38 - The area has been identified as suitable for comprehensive regeneration with the aim being to make it a more attractive and welcoming gateway for the city, providing new housing, business and retail space and leisure and tourism facilities. Opportunities will be identified to improve transport links with a focus on cycling, walking and public transport and the removal of non-essential traffic from the area. There is also scope for significant public space enhancements and new landscaping incorporating blue / green infrastructure delivering multi-functional benefits.

AL5 policy text requested amendments underlined for section 5 - Provision of open space that:
* Is in accordance with Policy DM34, including retention of the existing playing pitch unless suitable re-provision is provided;
* Reinforces / enhances green and blue infrastructure consistent with Policy S29 and fully exploits the opportunities for sustainable drainage.


AL5 policy text requested amendments underlined for section 8 - Provision of both a surface and waste water management plan which demonstrates no net increase in flow to Apuldram Waste Water Treatment Works would result from this development, unless suitable alternative provision is agreed;


Policy AL6: Land South-West of Chichester (Apuldram and Donnington Parishes)
The LLFA has concerns regarding the lack of reference to flood risk constraints of the site in Policy AL6. There is reference to flood risk in paragraph 6.47. However, the policy itself makes no reference to these constraints.
The constraints arise from a combination of the following:

* Current tidal /fluvial flood risk extending from Chichester harbour to the west and up the River Lavant floodplain; (Map 1)
* Future tidal /fluvial flood risk associated with climate change; (Map 1)
* Constraints on infiltration of surface water run off because of high seasonal groundwater levels (<0.025m below the surface) (Map 2); and
* Constraints on gravity outfalls because of the low relief and long-term reduction in tidal window for discharge.

The above limits the options for how the site can be effectively drained without a step change from typically employed methods to embrace more innovative and currently expensive options e.g. blue roofs and rainwater harvesting.

The LLFA recommends that the policy sets out both the above constraints and the type of innovative drainage that will be required to achieve the development objectives for the site.



Key: Projected medium projection extent of SLR based upon 4m contour

AL6 extent

Current Flood Zone 3 extent.

Current Areas of high (1:30) surface water flood risk

Map 1 Existing and projected Tidal and surface water flood risk for AL6.

Consistent with paragraph 3.2 of the SFRA, given the high risk of flooding both now and into the future for this site, it is recommended that CDC gives consideration to the climate change maps to understand how the flood zones are predicted to change over the lifetime of the development.


Key:
AL6 boundary.

Groundwater levels are either at very near (within 0.025m of) the ground surface.

Groundwater levels are between 0.025m and 0.5m below the ground surface

Map 2 Groundwater flood risk JBA

Policy AL6 WSCC PROW considers 'necessary highway improvements to adequately mitigate the likely impacts on the highway network' to include a bridge crossing of the A27 for convenient walking and cycling access to the Terminus Road industrial estate and the city. There is an existing public footpath but, as this crosses the A27 at-grade, this will not provide the safest facility and not encourage people to minimise use of vehicles for local access. Provision of a bridge and access through the site could also establish a valuable link to the popular Salterns Way walking and cycle path. An additional link to Salterns Way should also be provided off the A286 for the benefit of Stockbridge residents as a safer alternative to the A286.


AL 7 Highgrove Farm, Bosham
The LLFA notes that the above site has the potential for a moderate risk of groundwater flooding. It is likely that this is perched groundwater draining from higher ground / springs to the north that lies in the superficial mixed sediments underlain by Lambeth Clay.


Policy AL8: East Wittering Parish
Due to no information on where housing is going to be located so the LLFA is not in a position to comment on proposed housing allocation sites at this stage.

The policy requires 'Opportunities ... for the expansion and provision of green infrastructure into the wider countryside including between settlements and facilities'. Existing and future residents and the local visitor economy would benefit by delivery of an off-road route for walkers, cyclists and horse riders to and from the Medmerry development and towards Selsey. It is considered that Policy AL8 should aim to deliver this enhancement specifically.


Policy AL9: Fishbourne Parish
Due to no information on where housing is going to be located so the LLFA is not in a position to comment on proposed housing allocation sites at this stage.

It is considered that off-road cycling links to land West of Chichester (off Salthill Road) and to Bosham (off Park Lane) would benefit this community with enhanced sustainable connectivity.


Policy AL10: Chidham and Hambrook Parish
Due to no information on where housing is going to be located so the LLFA is not in a position to comment on proposed housing allocation sites at this stage.

The policy requires 'opportunities' to develop green infrastructure and links to other communities. An opportunity, in conjunction with Highways England, exists to maximise the value of existing infrastructure by creating a new bridleway (for walkers, cyclists and horse riders) on a path using an existing A27 overbridge.


Policy AL11: Hunston Parish
Due to no information on where housing is going to be located so the LLFA is not in a position to comment on proposed housing allocation sites at this stage.

The village is already well connected for walkers to access the surrounding countryside but there are presently no local cycling or horse riding facilities on the PROW network. A bridleway link to South Mundham (with the potential for future cycle links to Pagham and towards Bognor Regis) and to Sidlesham via the golf course and Brimfast Lane would provide residents and visitors with improved access to the countryside and services.


Policy AL12: Land North of Park Farm, Selsey
It is unclear why the policy map shows the proposed strategic allocation lies outside of the Neighbourhood Plan proposed settlement boundary. Some explanation for this anomaly would be helpful in the text.


Groundwater flood risk as depicted by JBA mapping (Brown = seasonal groundwater level lies between 0.025 and 0.5m below the surface).

The principle concern that the LLFA wishes to highlight is the need to ensure that the necessary foul sewerage infrastructure to support development is in place. It is the LLFA understanding that the Siddlesham WWTW experiences capacity issues currently, in part exacerbated by groundwater infiltration. While Policy AL12 states: Development proposals will need to demonstrate that sufficient capacity will be available within the sewer network, including waste water treatment works, to accommodate the proposed development in accordance with Policy S31.

The policy proposes only to provide 'pedestrian links between the site and new development south of Park Lane'. It is considered that cycling links should also be provided.


Policy DM8: Transport, Accessibility and Parking
The PROW network can provide vital means for communities to interact and encourage sustainable local access. The policy requirement to create 'links between new development and existing pedestrian, cycle and public transport networks' is welcomed. However, establishing links into surrounding existing development should not be overlooked also - the greater the permeability, the greater the use.


Policy DM10: New Employment Sites
Whilst mentioned earlier in the Plan in respect of a number of specific sites, this policy should specifically aim to provide, as a matter of course, suitable walking and cycling infrastructure to encourage local sustainable access. This infrastructure may need to extend outside a site boundary so as to provide safe and convenient connection to existing infrastructure. This principle should apply also to Policy DM13: Built Tourist and Leisure Development and Policy DM14: Caravan and Camping Sites.


Policy DM32: Green Infrastructure
Whilst it is recognised the policy proposes support subject to not 'dissect[ing] ... the linear network of cycle ways, public rights of way, bridleways ...', the policy could lend support to establishing new routes as part of the Green Infrastructure network itself.


Policy DM35: Equestrian Development
It is appreciated why the Plan would wish to require future equine development to be 'well related to or has improved links to the existing bridleway network'. However, this will add to the pressure of use on the existing bridleway network, which is not extensive outside of the South Downs, so will increase degradation of paths. Future developments must, therefore, accept to contribute in some way, acceptable to the local highway authority, to mitigate the additional impact to be created so all lawful users are not disadvantaged.


Policy DM29: Biodiversity
The measures to safeguard and enhance the biodiversity value of development sites are welcomed, including seeking net biodiversity gain.


Schedule of proposed changes to the policies map
S30a West of City Corridors -suggest title should be West of City Strategic Wildlife Corridors (to match S30b: East of City Strategic Wildlife Corridors. The Strategic Wildlife Corridors are depicted in different colour patterns on the two plans which is somewhat confusing.


Strategic Wildlife Corridors Local Plan Review Background Paper
Proposed Hermitage to Westbourne Strategic Wildlife Corridor
A large area depicted as Biodiversity Opportunity Area (BOA) in Fig. 1 (immediately to the south of the Rivers Ems & Meadows Local Wildlife Site, Westbourne) is in fact housing and forms part of the settlement of Westbourne. You should consider if this land should be included as having potential for biodiversity enhancement.


Glossary
Includes Sites of Nature Conservation Importance (SNCIs) but not Local Wildlife Sites (LWSs). SNCIs are now known as LWSs.

West Sussex County Council Officer Level Response
Introduction
The Chichester Local Plan Review Preferred Approach sets out how the future development in the District will be shaped, excluding the area within the South Downs National Park, up to 2035. It includes the overall development strategy as well as relevant strategic policies to meet the future needs of the area and development management policies to help guide development over the plan period. The Local Plan helps to:
* choose where the development goes;
* protect the character and beauty of the area;
* provide job and housing opportunities so that children can continue to work and live locally;
* support and help to boost the local economy;
* help residents to maintain healthy and active lifestyles; and,
* make sure that there is adequate services, travel options and community facilities.

The Chichester Local Plan was adopted in July 2015. At that time, the Local Plan was approved, but the Government Inspector said that it had to be reviewed again within five years, to make sure that sufficient housing was planned to meet the needs of the area.

The first part of the review process was carried out in June 2017 with an Issues and Options consultation, in which comments were invited regarding the overall development strategy and possible development locations. The Local Plan Review: Preferred Approach is the second stage of the process. It sets out the proposed development strategy and policies for the area to meet future needs.


West Sussex County Council Officer Level Comments
This note sets out West Sussex County Council's (WSCC) officer response to the consultation on the draft Chichester Local Plan Review Preferred Approach. It highlights key issues and suggested changes to which Chichester District Council (CDC) is requested to give consideration. We will continue to work with CDC in preparation of the Local Plan Review and the Infrastructure Delivery Plan regarding WSCC service requirements in order to mitigate planned development.


Minerals and Waste
A steady and adequate supply of minerals and the achievement of sustainable waste management can help to achieve a District or Borough Council's goals in relation to the economy, housing, transport, communications, strategic infrastructure and the environment. Therefore, District and Borough Local Plans should recognise the importance of minerals and waste issues as relevant to the scope of their overall strategies.

We welcome the reference to the adopted Minerals and Waste Local Plans and safeguarding in the document and the requirements in policies where a site is located within a minerals safeguarding area, or near to a safeguarded waste site. There are some missing references to safeguarding of minerals and waste sites for some of the proposed allocations, set out below and request that these references are added. It is also requested that 'Joint' is added into the references for the Joint Minerals Local Plan through the document.

Policy W23 of the Waste Local Plan applies to all Districts & Boroughs, regarding waste management within development and should be referenced in the Chichester Local Plan Review.

AL3 East of Chichester
The site is to the north of the Fuel Depot site allocation in the Waste Local Plan (Policy W10) for a built waste facility as part of a comprehensive redevelopment of the site (including complimentary non-waste uses). The East of Chichester allocation is the land to the north, bisected by the railway line, of the Fuel Depot. Reference should be made to giving consideration to the allocation, and therefore its safeguarding.

AL4 Westhampnett/North East Chichester
Reference should be made to minerals safeguarding, for consistency with other allocations, as within the sharp sand and gravel safeguarding area.

AL5 Southern Gateway
Reference should be made to the mineral infrastructure safeguarding policy M10 as within 200m of the Chichester Railhead.

AL6 South-West of Chichester
Reference should be made to the mineral infrastructure safeguarding policy M10 as within 300m of the Chichester Railhead.

AL7 Highgrove Farm Bosham
Remove reference to minerals safeguarding as the site is not within the safeguarding or consultation area.

AL12 Park Farm Selsey
Reference should be made to minerals safeguarding as site is within the sharp sand and gravel safeguarding area.

Neighbourhood plan allocations
Sites are yet to be allocated though neighbourhood plans. It is considered that the Joint Minerals Local Plan and Waste Local Plan are referenced, particularly with regards to safeguarding policies (M9, M10 and W2) and these documents and policies are given detailed consideration when allocating sites. Development at, adjacent or proximal to existing waste or mineral sites / infrastructure should be the subject to consultation with WSCC.


Connectivity and Sustainable Travel
The County council has worked with the District Council on the preparation of the transport evidence base study undertaken by Peter Brett Associates for the District Council. The recommended transport mitigation strategy, as assessed using the Chichester Area Transport Model has been demonstrated to be capable in principle to prevent the development from resulting in severe residual cumulative impacts on the highways and transport network. However, the recommended strategy has several risks to deliverability and acceptability associated with it, which require further work to be undertaken to demonstrate that the strategy can be implemented in its current form to provide the forecasted mitigation to travel conditions.

There are three locations where new highway alignments are proposed outside of existing highways boundaries. Two of these may include significant earthworks or structures to be delivered, being Stockbridge Link Road and Terminus Road diversion. The cost of the mitigation strategy exceeds a figure which could reasonably be supported by the value of the proposed development developer contributions alone, therefore the delivery of the strategy will depend upon securing of external grant funding to top up developer contributions. WSCC will work with the District Council in supporting and or applying for funding, the District Council needing to secure Highways England to support funding applications for A27 improvements. The proposed junction designs for the A27 Stockbridge and Whyke roundabouts include bans to well used right turn movements off the Chichester A27 bypass which result in significant forecast changes to traffic flows on local roads in the south of Chichester and on the Manhood Peninsular.

There is a need to ensure the land outside the highway boundary is available and the plan should set out how this land will be acquired to deliver the measures, it may be that a commitment to use, if required, and therefore reference to CPO be made in the policy.

Funding for the mitigation strategy is uncertain. It is considered that the Plan should set out how it will deal with this uncertainty. This could include trigger points in the monitoring framework to trigger a change of approach or alternative options to deliver the required development.

These factors mean that feasibility work is necessary to be undertaken prior to Plan submission, to reduce as far as practicable risks to costs, land take, impacts and deliverability of the proposed transport strategy in order to show that the strategy can be implemented within the plan period and that the funding strategy will be sufficient to meet the design requirements. In particular the following will need to be addressed:

* Statutory undertakers equipment under the roads junctions to be impacted.
* Extent of earthworks required to create a vertical and horizontal alignment compliant with design standards. Design audit to identify any required departures from standard.
* Designing for drainage and flooding issues, including compliance with the WSCC LLFA Policy for the Management of Surface Water, November 2018.
* Designs for structures to cross watercourses - Stockbridge Link Road
* Design should include suitable provision for rights of way and footway crossings
* Scoping for whether and at what level further Environmental Impact Assessment will be required.
* Stage 1 Road safety Audit, designers response report and resulting amendments to designs.
* Land take required after feasibility level designs have been developed and availability of required land.
* Wophams Lane - impacts of forecast changes to flow patterns to take B2201 southbound traffic on requirements for highway width, alignment, footway provision and junctions with A286 Birdham Road and B2201 Selsey Road; design solution required.
* Quarry Lane, Kingsham Avenue /Road, Terminus Road; impacts of forecast flow changes on highway users, residential and commercial frontagers and measures to manage through traffic whilst maintaining local access

Sustainable transport measures will also be required to mitigate planned development. These will be identified through more detailed assessments of sites including pre-application consideration. Funding will need to be identified through development and other sources as well in some cases.

Public Rights of Way
There is support for the Local Plan Review's approach to Public Rights Of Way (PROW), not just for the potential to impact on existing public off-road access but also the opportunity it brings to enhance this access for the benefit of future residents, communities and visitors. PROW deliver benefits for personal health and wellbeing; sustainable transport; reduction of air pollution and road congestion; are able to support local economies; and they connect communities.
WSCC PROW welcomes several aspects of the Vision statement, which give support to the protection and enhancement of the PROW network, and provision of safe and convenient off-road access opportunities for residents and visitors:

* Pursue a healthy lifestyle and benefit from a sense of well-being supported by good access to education, health, leisure, open space and nature, sports and other essential facilities;
* Live in sustainable neighbourhoods supported by necessary infrastructure and facilities;
* Move around safely and conveniently with opportunities to choose alternatives to car travel.

The Local Plan Strategic Objectives offer further support to enhance off-road access, particularly to 'Encourage healthy and active lifestyles for all, developing accessible health and leisure facilities and linked green spaces'. However, the objective to 'Achieve a sustainable and integrated transport system through improved cycling networks and links to public transport' should recognise walking also as an important mode for many people; some strategic enhancements will significantly improve walkers' safety and convenience.

It is considered that West of Chichester the A259 could act as a corridor for increased volumes of non-motorised access, particularly cycling. Improvement of the existing on-road facility and development of a various 'feeder' routes to connect with the many settlements, perhaps using quiet lanes in places, would encourage cycling particularly to be a natural alternative to vehicle use. Policy S18: Integrated Coastal Zone Management for the Manhood Peninsula, gives regard to such an ambition in stating it will 'Improve infrastructure to support sustainable modes of transport, especially cycle ways, bridleways and footpaths, including the National Coastal Footpath'.

The National Planning Policy Framework (NPPF) Open Space and Recreation, para 97b) states:
the loss resulting from the proposed development would be replaced by equivalent or better provision in terms of quantity and quality in a suitable location.
The NPPF para 98 also states:
Planning policies and decisions should protect and enhance public rights of way and access, including taking opportunities to provide better facilities for users, for example by adding links to existing rights of way networks including National Trails.'
There is support for Policy S20: Design, that recognises these requirements in stating development 'is well connected to provide safe and convenient ease of movement by all users, prioritising pedestrian and cycle movements both within the scheme and neighbouring areas and ensuring that the needs of vehicular traffic does not dominate at the expense of other modes of transport, or undermine the resulting quality of places' and 'incorporates and/or links to high quality Green Infrastructure and landscaping to enhance biodiversity and meet recreational needs, including public rights of way'.


Education
As the local education authority, WSCC has the statutory duty to ensure that there is a sufficient supply of suitable school places to meet statutory requirements for early years, primary, secondary and sixth form provision (including up to age 25 for those with special educational needs and/or disabilities). Education infrastructure, or contributions to provide infrastructure, will be required in order to mitigate proposed development. We will continue to work with CDC in preparation of the Local Plan Review and the Infrastructure Delivery Plan regarding education and other service requirements in order to mitigate planned development.

The table below sets out the primary, secondary school and sixth form requirements to mitigate proposed development. SEE ATTACHMENT FOR TABLE

AL1 Land West of Chichester

It should be noted that phase one of this development will provide the primary school with the core of the building being built to the specification for a 2 form entry (FE) school and 1FE teaching accommodation. Phase 2 as per 6.10 on page 93 should include expansion of the primary school for the further 1FE of teaching accommodation.

AL2 Land at Shopwhyke (Oving Parish)

No update to original response for this allocation is required.

AL3 Land East of Chichester - previously South of Shopwhyke

At the current time pupil place planning indicates that there is insufficient space within the primary schools that serve this proposed development. Further capacity would be required to accommodate the development. Land for a 1 FE expandable to 2FE and pro rata share of the build costs would be required.

If numbers were to increase on the east side of the city, education provision will need to be reviewed, potentially a further 1FE may be required including land provision, this could be in the form of an expansion or a new school being built capable of expansion to 3FE.

At the current time pupil place planning indicates that there would be expansion capacity to accommodate the child product from this proposed development for secondary aged pupils. Contributions would be required for expansion of secondary schools if feasible and required.

At the current time pupil place planning indicates that there would be expansion capacity to accommodate the child product from this proposed development for sixth form pupils. Contributions would be required for expansion of the provision if feasible and required.

AL4 Land at Westhampnett / North East Chichester

The remaining 200 dwellings will impact on the education provision in the area, financial contributions towards expansion of existing or pro rata costs towards the expansion of the school within AL3.

At the current time pupil place planning indicates that there would be expansion capacity to accommodate the child product from this proposed development for secondary aged pupils. Contributions would be required for expansion of secondary schools if feasible and required.

At the current time pupil place planning indicates that there would be expansion capacity to accommodate the child product from this proposed development for sixth form pupils. Contributions would be required for expansion of the provision if feasible and required.

AL5 Southern Gateway

At the current time pupil place planning indicates that there would be sufficient space or expansion capacity to accommodate the child product from the strategic allocation of 350 dwellings in the Southern Gateway. However, consideration should be given to the cumulative impact of housing in the area Land South West of Chichester (AL6) to allocate land within the area for a 1FE expandable to 2FE primary school. Pro rata financial contributions towards the build costs would be sought from developers to mitigate their impact.

At the current time pupil place planning indicates that there would be expansion capacity to accommodate the child product from this proposed development for secondary aged pupils. Contributions would be required for expansion of secondary schools if feasible and required.

At the current time pupil place planning indicates that there would be expansion capacity to accommodate the child product from this proposed development for sixth form pupils. Contributions would be required for expansion of the provision if feasible and required.

AL6 Land South West of Chichester (Apuldram & Donnington Parishes)

It should be noted that the primary education provision in this area is either in Chichester City Centre which means crossing the main A27 or by travelling south towards the peninsula. Consideration should be given to the cumulative impact of further housing in the area along with the Southern Gateway allocation (AL5) to allocate land within the strategic allocation site for a 1FE expandable to 2FE primary school. Pro rata financial contributions towards the build costs would be sought from developers to mitigate their impact.

At the current time pupil place planning indicates that there would be expansion capacity to accommodate the child product from this proposed development for secondary aged pupils. Contributions would be required for expansion of secondary schools if feasible and required.

At the current time pupil place planning indicates that there would be expansion capacity to accommodate the child product from this proposed development for sixth form pupils. Contributions would be required for expansion of the provision if feasible and required.

AL7 Bosham

The current primary provision serving the area is at capacity, expansion of the school on its existing site is not possible. As part of the strategic allocation, it is proposed that land for a 2FE primary school be provided. The strategic allocation of 250 dwellings in isolation does not require a new school to be built. Certainty over the land allocation and sufficient funding will be key drivers in realising this proposal.

AL7, AL10 and AL13 are all within the same school planning area, the cumulative total of the strategic allocations brings forward a requirement for c3 forms of entry additional school places. The Local Plan, as currently drafted, indicates an oversupply of school places which could affect the viability of all the schools in the planning area.

Expansion of the secondary school may be possible. Contributions would be required for expansion of secondary schools if feasible and required.

AL9 Fishbourne

The primary school serving the area is currently at capacity, expansion of the school may be possible, feasibility / options appraisals would need to be undertaken.

At the current time pupil place planning indicates that there would be sufficient space or expansion capacity to accommodate the child product from this proposed development for secondary aged pupils. Contributions would be required for expansion of primary and secondary schools and sixth form if feasible and required.

AL8 East Wittering

At the current time pupil place planning indicates that there would be sufficient space or expansion capacity to accommodate the child product from this proposed development.

Contributions would be required for expansion of primary and secondary schools if feasible and required.

AL10 Chidham and Hambrook area

The current primary provision serving the area is at capacity, expansion of the school on its existing site is not possible. As part of the strategic allocation, it is proposed that land for a 2FE primary school be provided. Certainty over the land allocation and sufficient funding will be key drivers in realising this proposal.

AL7, AL10 and AL13 are all within the same school planning area, the cumulative total of the strategic allocations brings forward a requirement for c3 forms of entry additional school places. The Local Plan, as currently drafted, indicates an oversupply of school places which could affect the viability of all the schools in the planning area.

Expansion of the secondary school may be possible. Contributions would be required for expansion of secondary schools if feasible and required.

AL11 Hunston

Any development within this area cannot currently be accommodated in the existing primary school at North Mundham. Further capacity would be required to accommodate the development, CDC will need to work with WSCC to determine how additional capacity in the area could be accommodated if land is to be allocated.

At the current time pupil place planning indicates that there would be sufficient space or expansion capacity to accommodate the child product from this proposed development for secondary aged pupils. Contributions would be required for expansion of secondary schools and sixth form if feasible and required.

AL12 Selsey

Further capacity would be required to accommodate the development. Contributions (and possibly land if required) would be sought to meet the pupil product from the development in the most appropriate form once this can be clarified.

At the current time pupil place planning indicates that there would be sufficient space to accommodate the child product from this proposed development for secondary aged pupils. Contributions would be required for expansion of secondary schools if feasible and required.

AL13 Southbourne

At the current time pupil place planning indicates that there is insufficient space within the primary schools that serve this proposed development. Further capacity would be required to accommodate the development. Land for a 2form entry expandable to 3FE primary school and pro rata share of the build costs would be required.

AL7, AL10 and AL13 are all within the same school planning area, the cumulative total of the strategic allocations brings forward a requirement for c3 forms of entry additional school places. The Local Plan, as currently drafted, indicates an oversupply of school places which could affect the viability of all the schools in the planning area.

Expansion of the secondary school may be possible. Contributions would be required for expansion of secondary schools if feasible and required.

AL14 Tangmere

The current allocation of 1,300 dwellings will bring forward the requirement for land for a 1FE expandable to 2FE and financial contributions would be sought to meet the pupil product from the development in the most appropriate form once this can be clarified.

At the current time pupil place planning indicates that there would be sufficient space or expansion capacity to accommodate the child product from this proposed development for secondary aged pupils. Contributions would be required for expansion of secondary schools and sixth form if feasible and required.

Footnote: - if all of the proposed sites were to come forward the secondary school and sixth form provision would be full in the Chichester Planning Area. Expansion of the secondary schools in the Chichester Planning Area to cater for the increased demand would need to be sought from the academy sponsors, where appropriate and the Local Authority.


Lead Local Flood Authority
The Lead Local Flood Authority (LLFA) is concerned about the approach being taken with regard to ensuring potential wastewater treatment for proposed new sustainable development.

Paragraph 8 of the NPPF states:
8. Achieving sustainable development means that the planning system has three overarching objectives, which are interdependent and need to be pursued in mutually supportive ways (so that opportunities can be taken to secure net gains across each of the different objectives):

a) An economic objective - to help build a strong, responsive and competitive
economy, by ensuring that sufficient land of the right types is available in the
right places and at the right time to support growth, innovation and improved
productivity; and by identifying and coordinating the provision of infrastructure;

Paragraph 20 of the NPPF states:
20. Strategic policies should set out an overall strategy for the pattern, scale and quality of development, and make sufficient provision for:
a) housing (including affordable housing), employment, retail, leisure and other commercial development;
b) infrastructure for transport, telecommunications, security, waste management, water supply, wastewater, flood risk and coastal change management, and the provision of minerals and energy (including heat);

In the LLFAs view, the Local Plan Review is not setting out an overall strategy for the pattern, scale and quality of development in relation to arrangements for wastewater management. The LLFA considers that CDC needs to go further in incorporating within the Local Plan Review how this provision is being made.


Additional Policy Comments

Policy S12: Infrastructure Provision
Support the requirement that all development must provide or fund new infrastructure, facilities and services required, both on and off-site (including full fibre communications infrastructure) as a consequence of the proposal. The explicit reference to full fibre communications infrastructure is supported as this will provide gigabit-capable and future-proofed services to all development, existing and new. The reference to provision of facilities and services on and off-site is also supported as in the case of broadband for example, all development will be adequately equipped with the necessary infrastructure installed for the purposes of connecting to full fibre gigabit-capable broadband services. This policy supports the County Council's aim for increased digital infrastructure that will provide for gigabit-capable broadband and future technologies such as 5G.

Support the reference to safeguarding educational facilities under section 3 of the policy.

The policy includes the requirement to 'Facilitate accessibility to facilities and services by a range of transport modes'. PROW can offer vital access means for walkers and cyclists, such as for employment land use (e.g. commuting by bicycle) and in support of the high street, both for employees and customers. IT is considered that this Policy, also Policy S13: Chichester City Development Principles, should aim to encourage such access to be the natural and preferred modes of access, thereby helping achieve the benefits previously described. It is noted Policy S14: Chichester City Transport Strategy, does acknowledge cycling and walking and lends support to their improvement.

The supporting text, paragraph 4.81 makes reference to the Strategic Infrastructure Package (SIP). It is requested that this wording is removed and replaced with West Sussex County Council identifies service infrastructure requirements necessary to support new and existing communities, where strategic development and growth is proposed in Local Plans. These are required to deliver the County Council's statutory responsibilities, strategic objectives and current policy and feed into the preparation of the Infrastructure Delivery Plan.


Policy S13: Chichester City Development Principles
This policy, like policy S12, it is considered should aim to encourage such access to be the natural and preferred modes of access, thereby helping achieve the benefits previously described. It is noted Policy S14: Chichester City Transport Strategy, does acknowledge cycling and walking and lends support to their improvement.


Policy S23: Transport and Accessibility
The policy and supporting text paragraphs 5.15 - 5.33 refer to Transport Infrastructure. Understandably much consideration is given to the A27 around Chichester; however, in addition to seeking new infrastructure from new development, it is recommended support in principle is given to maximising the value of existing infrastructure so as to facilitate off-road user modes accessing either side of the A27.


S24: Countryside
Supporting text paragraphs 5.34 - 5.43, acknowledges 'it is necessary to provide for the social and economic needs of small rural communities, and enable those who manage, live and work in the countryside to continue to do so'. It is recognised in para 7.205, supporting text to policy SM35 Equestrian Development, the high numbers of liveried and stabled horses. A considerable network of businesses are supported by such a high equine population, and in addition to financial value within the local community there is considerable benefit in terms of health and wellbeing of individuals. It is suggested that Policy S24: Countryside, could recognise this specifically.


S27: Flood Risk Management
Supporting text paragraph 5.54, requested amendments underlined - as a consequence of the rise in sea levels and storm surges, parts of the plan area will be at increased risk from coastal erosion, groundwater, fluvial and/or tidal flooding. Hard defences may not be possible to maintain in the long term, therefore development needs to be strongly restricted in areas at risk to flooding and erosion, whilst ensuring that existing towns and villages are protected by sustainable means that make space for water in suitable areas. Development must take account of the policies of the relevant shoreline management plan

Supporting text paragraph 5.58, requested amendments underlined - Built development can lead to increased surface water run-off; therefore new
development is encouraged to incorporate mitigation techniques in its design, such as permeable surfaces and Sustainable Drainage Systems (SuDS). Where appropriate, SuDS should be used as part of the linked green infrastructure network to provide multiple functions and benefits to landscape quality, recreation and biodiversity. This can be achieved through habitat creation, new open spaces and good design. SuDS should be designed to help cope with intense rainfall events and to overcome any deterioration in water quality status. In determining the suitability of SuDS for individual development sites, developers should refer to guidance published by the Lead Local Flood Authority (LLFA): West Sussex LLFA Policy for the Management of Surface Water: https://www.westsussex.gov.uk/media/12230/ws_llfa_policy_for_management_of_surface_water.pdf and, if necessary, seek further advice from the Lead Local Flood Authority LLFA.

S27 policy text requested amendments underlined for section 1 - a. through a sequential approach, taking into consideration all forms of flooding, it is located in the lowest appropriate flood risk location in accordance with the NPPF and the Chichester Strategic Flood Risk Assessment (SFRA); and

S27 policy text requested amendments underlined for section 2. Sustainable drainage systems (SuDS) will be required on major developments (10 or more dwellings or equivalent) and encouraged for smaller schemes. SUDS should be designed into the landscape of all new development and should be included as part of a District wide approach to improve water quality and provide flood mitigation. A site-specific Flood Risk Assessment will be required for sites within or adjacent to areas at risk of surface water flooding as identified in the SFRA. There should be no increase in either the volume or rate of surface water runoff leaving the site.

S27 policy text requested additional bullet point as number 4 - Clear management arrangements and funding for their ongoing maintenance over the lifetime of the development should be proposed. Planning conditions and / or obligations will be used to secure these arrangements.

S27 policy text requested amendments underlined for section 2, but would be section 5 - Development should not result in any property or highway, on or off site, being at greater risk of flooding than the 1 in 100 year storm return period, including an allowance for climate change.


Policy S29: Green Infrastructure
The Green Infrastructure policy is welcomed, including provision of new Green Infrastructure as an integral part of the development at Strategic Development Locations. It is recommended that measures are put in place to secure the long term management of such Green Infrastructure.


Policy S30: Strategic Wildlife Corridors
The identification of Strategic Wildlife Corridors and inclusion of a policy to safeguard them from development is welcomed. It is recommended that CDC promotes positive conservation management within these corridors to maximise their contribution to maintaining and enhancing biodiversity. As stated in Section 5.66, 'These corridors do not stop at the plan area boundaries.' Thus, it is recommended that CDC works in partnership with Chichester Harbour Conservancy and The South Downs National Park Authority to ensure that these Strategic Wildlife Corridors continue to provide effective corridors and connectivity across the wider landscape.

Section 5.66 refers to four Strategic Wildlife Corridors connecting Chichester Harbour with the South Downs National Park but it is noted that there is no mention of the Strategic Wildlife Corridors to the east of Chichester which connect Pagham Harbour with the South Downs National Park (as seen in Policy Map S30b). It is also noted that the maps referred to in Section 5.66, Maps 5.1 & 5.2 are missing.

WSCC and CDC promoted a Mitigated Northern Route for the A27 at Chichester as the preferred option, subject to the inclusion of important mitigation measures that are needed to make the scheme acceptable in environmental terms and the 'full southern route' as a reasonable alternative. Both routes could impact on the identified Strategic Wildlife Corridors. As currently drafted, Policy S30 would seem to prevent a mitigated northern route from coming forward in the future. Therefore, the District Council should consider whether the policy is overly restrictive (for example should it refer to 'significant adverse impacts' or 'unacceptable adverse impacts'?) and how it would be applied if a northern route for A27 were to come forward in the future.


Policy S31: Wastewater Management and Water Quality
S27 policy text requested amendments underlined for section 3, this - Where appropriate, development should contribute to the delivery of identified actions to deliver infiltration reduction across the catchment. Where appropriate development should contribute to the delivery of identified actions to deliver a reduction in the level of infiltration of groundwater into the sewer system.


Policy AL1: Land West of Chichester
AL1 policy text requested additional bullet point as number 8 - Increase capacity to attenuate surface water on site, thereby reducing the discharge flows off the site below current rates and reducing the risk of flooding to residential areas downstream.

AL1 policy text requested additional bullet point under 15 as 15 b- Provide mitigation for any loss of watercourse habitat resulting from culverting for highway provision in the development;

AL1 policy text in supporting 'improved cycle and pedestrian routes linking the site with the city, Fishbourne and the South Downs National Park', a new key link for cycling will be to Salthill Road, thereby enabling cyclists to benefit from the existing bridge crossing of the A27 for journeys to and from the west.


AL2: Land at Shopwyke (Oving Parish)
The policy acknowledges need 'for foot/cycle bridge across A27 to Coach Road'. There is also need for equestrian users to cross the A27 and WSCC PROW has received several enquiries seeking support for such infrastructure. Consideration could be given to the proposed bridge providing for all three modes.


AL3: East of Chichester (Oving Parish)
AL3 supporting text requested amendments underlined for paragraph 6.22 - The site is identified for 600 dwellings, however, there may be potential to deliver a large strategic development of 1000 dwellings, subject to further evidence, including the testing of additional growth on the local highway network and capacity of the site to provide flood risk attenuation for the increased housing density. The site should be master planned as a whole, and delivered through a phased development over a ten year period. Although the site is physically separated from the city by the A27 Chichester Bypass, the development should form a planned extension to the city, forming a new neighbourhood. This will involve opportunities to provide new facilities to serve the wider local community with good off-site access, particularly by walking and cycling to existing local facilities and facilities in the city.

AL3 policy requires exploring integrated green infrastructure with other strategic sites to the north east of the city, Tangmere and the wider countryside. It is considered that future residents will have expectations for provision of safe and convenient links towards Oving and also across the railway to link to the A259 cycle path and PROW south of the A259. It is considered that the policy should be strengthened to ensure such provision.


Policy AL4: Land at Westhampnett/North East Chichester
AL4 policy text requested amendments underlined for section 3 - Open space and green infrastructure, including a linear greenspace with public access along the Lavant Valley.

Taking into account the site-specific requirements, proposals for the site should satisfy the following requirements:

Policy AL4 policy, it is welcomed that 'provision should be made for green links to the South Downs National Park and Chichester City.' Safe and convenient walking and cycling to Lavant, from where people will access the South Downs, will provide for sustainable transport use.


Policy AL5 Southern Gateway
AL5 supporting text requested amendments underlined for paragraph 6.38 - The area has been identified as suitable for comprehensive regeneration with the aim being to make it a more attractive and welcoming gateway for the city, providing new housing, business and retail space and leisure and tourism facilities. Opportunities will be identified to improve transport links with a focus on cycling, walking and public transport and the removal of non-essential traffic from the area. There is also scope for significant public space enhancements and new landscaping incorporating blue / green infrastructure delivering multi-functional benefits.

AL5 policy text requested amendments underlined for section 5 - Provision of open space that:
* Is in accordance with Policy DM34, including retention of the existing playing pitch unless suitable re-provision is provided;
* Reinforces / enhances green and blue infrastructure consistent with Policy S29 and fully exploits the opportunities for sustainable drainage.


AL5 policy text requested amendments underlined for section 8 - Provision of both a surface and waste water management plan which demonstrates no net increase in flow to Apuldram Waste Water Treatment Works would result from this development, unless suitable alternative provision is agreed;


Policy AL6: Land South-West of Chichester (Apuldram and Donnington Parishes)
The LLFA has concerns regarding the lack of reference to flood risk constraints of the site in Policy AL6. There is reference to flood risk in paragraph 6.47. However, the policy itself makes no reference to these constraints.
The constraints arise from a combination of the following:

* Current tidal /fluvial flood risk extending from Chichester harbour to the west and up the River Lavant floodplain; (Map 1)
* Future tidal /fluvial flood risk associated with climate change; (Map 1)
* Constraints on infiltration of surface water run off because of high seasonal groundwater levels (<0.025m below the surface) (Map 2); and
* Constraints on gravity outfalls because of the low relief and long-term reduction in tidal window for discharge.

The above limits the options for how the site can be effectively drained without a step change from typically employed methods to embrace more innovative and currently expensive options e.g. blue roofs and rainwater harvesting.

The LLFA recommends that the policy sets out both the above constraints and the type of innovative drainage that will be required to achieve the development objectives for the site.



Key: Projected medium projection extent of SLR based upon 4m contour

AL6 extent

Current Flood Zone 3 extent.

Current Areas of high (1:30) surface water flood risk

Map 1 Existing and projected Tidal and surface water flood risk for AL6.

Consistent with paragraph 3.2 of the SFRA, given the high risk of flooding both now and into the future for this site, it is recommended that CDC gives consideration to the climate change maps to understand how the flood zones are predicted to change over the lifetime of the development.


Key:
AL6 boundary.

Groundwater levels are either at very near (within 0.025m of) the ground surface.

Groundwater levels are between 0.025m and 0.5m below the ground surface

Map 2 Groundwater flood risk JBA

Policy AL6 WSCC PROW considers 'necessary highway improvements to adequately mitigate the likely impacts on the highway network' to include a bridge crossing of the A27 for convenient walking and cycling access to the Terminus Road industrial estate and the city. There is an existing public footpath but, as this crosses the A27 at-grade, this will not provide the safest facility and not encourage people to minimise use of vehicles for local access. Provision of a bridge and access through the site could also establish a valuable link to the popular Salterns Way walking and cycle path. An additional link to Salterns Way should also be provided off the A286 for the benefit of Stockbridge residents as a safer alternative to the A286.


AL 7 Highgrove Farm, Bosham
The LLFA notes that the above site has the potential for a moderate risk of groundwater flooding. It is likely that this is perched groundwater draining from higher ground / springs to the north that lies in the superficial mixed sediments underlain by Lambeth Clay.


Policy AL8: East Wittering Parish
Due to no information on where housing is going to be located so the LLFA is not in a position to comment on proposed housing allocation sites at this stage.

The policy requires 'Opportunities ... for the expansion and provision of green infrastructure into the wider countryside including between settlements and facilities'. Existing and future residents and the local visitor economy would benefit by delivery of an off-road route for walkers, cyclists and horse riders to and from the Medmerry development and towards Selsey. It is considered that Policy AL8 should aim to deliver this enhancement specifically.


Policy AL9: Fishbourne Parish
Due to no information on where housing is going to be located so the LLFA is not in a position to comment on proposed housing allocation sites at this stage.

It is considered that off-road cycling links to land West of Chichester (off Salthill Road) and to Bosham (off Park Lane) would benefit this community with enhanced sustainable connectivity.


Policy AL10: Chidham and Hambrook Parish
Due to no information on where housing is going to be located so the LLFA is not in a position to comment on proposed housing allocation sites at this stage.

The policy requires 'opportunities' to develop green infrastructure and links to other communities. An opportunity, in conjunction with Highways England, exists to maximise the value of existing infrastructure by creating a new bridleway (for walkers, cyclists and horse riders) on a path using an existing A27 overbridge.


Policy AL11: Hunston Parish
Due to no information on where housing is going to be located so the LLFA is not in a position to comment on proposed housing allocation sites at this stage.

The village is already well connected for walkers to access the surrounding countryside but there are presently no local cycling or horse riding facilities on the PROW network. A bridleway link to South Mundham (with the potential for future cycle links to Pagham and towards Bognor Regis) and to Sidlesham via the golf course and Brimfast Lane would provide residents and visitors with improved access to the countryside and services.


Policy AL12: Land North of Park Farm, Selsey
It is unclear why the policy map shows the proposed strategic allocation lies outside of the Neighbourhood Plan proposed settlement boundary. Some explanation for this anomaly would be helpful in the text.


Groundwater flood risk as depicted by JBA mapping (Brown = seasonal groundwater level lies between 0.025 and 0.5m below the surface).

The principle concern that the LLFA wishes to highlight is the need to ensure that the necessary foul sewerage infrastructure to support development is in place. It is the LLFA understanding that the Siddlesham WWTW experiences capacity issues currently, in part exacerbated by groundwater infiltration. While Policy AL12 states: Development proposals will need to demonstrate that sufficient capacity will be available within the sewer network, including waste water treatment works, to accommodate the proposed development in accordance with Policy S31.

The policy proposes only to provide 'pedestrian links between the site and new development south of Park Lane'. It is considered that cycling links should also be provided.


Policy DM8: Transport, Accessibility and Parking
The PROW network can provide vital means for communities to interact and encourage sustainable local access. The policy requirement to create 'links between new development and existing pedestrian, cycle and public transport networks' is welcomed. However, establishing links into surrounding existing development should not be overlooked also - the greater the permeability, the greater the use.


Policy DM10: New Employment Sites
Whilst mentioned earlier in the Plan in respect of a number of specific sites, this policy should specifically aim to provide, as a matter of course, suitable walking and cycling infrastructure to encourage local sustainable access. This infrastructure may need to extend outside a site boundary so as to provide safe and convenient connection to existing infrastructure. This principle should apply also to Policy DM13: Built Tourist and Leisure Development and Policy DM14: Caravan and Camping Sites.


Policy DM32: Green Infrastructure
Whilst it is recognised the policy proposes support subject to not 'dissect[ing] ... the linear network of cycle ways, public rights of way, bridleways ...', the policy could lend support to establishing new routes as part of the Green Infrastructure network itself.


Policy DM35: Equestrian Development
It is appreciated why the Plan would wish to require future equine development to be 'well related to or has improved links to the existing bridleway network'. However, this will add to the pressure of use on the existing bridleway network, which is not extensive outside of the South Downs, so will increase degradation of paths. Future developments must, therefore, accept to contribute in some way, acceptable to the local highway authority, to mitigate the additional impact to be created so all lawful users are not disadvantaged.


Policy DM29: Biodiversity
The measures to safeguard and enhance the biodiversity value of development sites are welcomed, including seeking net biodiversity gain.


Schedule of proposed changes to the policies map
S30a West of City Corridors -suggest title should be West of City Strategic Wildlife Corridors (to match S30b: East of City Strategic Wildlife Corridors. The Strategic Wildlife Corridors are depicted in different colour patterns on the two plans which is somewhat confusing.


Strategic Wildlife Corridors Local Plan Review Background Paper
Proposed Hermitage to Westbourne Strategic Wildlife Corridor
A large area depicted as Biodiversity Opportunity Area (BOA) in Fig. 1 (immediately to the south of the Rivers Ems & Meadows Local Wildlife Site, Westbourne) is in fact housing and forms part of the settlement of Westbourne. You should consider if this land should be included as having potential for biodiversity enhancement.


Glossary
Includes Sites of Nature Conservation Importance (SNCIs) but not Local Wildlife Sites (LWSs). SNCIs are now known as LWSs.

West Sussex County Council Officer Level Response
Introduction
The Chichester Local Plan Review Preferred Approach sets out how the future development in the District will be shaped, excluding the area within the South Downs National Park, up to 2035. It includes the overall development strategy as well as relevant strategic policies to meet the future needs of the area and development management policies to help guide development over the plan period. The Local Plan helps to:
* choose where the development goes;
* protect the character and beauty of the area;
* provide job and housing opportunities so that children can continue to work and live locally;
* support and help to boost the local economy;
* help residents to maintain healthy and active lifestyles; and,
* make sure that there is adequate services, travel options and community facilities.

The Chichester Local Plan was adopted in July 2015. At that time, the Local Plan was approved, but the Government Inspector said that it had to be reviewed again within five years, to make sure that sufficient housing was planned to meet the needs of the area.

The first part of the review process was carried out in June 2017 with an Issues and Options consultation, in which comments were invited regarding the overall development strategy and possible development locations. The Local Plan Review: Preferred Approach is the second stage of the process. It sets out the proposed development strategy and policies for the area to meet future needs.


West Sussex County Council Officer Level Comments
This note sets out West Sussex County Council's (WSCC) officer response to the consultation on the draft Chichester Local Plan Review Preferred Approach. It highlights key issues and suggested changes to which Chichester District Council (CDC) is requested to give consideration. We will continue to work with CDC in preparation of the Local Plan Review and the Infrastructure Delivery Plan regarding WSCC service requirements in order to mitigate planned development.


Minerals and Waste
A steady and adequate supply of minerals and the achievement of sustainable waste management can help to achieve a District or Borough Council's goals in relation to the economy, housing, transport, communications, strategic infrastructure and the environment. Therefore, District and Borough Local Plans should recognise the importance of minerals and waste issues as relevant to the scope of their overall strategies.

We welcome the reference to the adopted Minerals and Waste Local Plans and safeguarding in the document and the requirements in policies where a site is located within a minerals safeguarding area, or near to a safeguarded waste site. There are some missing references to safeguarding of minerals and waste sites for some of the proposed allocations, set out below and request that these references are added. It is also requested that 'Joint' is added into the references for the Joint Minerals Local Plan through the document.

Policy W23 of the Waste Local Plan applies to all Districts & Boroughs, regarding waste management within development and should be referenced in the Chichester Local Plan Review.

AL3 East of Chichester
The site is to the north of the Fuel Depot site allocation in the Waste Local Plan (Policy W10) for a built waste facility as part of a comprehensive redevelopment of the site (including complimentary non-waste uses). The East of Chichester allocation is the land to the north, bisected by the railway line, of the Fuel Depot. Reference should be made to giving consideration to the allocation, and therefore its safeguarding.

AL4 Westhampnett/North East Chichester
Reference should be made to minerals safeguarding, for consistency with other allocations, as within the sharp sand and gravel safeguarding area.

AL5 Southern Gateway
Reference should be made to the mineral infrastructure safeguarding policy M10 as within 200m of the Chichester Railhead.

AL6 South-West of Chichester
Reference should be made to the mineral infrastructure safeguarding policy M10 as within 300m of the Chichester Railhead.

AL7 Highgrove Farm Bosham
Remove reference to minerals safeguarding as the site is not within the safeguarding or consultation area.

AL12 Park Farm Selsey
Reference should be made to minerals safeguarding as site is within the sharp sand and gravel safeguarding area.

Neighbourhood plan allocations
Sites are yet to be allocated though neighbourhood plans. It is considered that the Joint Minerals Local Plan and Waste Local Plan are referenced, particularly with regards to safeguarding policies (M9, M10 and W2) and these documents and policies are given detailed consideration when allocating sites. Development at, adjacent or proximal to existing waste or mineral sites / infrastructure should be the subject to consultation with WSCC.


Connectivity and Sustainable Travel
The County council has worked with the District Council on the preparation of the transport evidence base study undertaken by Peter Brett Associates for the District Council. The recommended transport mitigation strategy, as assessed using the Chichester Area Transport Model has been demonstrated to be capable in principle to prevent the development from resulting in severe residual cumulative impacts on the highways and transport network. However, the recommended strategy has several risks to deliverability and acceptability associated with it, which require further work to be undertaken to demonstrate that the strategy can be implemented in its current form to provide the forecasted mitigation to travel conditions.

There are three locations where new highway alignments are proposed outside of existing highways boundaries. Two of these may include significant earthworks or structures to be delivered, being Stockbridge Link Road and Terminus Road diversion. The cost of the mitigation strategy exceeds a figure which could reasonably be supported by the value of the proposed development developer contributions alone, therefore the delivery of the strategy will depend upon securing of external grant funding to top up developer contributions. WSCC will work with the District Council in supporting and or applying for funding, the District Council needing to secure Highways England to support funding applications for A27 improvements. The proposed junction designs for the A27 Stockbridge and Whyke roundabouts include bans to well used right turn movements off the Chichester A27 bypass which result in significant forecast changes to traffic flows on local roads in the south of Chichester and on the Manhood Peninsular.

There is a need to ensure the land outside the highway boundary is available and the plan should set out how this land will be acquired to deliver the measures, it may be that a commitment to use, if required, and therefore reference to CPO be made in the policy.

Funding for the mitigation strategy is uncertain. It is considered that the Plan should set out how it will deal with this uncertainty. This could include trigger points in the monitoring framework to trigger a change of approach or alternative options to deliver the required development.

These factors mean that feasibility work is necessary to be undertaken prior to Plan submission, to reduce as far as practicable risks to costs, land take, impacts and deliverability of the proposed transport strategy in order to show that the strategy can be implemented within the plan period and that the funding strategy will be sufficient to meet the design requirements. In particular the following will need to be addressed:

* Statutory undertakers equipment under the roads junctions to be impacted.
* Extent of earthworks required to create a vertical and horizontal alignment compliant with design standards. Design audit to identify any required departures from standard.
* Designing for drainage and flooding issues, including compliance with the WSCC LLFA Policy for the Management of Surface Water, November 2018.
* Designs for structures to cross watercourses - Stockbridge Link Road
* Design should include suitable provision for rights of way and footway crossings
* Scoping for whether and at what level further Environmental Impact Assessment will be required.
* Stage 1 Road safety Audit, designers response report and resulting amendments to designs.
* Land take required after feasibility level designs have been developed and availability of required land.
* Wophams Lane - impacts of forecast changes to flow patterns to take B2201 southbound traffic on requirements for highway width, alignment, footway provision and junctions with A286 Birdham Road and B2201 Selsey Road; design solution required.
* Quarry Lane, Kingsham Avenue /Road, Terminus Road; impacts of forecast flow changes on highway users, residential and commercial frontagers and measures to manage through traffic whilst maintaining local access

Sustainable transport measures will also be required to mitigate planned development. These will be identified through more detailed assessments of sites including pre-application consideration. Funding will need to be identified through development and other sources as well in some cases.

Public Rights of Way
There is support for the Local Plan Review's approach to Public Rights Of Way (PROW), not just for the potential to impact on existing public off-road access but also the opportunity it brings to enhance this access for the benefit of future residents, communities and visitors. PROW deliver benefits for personal health and wellbeing; sustainable transport; reduction of air pollution and road congestion; are able to support local economies; and they connect communities.
WSCC PROW welcomes several aspects of the Vision statement, which give support to the protection and enhancement of the PROW network, and provision of safe and convenient off-road access opportunities for residents and visitors:

* Pursue a healthy lifestyle and benefit from a sense of well-being supported by good access to education, health, leisure, open space and nature, sports and other essential facilities;
* Live in sustainable neighbourhoods supported by necessary infrastructure and facilities;
* Move around safely and conveniently with opportunities to choose alternatives to car travel.

The Local Plan Strategic Objectives offer further support to enhance off-road access, particularly to 'Encourage healthy and active lifestyles for all, developing accessible health and leisure facilities and linked green spaces'. However, the objective to 'Achieve a sustainable and integrated transport system through improved cycling networks and links to public transport' should recognise walking also as an important mode for many people; some strategic enhancements will significantly improve walkers' safety and convenience.

It is considered that West of Chichester the A259 could act as a corridor for increased volumes of non-motorised access, particularly cycling. Improvement of the existing on-road facility and development of a various 'feeder' routes to connect with the many settlements, perhaps using quiet lanes in places, would encourage cycling particularly to be a natural alternative to vehicle use. Policy S18: Integrated Coastal Zone Management for the Manhood Peninsula, gives regard to such an ambition in stating it will 'Improve infrastructure to support sustainable modes of transport, especially cycle ways, bridleways and footpaths, including the National Coastal Footpath'.

The National Planning Policy Framework (NPPF) Open Space and Recreation, para 97b) states:
the loss resulting from the proposed development would be replaced by equivalent or better provision in terms of quantity and quality in a suitable location.
The NPPF para 98 also states:
Planning policies and decisions should protect and enhance public rights of way and access, including taking opportunities to provide better facilities for users, for example by adding links to existing rights of way networks including National Trails.'
There is support for Policy S20: Design, that recognises these requirements in stating development 'is well connected to provide safe and convenient ease of movement by all users, prioritising pedestrian and cycle movements both within the scheme and neighbouring areas and ensuring that the needs of vehicular traffic does not dominate at the expense of other modes of transport, or undermine the resulting quality of places' and 'incorporates and/or links to high quality Green Infrastructure and landscaping to enhance biodiversity and meet recreational needs, including public rights of way'.


Education
As the local education authority, WSCC has the statutory duty to ensure that there is a sufficient supply of suitable school places to meet statutory requirements for early years, primary, secondary and sixth form provision (including up to age 25 for those with special educational needs and/or disabilities). Education infrastructure, or contributions to provide infrastructure, will be required in order to mitigate proposed development. We will continue to work with CDC in preparation of the Local Plan Review and the Infrastructure Delivery Plan regarding education and other service requirements in order to mitigate planned development.

The table below sets out the primary, secondary school and sixth form requirements to mitigate proposed development. SEE ATTACHMENT FOR TABLE

AL1 Land West of Chichester

It should be noted that phase one of this development will provide the primary school with the core of the building being built to the specification for a 2 form entry (FE) school and 1FE teaching accommodation. Phase 2 as per 6.10 on page 93 should include expansion of the primary school for the further 1FE of teaching accommodation.

AL2 Land at Shopwhyke (Oving Parish)

No update to original response for this allocation is required.

AL3 Land East of Chichester - previously South of Shopwhyke

At the current time pupil place planning indicates that there is insufficient space within the primary schools that serve this proposed development. Further capacity would be required to accommodate the development. Land for a 1 FE expandable to 2FE and pro rata share of the build costs would be required.

If numbers were to increase on the east side of the city, education provision will need to be reviewed, potentially a further 1FE may be required including land provision, this could be in the form of an expansion or a new school being built capable of expansion to 3FE.

At the current time pupil place planning indicates that there would be expansion capacity to accommodate the child product from this proposed development for secondary aged pupils. Contributions would be required for expansion of secondary schools if feasible and required.

At the current time pupil place planning indicates that there would be expansion capacity to accommodate the child product from this proposed development for sixth form pupils. Contributions would be required for expansion of the provision if feasible and required.

AL4 Land at Westhampnett / North East Chichester

The remaining 200 dwellings will impact on the education provision in the area, financial contributions towards expansion of existing or pro rata costs towards the expansion of the school within AL3.

At the current time pupil place planning indicates that there would be expansion capacity to accommodate the child product from this proposed development for secondary aged pupils. Contributions would be required for expansion of secondary schools if feasible and required.

At the current time pupil place planning indicates that there would be expansion capacity to accommodate the child product from this proposed development for sixth form pupils. Contributions would be required for expansion of the provision if feasible and required.

AL5 Southern Gateway

At the current time pupil place planning indicates that there would be sufficient space or expansion capacity to accommodate the child product from the strategic allocation of 350 dwellings in the Southern Gateway. However, consideration should be given to the cumulative impact of housing in the area Land South West of Chichester (AL6) to allocate land within the area for a 1FE expandable to 2FE primary school. Pro rata financial contributions towards the build costs would be sought from developers to mitigate their impact.

At the current time pupil place planning indicates that there would be expansion capacity to accommodate the child product from this proposed development for secondary aged pupils. Contributions would be required for expansion of secondary schools if feasible and required.

At the current time pupil place planning indicates that there would be expansion capacity to accommodate the child product from this proposed development for sixth form pupils. Contributions would be required for expansion of the provision if feasible and required.

AL6 Land South West of Chichester (Apuldram & Donnington Parishes)

It should be noted that the primary education provision in this area is either in Chichester City Centre which means crossing the main A27 or by travelling south towards the peninsula. Consideration should be given to the cumulative impact of further housing in the area along with the Southern Gateway allocation (AL5) to allocate land within the strategic allocation site for a 1FE expandable to 2FE primary school. Pro rata financial contributions towards the build costs would be sought from developers to mitigate their impact.

At the current time pupil place planning indicates that there would be expansion capacity to accommodate the child product from this proposed development for secondary aged pupils. Contributions would be required for expansion of secondary schools if feasible and required.

At the current time pupil place planning indicates that there would be expansion capacity to accommodate the child product from this proposed development for sixth form pupils. Contributions would be required for expansion of the provision if feasible and required.

AL7 Bosham

The current primary provision serving the area is at capacity, expansion of the school on its existing site is not possible. As part of the strategic allocation, it is proposed that land for a 2FE primary school be provided. The strategic allocation of 250 dwellings in isolation does not require a new school to be built. Certainty over the land allocation and sufficient funding will be key drivers in realising this proposal.

AL7, AL10 and AL13 are all within the same school planning area, the cumulative total of the strategic allocations brings forward a requirement for c3 forms of entry additional school places. The Local Plan, as currently drafted, indicates an oversupply of school places which could affect the viability of all the schools in the planning area.

Expansion of the secondary school may be possible. Contributions would be required for expansion of secondary schools if feasible and required.

AL9 Fishbourne

The primary school serving the area is currently at capacity, expansion of the school may be possible, feasibility / options appraisals would need to be undertaken.

At the current time pupil place planning indicates that there would be sufficient space or expansion capacity to accommodate the child product from this proposed development for secondary aged pupils. Contributions would be required for expansion of primary and secondary schools and sixth form if feasible and required.

AL8 East Wittering

At the current time pupil place planning indicates that there would be sufficient space or expansion capacity to accommodate the child product from this proposed development.

Contributions would be required for expansion of primary and secondary schools if feasible and required.

AL10 Chidham and Hambrook area

The current primary provision serving the area is at capacity, expansion of the school on its existing site is not possible. As part of the strategic allocation, it is proposed that land for a 2FE primary school be provided. Certainty over the land allocation and sufficient funding will be key drivers in realising this proposal.

AL7, AL10 and AL13 are all within the same school planning area, the cumulative total of the strategic allocations brings forward a requirement for c3 forms of entry additional school places. The Local Plan, as currently drafted, indicates an oversupply of school places which could affect the viability of all the schools in the planning area.

Expansion of the secondary school may be possible. Contributions would be required for expansion of secondary schools if feasible and required.

AL11 Hunston

Any development within this area cannot currently be accommodated in the existing primary school at North Mundham. Further capacity would be required to accommodate the development, CDC will need to work with WSCC to determine how additional capacity in the area could be accommodated if land is to be allocated.

At the current time pupil place planning indicates that there would be sufficient space or expansion capacity to accommodate the child product from this proposed development for secondary aged pupils. Contributions would be required for expansion of secondary schools and sixth form if feasible and required.

AL12 Selsey

Further capacity would be required to accommodate the development. Contributions (and possibly land if required) would be sought to meet the pupil product from the development in the most appropriate form once this can be clarified.

At the current time pupil place planning indicates that there would be sufficient space to accommodate the child product from this proposed development for secondary aged pupils. Contributions would be required for expansion of secondary schools if feasible and required.

AL13 Southbourne

At the current time pupil place planning indicates that there is insufficient space within the primary schools that serve this proposed development. Further capacity would be required to accommodate the development. Land for a 2form entry expandable to 3FE primary school and pro rata share of the build costs would be required.

AL7, AL10 and AL13 are all within the same school planning area, the cumulative total of the strategic allocations brings forward a requirement for c3 forms of entry additional school places. The Local Plan, as currently drafted, indicates an oversupply of school places which could affect the viability of all the schools in the planning area.

Expansion of the secondary school may be possible. Contributions would be required for expansion of secondary schools if feasible and required.

AL14 Tangmere

The current allocation of 1,300 dwellings will bring forward the requirement for land for a 1FE expandable to 2FE and financial contributions would be sought to meet the pupil product from the development in the most appropriate form once this can be clarified.

At the current time pupil place planning indicates that there would be sufficient space or expansion capacity to accommodate the child product from this proposed development for secondary aged pupils. Contributions would be required for expansion of secondary schools and sixth form if feasible and required.

Footnote: - if all of the proposed sites were to come forward the secondary school and sixth form provision would be full in the Chichester Planning Area. Expansion of the secondary schools in the Chichester Planning Area to cater for the increased demand would need to be sought from the academy sponsors, where appropriate and the Local Authority.


Lead Local Flood Authority
The Lead Local Flood Authority (LLFA) is concerned about the approach being taken with regard to ensuring potential wastewater treatment for proposed new sustainable development.

Paragraph 8 of the NPPF states:
8. Achieving sustainable development means that the planning system has three overarching objectives, which are interdependent and need to be pursued in mutually supportive ways (so that opportunities can be taken to secure net gains across each of the different objectives):

a) An economic objective - to help build a strong, responsive and competitive
economy, by ensuring that sufficient land of the right types is available in the
right places and at the right time to support growth, innovation and improved
productivity; and by identifying and coordinating the provision of infrastructure;

Paragraph 20 of the NPPF states:
20. Strategic policies should set out an overall strategy for the pattern, scale and quality of development, and make sufficient provision for:
a) housing (including affordable housing), employment, retail, leisure and other commercial development;
b) infrastructure for transport, telecommunications, security, waste management, water supply, wastewater, flood risk and coastal change management, and the provision of minerals and energy (including heat);

In the LLFAs view, the Local Plan Review is not setting out an overall strategy for the pattern, scale and quality of development in relation to arrangements for wastewater management. The LLFA considers that CDC needs to go further in incorporating within the Local Plan Review how this provision is being made.


Additional Policy Comments

Policy S12: Infrastructure Provision
Support the requirement that all development must provide or fund new infrastructure, facilities and services required, both on and off-site (including full fibre communications infrastructure) as a consequence of the proposal. The explicit reference to full fibre communications infrastructure is supported as this will provide gigabit-capable and future-proofed services to all development, existing and new. The reference to provision of facilities and services on and off-site is also supported as in the case of broadband for example, all development will be adequately equipped with the necessary infrastructure installed for the purposes of connecting to full fibre gigabit-capable broadband services. This policy supports the County Council's aim for increased digital infrastructure that will provide for gigabit-capable broadband and future technologies such as 5G.

Support the reference to safeguarding educational facilities under section 3 of the policy.

The policy includes the requirement to 'Facilitate accessibility to facilities and services by a range of transport modes'. PROW can offer vital access means for walkers and cyclists, such as for employment land use (e.g. commuting by bicycle) and in support of the high street, both for employees and customers. IT is considered that this Policy, also Policy S13: Chichester City Development Principles, should aim to encourage such access to be the natural and preferred modes of access, thereby helping achieve the benefits previously described. It is noted Policy S14: Chichester City Transport Strategy, does acknowledge cycling and walking and lends support to their improvement.

The supporting text, paragraph 4.81 makes reference to the Strategic Infrastructure Package (SIP). It is requested that this wording is removed and replaced with West Sussex County Council identifies service infrastructure requirements necessary to support new and existing communities, where strategic development and growth is proposed in Local Plans. These are required to deliver the County Council's statutory responsibilities, strategic objectives and current policy and feed into the preparation of the Infrastructure Delivery Plan.


Policy S13: Chichester City Development Principles
This policy, like policy S12, it is considered should aim to encourage such access to be the natural and preferred modes of access, thereby helping achieve the benefits previously described. It is noted Policy S14: Chichester City Transport Strategy, does acknowledge cycling and walking and lends support to their improvement.


Policy S23: Transport and Accessibility
The policy and supporting text paragraphs 5.15 - 5.33 refer to Transport Infrastructure. Understandably much consideration is given to the A27 around Chichester; however, in addition to seeking new infrastructure from new development, it is recommended support in principle is given to maximising the value of existing infrastructure so as to facilitate off-road user modes accessing either side of the A27.


S24: Countryside
Supporting text paragraphs 5.34 - 5.43, acknowledges 'it is necessary to provide for the social and economic needs of small rural communities, and enable those who manage, live and work in the countryside to continue to do so'. It is recognised in para 7.205, supporting text to policy SM35 Equestrian Development, the high numbers of liveried and stabled horses. A considerable network of businesses are supported by such a high equine population, and in addition to financial value within the local community there is considerable benefit in terms of health and wellbeing of individuals. It is suggested that Policy S24: Countryside, could recognise this specifically.


S27: Flood Risk Management
Supporting text paragraph 5.54, requested amendments underlined - as a consequence of the rise in sea levels and storm surges, parts of the plan area will be at increased risk from coastal erosion, groundwater, fluvial and/or tidal flooding. Hard defences may not be possible to maintain in the long term, therefore development needs to be strongly restricted in areas at risk to flooding and erosion, whilst ensuring that existing towns and villages are protected by sustainable means that make space for water in suitable areas. Development must take account of the policies of the relevant shoreline management plan

Supporting text paragraph 5.58, requested amendments underlined - Built development can lead to increased surface water run-off; therefore new
development is encouraged to incorporate mitigation techniques in its design, such as permeable surfaces and Sustainable Drainage Systems (SuDS). Where appropriate, SuDS should be used as part of the linked green infrastructure network to provide multiple functions and benefits to landscape quality, recreation and biodiversity. This can be achieved through habitat creation, new open spaces and good design. SuDS should be designed to help cope with intense rainfall events and to overcome any deterioration in water quality status. In determining the suitability of SuDS for individual development sites, developers should refer to guidance published by the Lead Local Flood Authority (LLFA): West Sussex LLFA Policy for the Management of Surface Water: https://www.westsussex.gov.uk/media/12230/ws_llfa_policy_for_management_of_surface_water.pdf and, if necessary, seek further advice from the Lead Local Flood Authority LLFA.

S27 policy text requested amendments underlined for section 1 - a. through a sequential approach, taking into consideration all forms of flooding, it is located in the lowest appropriate flood risk location in accordance with the NPPF and the Chichester Strategic Flood Risk Assessment (SFRA); and

S27 policy text requested amendments underlined for section 2. Sustainable drainage systems (SuDS) will be required on major developments (10 or more dwellings or equivalent) and encouraged for smaller schemes. SUDS should be designed into the landscape of all new development and should be included as part of a District wide approach to improve water quality and provide flood mitigation. A site-specific Flood Risk Assessment will be required for sites within or adjacent to areas at risk of surface water flooding as identified in the SFRA. There should be no increase in either the volume or rate of surface water runoff leaving the site.

S27 policy text requested additional bullet point as number 4 - Clear management arrangements and funding for their ongoing maintenance over the lifetime of the development should be proposed. Planning conditions and / or obligations will be used to secure these arrangements.

S27 policy text requested amendments underlined for section 2, but would be section 5 - Development should not result in any property or highway, on or off site, being at greater risk of flooding than the 1 in 100 year storm return period, including an allowance for climate change.


Policy S29: Green Infrastructure
The Green Infrastructure policy is welcomed, including provision of new Green Infrastructure as an integral part of the development at Strategic Development Locations. It is recommended that measures are put in place to secure the long term management of such Green Infrastructure.


Policy S30: Strategic Wildlife Corridors
The identification of Strategic Wildlife Corridors and inclusion of a policy to safeguard them from development is welcomed. It is recommended that CDC promotes positive conservation management within these corridors to maximise their contribution to maintaining and enhancing biodiversity. As stated in Section 5.66, 'These corridors do not stop at the plan area boundaries.' Thus, it is recommended that CDC works in partnership with Chichester Harbour Conservancy and The South Downs National Park Authority to ensure that these Strategic Wildlife Corridors continue to provide effective corridors and connectivity across the wider landscape.

Section 5.66 refers to four Strategic Wildlife Corridors connecting Chichester Harbour with the South Downs National Park but it is noted that there is no mention of the Strategic Wildlife Corridors to the east of Chichester which connect Pagham Harbour with the South Downs National Park (as seen in Policy Map S30b). It is also noted that the maps referred to in Section 5.66, Maps 5.1 & 5.2 are missing.

WSCC and CDC promoted a Mitigated Northern Route for the A27 at Chichester as the preferred option, subject to the inclusion of important mitigation measures that are needed to make the scheme acceptable in environmental terms and the 'full southern route' as a reasonable alternative. Both routes could impact on the identified Strategic Wildlife Corridors. As currently drafted, Policy S30 would seem to prevent a mitigated northern route from coming forward in the future. Therefore, the District Council should consider whether the policy is overly restrictive (for example should it refer to 'significant adverse impacts' or 'unacceptable adverse impacts'?) and how it would be applied if a northern route for A27 were to come forward in the future.


Policy S31: Wastewater Management and Water Quality
S27 policy text requested amendments underlined for section 3, this - Where appropriate, development should contribute to the delivery of identified actions to deliver infiltration reduction across the catchment. Where appropriate development should contribute to the delivery of identified actions to deliver a reduction in the level of infiltration of groundwater into the sewer system.


Policy AL1: Land West of Chichester
AL1 policy text requested additional bullet point as number 8 - Increase capacity to attenuate surface water on site, thereby reducing the discharge flows off the site below current rates and reducing the risk of flooding to residential areas downstream.

AL1 policy text requested additional bullet point under 15 as 15 b- Provide mitigation for any loss of watercourse habitat resulting from culverting for highway provision in the development;

AL1 policy text in supporting 'improved cycle and pedestrian routes linking the site with the city, Fishbourne and the South Downs National Park', a new key link for cycling will be to Salthill Road, thereby enabling cyclists to benefit from the existing bridge crossing of the A27 for journeys to and from the west.


AL2: Land at Shopwyke (Oving Parish)
The policy acknowledges need 'for foot/cycle bridge across A27 to Coach Road'. There is also need for equestrian users to cross the A27 and WSCC PROW has received several enquiries seeking support for such infrastructure. Consideration could be given to the proposed bridge providing for all three modes.


AL3: East of Chichester (Oving Parish)
AL3 supporting text requested amendments underlined for paragraph 6.22 - The site is identified for 600 dwellings, however, there may be potential to deliver a large strategic development of 1000 dwellings, subject to further evidence, including the testing of additional growth on the local highway network and capacity of the site to provide flood risk attenuation for the increased housing density. The site should be master planned as a whole, and delivered through a phased development over a ten year period. Although the site is physically separated from the city by the A27 Chichester Bypass, the development should form a planned extension to the city, forming a new neighbourhood. This will involve opportunities to provide new facilities to serve the wider local community with good off-site access, particularly by walking and cycling to existing local facilities and facilities in the city.

AL3 policy requires exploring integrated green infrastructure with other strategic sites to the north east of the city, Tangmere and the wider countryside. It is considered that future residents will have expectations for provision of safe and convenient links towards Oving and also across the railway to link to the A259 cycle path and PROW south of the A259. It is considered that the policy should be strengthened to ensure such provision.


Policy AL4: Land at Westhampnett/North East Chichester
AL4 policy text requested amendments underlined for section 3 - Open space and green infrastructure, including a linear greenspace with public access along the Lavant Valley.

Taking into account the site-specific requirements, proposals for the site should satisfy the following requirements:

Policy AL4 policy, it is welcomed that 'provision should be made for green links to the South Downs National Park and Chichester City.' Safe and convenient walking and cycling to Lavant, from where people will access the South Downs, will provide for sustainable transport use.


Policy AL5 Southern Gateway
AL5 supporting text requested amendments underlined for paragraph 6.38 - The area has been identified as suitable for comprehensive regeneration with the aim being to make it a more attractive and welcoming gateway for the city, providing new housing, business and retail space and leisure and tourism facilities. Opportunities will be identified to improve transport links with a focus on cycling, walking and public transport and the removal of non-essential traffic from the area. There is also scope for significant public space enhancements and new landscaping incorporating blue / green infrastructure delivering multi-functional benefits.

AL5 policy text requested amendments underlined for section 5 - Provision of open space that:
* Is in accordance with Policy DM34, including retention of the existing playing pitch unless suitable re-provision is provided;
* Reinforces / enhances green and blue infrastructure consistent with Policy S29 and fully exploits the opportunities for sustainable drainage.


AL5 policy text requested amendments underlined for section 8 - Provision of both a surface and waste water management plan which demonstrates no net increase in flow to Apuldram Waste Water Treatment Works would result from this development, unless suitable alternative provision is agreed;


Policy AL6: Land South-West of Chichester (Apuldram and Donnington Parishes)
The LLFA has concerns regarding the lack of reference to flood risk constraints of the site in Policy AL6. There is reference to flood risk in paragraph 6.47. However, the policy itself makes no reference to these constraints.
The constraints arise from a combination of the following:

* Current tidal /fluvial flood risk extending from Chichester harbour to the west and up the River Lavant floodplain; (Map 1)
* Future tidal /fluvial flood risk associated with climate change; (Map 1)
* Constraints on infiltration of surface water run off because of high seasonal groundwater levels (<0.025m below the surface) (Map 2); and
* Constraints on gravity outfalls because of the low relief and long-term reduction in tidal window for discharge.

The above limits the options for how the site can be effectively drained without a step change from typically employed methods to embrace more innovative and currently expensive options e.g. blue roofs and rainwater harvesting.

The LLFA recommends that the policy sets out both the above constraints and the type of innovative drainage that will be required to achieve the development objectives for the site.



Key: Projected medium projection extent of SLR based upon 4m contour

AL6 extent

Current Flood Zone 3 extent.

Current Areas of high (1:30) surface water flood risk

Map 1 Existing and projected Tidal and surface water flood risk for AL6.

Consistent with paragraph 3.2 of the SFRA, given the high risk of flooding both now and into the future for this site, it is recommended that CDC gives consideration to the climate change maps to understand how the flood zones are predicted to change over the lifetime of the development.


Key:
AL6 boundary.

Groundwater levels are either at very near (within 0.025m of) the ground surface.

Groundwater levels are between 0.025m and 0.5m below the ground surface

Map 2 Groundwater flood risk JBA

Policy AL6 WSCC PROW considers 'necessary highway improvements to adequately mitigate the likely impacts on the highway network' to include a bridge crossing of the A27 for convenient walking and cycling access to the Terminus Road industrial estate and the city. There is an existing public footpath but, as this crosses the A27 at-grade, this will not provide the safest facility and not encourage people to minimise use of vehicles for local access. Provision of a bridge and access through the site could also establish a valuable link to the popular Salterns Way walking and cycle path. An additional link to Salterns Way should also be provided off the A286 for the benefit of Stockbridge residents as a safer alternative to the A286.


AL 7 Highgrove Farm, Bosham
The LLFA notes that the above site has the potential for a moderate risk of groundwater flooding. It is likely that this is perched groundwater draining from higher ground / springs to the north that lies in the superficial mixed sediments underlain by Lambeth Clay.


Policy AL8: East Wittering Parish
Due to no information on where housing is going to be located so the LLFA is not in a position to comment on proposed housing allocation sites at this stage.

The policy requires 'Opportunities ... for the expansion and provision of green infrastructure into the wider countryside including between settlements and facilities'. Existing and future residents and the local visitor economy would benefit by delivery of an off-road route for walkers, cyclists and horse riders to and from the Medmerry development and towards Selsey. It is considered that Policy AL8 should aim to deliver this enhancement specifically.


Policy AL9: Fishbourne Parish
Due to no information on where housing is going to be located so the LLFA is not in a position to comment on proposed housing allocation sites at this stage.

It is considered that off-road cycling links to land West of Chichester (off Salthill Road) and to Bosham (off Park Lane) would benefit this community with enhanced sustainable connectivity.


Policy AL10: Chidham and Hambrook Parish
Due to no information on where housing is going to be located so the LLFA is not in a position to comment on proposed housing allocation sites at this stage.

The policy requires 'opportunities' to develop green infrastructure and links to other communities. An opportunity, in conjunction with Highways England, exists to maximise the value of existing infrastructure by creating a new bridleway (for walkers, cyclists and horse riders) on a path using an existing A27 overbridge.


Policy AL11: Hunston Parish
Due to no information on where housing is going to be located so the LLFA is not in a position to comment on proposed housing allocation sites at this stage.

The village is already well connected for walkers to access the surrounding countryside but there are presently no local cycling or horse riding facilities on the PROW network. A bridleway link to South Mundham (with the potential for future cycle links to Pagham and towards Bognor Regis) and to Sidlesham via the golf course and Brimfast Lane would provide residents and visitors with improved access to the countryside and services.


Policy AL12: Land North of Park Farm, Selsey
It is unclear why the policy map shows the proposed strategic allocation lies outside of the Neighbourhood Plan proposed settlement boundary. Some explanation for this anomaly would be helpful in the text.


Groundwater flood risk as depicted by JBA mapping (Brown = seasonal groundwater level lies between 0.025 and 0.5m below the surface).

The principle concern that the LLFA wishes to highlight is the need to ensure that the necessary foul sewerage infrastructure to support development is in place. It is the LLFA understanding that the Siddlesham WWTW experiences capacity issues currently, in part exacerbated by groundwater infiltration. While Policy AL12 states: Development proposals will need to demonstrate that sufficient capacity will be available within the sewer network, including waste water treatment works, to accommodate the proposed development in accordance with Policy S31.

The policy proposes only to provide 'pedestrian links between the site and new development south of Park Lane'. It is considered that cycling links should also be provided.


Policy DM8: Transport, Accessibility and Parking
The PROW network can provide vital means for communities to interact and encourage sustainable local access. The policy requirement to create 'links between new development and existing pedestrian, cycle and public transport networks' is welcomed. However, establishing links into surrounding existing development should not be overlooked also - the greater the permeability, the greater the use.


Policy DM10: New Employment Sites
Whilst mentioned earlier in the Plan in respect of a number of specific sites, this policy should specifically aim to provide, as a matter of course, suitable walking and cycling infrastructure to encourage local sustainable access. This infrastructure may need to extend outside a site boundary so as to provide safe and convenient connection to existing infrastructure. This principle should apply also to Policy DM13: Built Tourist and Leisure Development and Policy DM14: Caravan and Camping Sites.


Policy DM32: Green Infrastructure
Whilst it is recognised the policy proposes support subject to not 'dissect[ing] ... the linear network of cycle ways, public rights of way, bridleways ...', the policy could lend support to establishing new routes as part of the Green Infrastructure network itself.


Policy DM35: Equestrian Development
It is appreciated why the Plan would wish to require future equine development to be 'well related to or has improved links to the existing bridleway network'. However, this will add to the pressure of use on the existing bridleway network, which is not extensive outside of the South Downs, so will increase degradation of paths. Future developments must, therefore, accept to contribute in some way, acceptable to the local highway authority, to mitigate the additional impact to be created so all lawful users are not disadvantaged.


Policy DM29: Biodiversity
The measures to safeguard and enhance the biodiversity value of development sites are welcomed, including seeking net biodiversity gain.


Schedule of proposed changes to the policies map
S30a West of City Corridors -suggest title should be West of City Strategic Wildlife Corridors (to match S30b: East of City Strategic Wildlife Corridors. The Strategic Wildlife Corridors are depicted in different colour patterns on the two plans which is somewhat confusing.


Strategic Wildlife Corridors Local Plan Review Background Paper
Proposed Hermitage to Westbourne Strategic Wildlife Corridor
A large area depicted as Biodiversity Opportunity Area (BOA) in Fig. 1 (immediately to the south of the Rivers Ems & Meadows Local Wildlife Site, Westbourne) is in fact housing and forms part of the settlement of Westbourne. You should consider if this land should be included as having potential for biodiversity enhancement.


Glossary
Includes Sites of Nature Conservation Importance (SNCIs) but not Local Wildlife Sites (LWSs). SNCIs are now known as LWSs.