Policy AL9: Fishbourne Parish

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Comment

Local Plan Review: Preferred Approach 2016-2035

Representation ID: 2406

Received: 07/02/2019

Respondent: South Downs National Park Authority

Representation Summary:

We consider that the policy wording for the A259 corridor Strategic Site Allocations could be more robust and proactive with regard to conserving and enhancing the National Park. In particular, it could provide more active direction to applicants in order to ensure adverse impacts are minimised locally, and in relation to the National Park. For example, with regard to green infrastructure, each of the
A259 Strategic Site Allocation policies (AL7, AL9, AL10 and AL13) include a criteria requiring the provision of green infrastructure.

Criterion 5 welcomed but could be reworded to ensure developers consider impact before creating scheme.

Full text:

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

Duty to Cooperate

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

Conserving and enhancing the natural beauty

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

Locations identified for development

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

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

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

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

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

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

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

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

Policy SD30 - Strategic wildlife corridors

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

Attachments:

Object

Local Plan Review: Preferred Approach 2016-2035

Representation ID: 2474

Received: 28/01/2019

Respondent: Fishbourne Neighbourhood Plan Group

Representation Summary:

Object:
- lack of criteria as to why allocation
- building on Bethwines would be unsustainable
- impact on infrastructure
- uncertainty over A27

Full text:

RESPONSE FROM FISHBOURNE NEIGHBOURHOOD PLAN REVIEW GROUP


INTRODUCTION
Our group was established by Fishbourne Parish Council to advise the Council on how it might produce a Revised Neighbourhood Plan which would be "aspirational but deliverable" (NPPF, para 16 b).

To reach the "aspirational" requirement, we will examine every source of land supply with the possibility of sustainable development. We will do this through:
* A re-examination of the "red" sites rejected in the HELAA Report
* The Issue of a call for sites in case there are any landowners/developers who missed the HELAA call;
* Initial contact meeting with individual developers;
* Consideration of small sites for first five years of FNP 2020-2035;
* Consideration of Clay Lane developments (with possible need to amend when decisions are reached about Wildlife Corridor);
* Comparison of the total potential of the above sites and the allocation to Fishbourne in the submission report so that any alterations can be made.

We are aware of the requirement for revised Neighbourhood Plans to have made good progress by June 2019 in order to demonstrate that the Local Plan Review Strategy can be delivered.

Our work, however, is hindered by the unacceptable process by which the allocation of 250 additional homes for Fishbourne was made and the resultant confusion and traffic issues... Our principal concerns centre on five aspects:

1.The lack of any declared criteria for what otherwise seems a purely arbitrary allocation taking no account of the local situation — a flagrant flouting of the spirit of Neighbourhood Planning as envisaged by the Secretary of State, James Brokenshire: "The number of new homes we build won't be based on what a developer thinks they can sell but on the real needs of local communities."

In order to gain approval, our revised Plan would be required to meet a target allocation of new building which has been set arbitrarily at 250 (five times the allocation in our original plan) and despite repeated requests little information has been released about the criteria used to calculate the parish allocations. Such information as we have suggests that "land availability" was a factor but there seems to have been:
* no discrimination between productive top quality farmland and scrubland;.
* no allowance being made for the difficulty in finding sustainable land because of Fishbourne's regular expansion since the 1970s.

When the Fishbourne Neighbourhood Plan 2014-2029 was approved, the allocation of 50 new homes was considered appropriate because of the size of the village and its proximity to Chichester. Four years later, this has changed to an additional 250 new homes with the only apparent reason (para 6.63) being that, as Fishbourne has been classified as a "service village', it must need growth of population to promote its vitality and to sustain its local facilities including the school and the community centre. This may be true of some rural villages but it is totally untrue about Fishbourne.

Indeed, not only has CDC failed to make out a case for its arbitrary allocation of 250 homes to Fishbourne, it has failed to make out a case for any additional housing since the lack of vitality is not an issue.
* Development has already reached the Northern, Southern and part of the Eastern boundaries of the village,
* The primary school is full with children exclusively from its catchment area
* Families moving into Fishbourne are having to seek places in schools several miles away which not only increases travel and pollution but means the children have no school-friends in their own community.
* The Fishbourne Centre frequently works at full capacity.
* St. Peters Place, a new Church and community facility, is also already working at near capacity.
* Fishbourne has a proactive Parish Council which had a couple of Village Plans before its Neighbourhood Plan 2014-29 (which has already met its allocation)
* The much used facilities on Fishbourne Playing Field (football —junior and adult; cricket, tennis, bowls, croquet, outdoor gym equipment and a secure children's play area) are fully used and the envy of local parishes!
* Fishbourne has a strong community spirit, the latest example of which, the Fishbourne Companions, have just celebrated their first birthday

Since the only land that might be classified as sustainable could produce only 200 homes, meeting the target allocation of 250 for Fishbourne would have to include some land from Bethwines. This would remove from the community their right to choose where building should take place. More important, too, is that this enforced breaking of the Parish Council's policy would lead inevitably to the whole farm being used to provide 1,000 homes regardless of:
* the top quality productive farmland,
* the valued views between the Harbour and the South Downs,
* the destructive effect on wildlife and birds especially at nesting time;
* the gridlock that would result on inadequate roads;
* an unacceptable health risk caused by the rise in air pollution.


The case for a need for growth in Fishbourne in order to sustain the vitality in the village and to help to sustain the school and other services has clearly NOT been made. What proportion of the justification for the allocation of 250 was based on this false data?



2. The impact of the proposed Wildlife Corridor on land in the Eastern part of the village (Clay Lane).

In the view of professional conservationists, the designated strategic wildlife corridors proposed in the local plan do little good, are too narrow to support the wildlife and do not go far enough in their coverage. They recommend that a single much wider corridor, which would provide wildlife with the natural space in which to move about relatively undisturbed. Therefore their positioning in this plan needs to be removed, rethought and reduced to one single, much wider area - for which Bethwines Farm is ideal!

Until the last minute imposition of the Wildlife Corridor, this site was the only site where an aspirational approach might have produced 160 of the 250 allocation. Failing a relocation of the corridor, we strongly recommend that the allocation for Fishbourne should be reduced by the number of homes the parish council has been prevented from offering on the Clay Lane site as a result of the decision taken by CDC since it is not equitable for the negative impact of a District Council initiative to fall on one parish.


3.Policy on Bethwines Farm.

"National policies and regulations aim to protect the best and most versatile (BMV) agricultural land and soils in England from significant, inappropriate or unsustainable development proposals." (Natural England, 2018).
"The Local Plan helps us to:
* shape where development goes;
* protect the character and beauty of the area" (Chichester District
Council,2018)
The intention to build on Bethwines Farm is not compliant with either of these statements. There needs to be more openness, clarity and consistency about the District Council's view on Bethwines Farm. This seems to shift from regarding it as :
* not being suitable for sustainable development (current Local Plan);
* suitable for 81 homes in HELAA with the remainder being unsuitable;
* suitable for 200+ if the Wildlife Corridor is not relocated from Clay Lane;
* (almost inevitably in the next Five Year Review) suitable for the remainder of the Farm leading to a total build of 1,000 homes, thereby doubling the
population of Fishbourne, causing unsustainable traffic congestion and
unacceptable levels of pollution and causing irreparable damage to, rather
than protecting "the character and beauty of the area".

Against this inconsistency, we support the Parish Council's consistent stance which is compliant with the 2018 revision of the National Planning Policy Framework, the existing Fishbourne Neighbourhood Plan - and even some of the Policies in the District Council's own Local Plan Consultation Document, with which the proposed practices are not compliant!

We will continue to plan on the assumption that CDC will note all the implications of building on Bethwines and will come to realise that building on Bethwines would not be appropriate but would "cause unnecessary, irreparable damage and would have an adverse impact that would demonstrably outweigh the advantages."

4. Conflict between policies and practice (infrastructure and transport)
CDC Local Plan Review Policy DM8 is a classic example. It states that any development must minimize and not create or add to problems of highway safety, congestion, air pollution or other damage. (The policy omits sound and light pollution which should be added).
It is our considered opinion that this is unachievable.
The A27 does not serve communities west of Chichester unless they use the A259 as a feeder road and there are no major employers in Fishbourne which makes travel to work a necessity.
Fishbourne is designated as a service village. The definition is that the village can provide a reasonable range of basic facilities, or have reasonable access to nearby facilities. We have no shops, no banks, no doctor, no facilities, in fact only two pubs and the Fishbourne Centre. Reasonable access - not possible due to distance and huge traffic problems. The 700 bus service that runs along the A259 is excellent, but it is nationally accepted that unless a bus stop is within 400 metres of the house, residents will not use it. The 56 bus only runs in the morning at 0815, 0943 and 1143hrs as a very limited service into the City but will again still be out of reach of potential Bethwines residents. The railway provision is a halt, not a station, and only has one train an hour in each direction, and again is out of reach of Bethwines development. Public transport is therefore not a viable option for any development on Bethwines Farm.
The 'transport corridor' is not effective now let alone with the 2250 houses scheduled to be built along the corridor between Chichester and Southbourne. A study of the 97 house Flavian Fields development in north Fishbourne revealed that 65% work and have to travel to employment outside of the village. This will apply equally to Chidham and Bosham. This figure also takes no account of the fact that parents will transport their children to school by car. These schools will be outside of the village due to Fishbourne and Bosham Schools being already full and the only secondary school at Southbourne being further away than Chichester schools. It has been established that Fishbourne already has the highest car dependency in Chichester District.
The CDC review team has used a national statistic of 50 cars per 100 households, but that is seriously flawed based upon local evidence that, from the Flavian Fields survey, places the figure at 200 cars per 100 households.
Specifically, the huge growth of 1000 houses in Fishbourne, Bosham and Chidham, amounts to a minimum of 1000 additional cars travelling during peak times. We would anticipate that these villages will use Chichester for employment, schools and facilities. The 1250 houses in Southbourne will further complicate the numbers, but a considerable number will probably travel westbound,
The average length of a family car is now 4.8 metres. Allowing for about a one metre+ gap between them, 1000 cars need a stationary road space of about 6000 metres or Chidham to the Fishbourne Roundabout.
The A27 roundabout at Fishbourne is a huge blockage to any increase of traffic. There is already a peak time queue every morning of half a mile along the A259, and six miles of standing traffic on the A27. That is the current situation, but the projected figures are much worse. The roundabout will be used by the following additional traffic attempting to access the A27:
* 1600 additional houses at Whitehouse Farm via Cathedral Way
* 1000 houses at Fishbourne, Bosham and Chidham via A259
* Terminus Road traffic via Cathedral Way
* Link road to development south of A27
* Manhood Peninsula traffic diverted west of Stockbridge.
The plans for a hamburger roundabout cannot deal with this size of traffic flow, and we can only deduce that incomplete data has been fed into the computer model to establish this junction method. The eastbound queue of stop-go traffic as a result of the traffic lights will just move up to Stockbridge blocking Fishbourne: the same would be true for westbound traffic. Where some of these roundabouts have been installed they have not been a success in handling traffic better.
The projected traffic queues will further add to the destructive effects of pollution if we have miles of standing traffic in Fishbourne. There are already 4 Air Quality Management Areas (AQMA) in Chichester, the most of any area in West Sussex. Is Fishbourne to become the 5th? Simon Ballard, CDC Senior Environmental Protection Officer has publicly attributed 4.1% of Chichester's being due to PM2.5, just one pollutant of the many pollutants from vehicle emissions.

This issue with air quality pollution does not stand alone, Fishbourne residents will suffer increased noise pollution and light pollution from the proposed raised Stockbridge Link Road, its slip road will impinge by 7,000m2 into The Fishbourne Meadows Conservation Area, further restricting Fishbourne residents from exiting the A259.
We would seek the opportunity to see the traffic flow data used for the junction analysis in order that we may use it for an independent study using road traffic simulation software. The timescale you have set for consultation does make a challenge very difficult and the CDC should be cognizant of and sympathetic to our inputs.
There is no doubt that the traffic presumptions made in the plan are seriously flawed, and that, if the true figures were used, the traffic plans would have to be substantially up- rated. This needs to be examined by the Planning Team.
5. Uncertainty about the A27
Peter Brett's traffic mitigation study in CDC's Local Plan has a clear dependency on Government's funding of the A27 improvements in Road Investment Strategy 2. The mitigation described in their study will mean that Chichester District Council will violate air quality levels throughout the plan period. Add to this the congestion and air pollution due to construction and the spread of pollution during works for diversionary routes.

One reason to abandon the A27 Northern upgrade was marginal and set against spend, even though the cost equates to a maximum of 2% of the £25 billion budget announced by the Chancellor in his Autumn statement. The other reason given is the conflict with National Policy, at some point will be tested for the first time, probably at Arundel. Where the requirements of the policy will have to be balanced against the good to the public (air quality, and accident reduction, support for economic growth locally and regionally).
The two reasons given by Highways England to abandon the A27 upgrade are all marginal, and set against spending on other parts of the country the financial argument does not hold water given the acknowledged congestion and accident figures of the A27.
The key to any resolution of the A259 and Fishbourne roundabout traffic problem is whether Highways England will take the Chichester District and BABA27's advice and take the A 27 flow away from Fishbourne Roundabout via a northern by pass. If the A27 is moved, this would still leave flows from the current bypass and Manhood peninsular etc. to be negotiated at Fishbourne roundabout when a hamburger roundabout would probably suffice.

SUMMARY OF MAIN RECOMMENDATIONS


Our recommendations to the CDC for the way forward to an aspirational but deliverable allocation for Fishbourne:

(1) Reassess the allocation for Fishbourne using accurate local evidence to base the allocation on need and taking into account the limited space available after an increase in population of 33% since 2001 on top of a doubling of the population over the previous four decades.
Correct other errors such as describing the AONB as being south of
the village: in fact the AONB stretches up to the A259
Insert vital information such as a map showing the potential sites: consultees
cannot comment adequately without this information and this makes the
consultation process unsafe.

(2) Take into account the views of the community in the village survey where:

* maintaining "Best and most versatile agricultural land";
* enhancing highly valued landscapes with views between Chichester Harbour AONB and the South Downs National Park;
* creating strategic gaps to retain the geographical identity of individual villages

all scored over 90% support (and are all compliant with NPPF).

(3) Given the flaws in the traffic presumptions, provide Fishbourne Parish Council with traffic-flow data so that an independent study can be conducted.

(4) Develop an open and consistent policy for Bethwines Farm

(5) Avoid causing irreparable harm. In many cases, it is possible to offer compensatory strategies to offset the original damage to amenities affected by new housing development. However, this is not possible where "best and most versatile agricultural land" is used for building.

(6) . Provide confirmation and proof that appropriate research has been conducted on air quality,particulate concentration and pollution expectations resulting from the increased traffic at Fishbourne Roundabout, including that expected to result from standing traffic on the approaches to Fishbourne roundabout from A259 westwards and the new proposed Donnington / Apuldram junction from the south into Fishbourne Roundabout.

Fishbourne Roundabout / A259 is already exceeding the EU air quality regulations and any 'improvements' planned for this roundabout will need to show substantial air quality improvements.

(7) Provide confirmation and proof that the expectations for increased sewage and waste water / run-off water from new building along A259 and in Fishbourne have been taken into account with regard to flood risk at the harbour and the approaching ditches in and around the Fishbourne area and that Southern Water have been involved regarding their capacity for these extra homes requirements.


(8) If the Wildlife Barrier is not relocated, reduce the Fishbourne allocation accordingly.









CONCLUSION

We repeat our intention to construct a revised Neighbourhood Plan that is aspirational but deliverable. However, before progress can be made we need a resolution of the problems raised in this report. - and, given the exceptionally tight timetable for the preparation of revised Neighbourhood Plans, there is an urgent need for these issues to be addressed and resolved.


Contact for queries or further discussion: Geoff Hand
Councillor.hand@fishbourne-pc.gov.uk

January 2019


FISHBOURNE NEIGHBOURHOOD PLAN STEERING GROUP
Geoff Hand Chairman, Fishbourne Parish Council; Editor FNP (2014-29)
Lucy Wright (Administrator) Clerk, FPC
Cllr. Louise Goldsmith County Councillor, Chichester West Division
Cllr. Adrian Moss District Councillor, Fishbourne Ward
Cllr. Adam Porter FPC & Flavian Fields Residents Association
Cllr. Ruth Keeley FPC & Mosse Gardens Residents Association
Cllr. Lynda Hunter FPC & Fishbourne Companions
Cllr. Mike Lander Vice-Chairman, FPC
Julian Snell Former Chairman FPC
Andy Relf Resident; formerly Sussex Police & Home Office
Maggie Borsberry Fishbourne W.I.
Trina Miliam Fishbourne Evening W.I.
Naomi Day Headteacher, Fishbourne Primary School
Rev. Canon Moira Wickens Rector
Vicky Blamire Fishbourne Pre-school
Libby Alexander Resident & CPRE
Zoe-Elizabeth Neal Save our South Coast
Edwin Scarterfield Resident, Employer and Fishbourne & Parklands Flood Protection Group
Roger Gould Resident Roman Way
Rita Lowry Resident, Bethwines Close
Pat Lowry Resident, Bethwines Close

Object

Local Plan Review: Preferred Approach 2016-2035

Representation ID: 2477

Received: 20/02/2019

Respondent: Fishbourne Parish Council

Representation Summary:

Object:
- 250 undeliverable
- traffic congestion
- issues of Bethwines - landscape
- water quality

Apply S24, S25 and S26 to consideration of devt on Bethwines Farm



Full text:

See attachment

Object

Local Plan Review: Preferred Approach 2016-2035

Representation ID: 2503

Received: 24/01/2019

Respondent: Mary Hand

Representation Summary:

250-plus new houses would alter the population dynamics.

Fishbourne has limits set by the A27 and the Harbour Conservancy.

If the newly designated "wildlife corridor", takes up space across potential Clay Lane sites it is arguable the resulting shortfall should be absorbed elsewhere.

The value placed by residents on the Bethwines site as a village amenity and a delineating gap not to be used for housing was clear at NP stage.

The Bethwines location would be tacked on to the existing built up area. Access to "facilities" would be mostly by car using roads already congested and in Blackboy Lane.

Full text:

It is important to be clear and open about the specific grounds for allocating "a minimum of 250 dwellings" to Fishbourne. Fishbourne has delivered on housing development since the 1930s, with at least one and more recently two major developments for each decade (except the 1940s for obvious reasons). These have been absorbed and integrated into the village. 250-plus new houses to the west would completely alter the population dynamics. The offer of 1000 homes, which has been made by the developers over the next few years would have the effect of doubling the population. Attractive though such an offer must be to planners seeking to find offers for the additional number of houses for Local Plans (2025 and 2030) there are other important issues at stake affecting the quality of life in this area. The consultation meeting at Fishbourne 16/1/18 showed a heavily developed corridor along the A259 with serious implications for further houses into the future - "Solent City" planned to become a reality!

Fishbourne has limits set by the A27 to the north and east and the Harbour Conservancy to the south (- just as the CDC area has limits set by the South Downs National Park and the Harbour Conservancy area ) Here in Fishbourne there is now little room left for further housing, within the "built-up-area" as redefined by the new Neighbourhood Plan 2020-2035 currently in preparation. If the newly designated "wildlife corridor", takes up space across potential Clay Lane sites it is arguable the resulting shortfall should be absorbed elsewhere.
Anyone not familiar with the village and area could mistake the Bethwines site as an obvious possibility for easy development now and especially as opening the way to meet new targets in ensuing CDC Local Plans. However attractive this might be to planners under pressure it should not negate genuine planning decisions which provide for the well-being of people and the environment, built and natural into the future. With the example of the classic mess, in planning terms, of Peacehaven just down the road, we should be warned!

1. Within the Fishbourne Neighbourhood Plan 2014-2029, agreed by referendum, a residential area was set taking into account limits to the east (Chichester), north (A27) and south (Harbour area). The value placed by residents on the Bethwines site as a village amenity and as a delineating gap not to be used for housing was clear at this stage. The necessity for a new Neighbourhood Plan superseding the 2014-29 plan does not lessen the objections in any way.
The Bethwines location would be tacked on to the existing built up area, not "well integrated". Access to "facilities" would be mostly by car using roads already congested and in Blackboy Lane crumbling and decrepit, and worsened by potential bus route use. 'Out in the fields' is not 'well integrated'!

3. There are sufficient transport problems already. As for the physical mess a major building development of 250 homes-plus could occasion on Blackboy Lane - the mind boggles! The recent weeks of disruption to traffic of the two house development to the south of Blackboy Lane would be nothing to it. Add to that the potential roadworks improving the A27 by-pass and the Whitehouse Farm development (access for lorries off Clay Lane planned) Fishbourne folk will be in for a number of uncomfortable messy years/decades!

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

Add to this the protection of the distance views to the west of the village across the coastal plain including the spectacular sunsets. This is also an area where the light qualities of the proximity of Chichester Harbour and the open sea can be appreciated. This special reflected light influenced the development of salad crop farming and the fruit tree nursery, once world famous. Bethwines land is also good quality farming land which should be protected. Particular local circumstances suggest that once broached for a relatively few houses, this would open the way to further and further developments reducing or even filling the settlement defining gap between Fishbourne and Bosham and between Chichester and the ribbon development along the A259. Protection of Chichester Harbour requires greater consideration than merely signing it off on the south side of the A259. It is part of the sweep of land down from the Downs and across the coastal plain to the sea. This needs to be evident in the landscape and environment, for the benefit of human beings, and for the benefit of migrating wildlife.

6. Opportunities for the expansion and provision of green infrastructure into the wider countryside including between settlements and facilities;
Fishbourne village has its historic western boundary which is the rural Blackboy Lane. Land to the west of Fishbourne already provides that green infrastructure providing a north/south flight path from harbour to the Downs. Local residents report regular sightings of bats between the Railway Cottage and Bethwines Farm, and also the presence of red kites, sparrow-hawks and peregrine falcons.

7. Demonstration that development would not have an adverse impact on the nature conservation interest of identified sites and habitats;
There is concern over flooding in Fishbourne which has implications for other areas. Run-off is into the Harbour and proximity means it is particularly affected by the tides and the ponding of water at high tide by the prevailing westerly winds. Standing water in the fields in an increasingly common occurrence in this area. Concreting over for housing will exacerbate the problem possibly leading to increased threat of flooding for existing homes in the path of the run-off. This inevitably impacts harbour-side environments

9. Provision of infrastructure and community facilities in accordance with the most up to date Infrastructure Delivery Plan;
This is a fine ideal but as with our Neighbourhood Plan 2014-29 promises can be reneged upon and while pavements and footpaths in existing developments are generally OK, paths between them or linking them to the rest of the village have rarely received adequate attention or maintenance, a pattern that may apply to other things especially in a time of financial restriction and therefore be on-going. Imposing a town-sized population on a rural environment requires more than merely plonking down houses. Plans have to identify what is needed and have the committed means for implementation.

Comment

Local Plan Review: Preferred Approach 2016-2035

Representation ID: 2507

Received: 24/01/2019

Respondent: Mary Hand

Representation Summary:

Bethwines land is good quality farming land which should be protected.

Fishbourne village has historic western boundary, the rural Blackboy Lane.

Run-off into the Harbour and proximity means it is particularly affected by tides and ponding of water at high tide by prevailing westerly winds. Standing water in fields is increasingly common occurrence in this area.

While pavements and footpaths in existing developments are generally OK, paths between have rarely received adequate maintenance.

There are sufficient transport problems already.

250 homes-plus would cause issues for Blackboy Lane.

Plus the potential roadworks improving the A27 by-pass and the Whitehouse Farm development.

Full text:

It is important to be clear and open about the specific grounds for allocating "a minimum of 250 dwellings" to Fishbourne. Fishbourne has delivered on housing development since the 1930s, with at least one and more recently two major developments for each decade (except the 1940s for obvious reasons). These have been absorbed and integrated into the village. 250-plus new houses to the west would completely alter the population dynamics. The offer of 1000 homes, which has been made by the developers over the next few years would have the effect of doubling the population. Attractive though such an offer must be to planners seeking to find offers for the additional number of houses for Local Plans (2025 and 2030) there are other important issues at stake affecting the quality of life in this area. The consultation meeting at Fishbourne 16/1/18 showed a heavily developed corridor along the A259 with serious implications for further houses into the future - "Solent City" planned to become a reality!

Fishbourne has limits set by the A27 to the north and east and the Harbour Conservancy to the south (- just as the CDC area has limits set by the South Downs National Park and the Harbour Conservancy area ) Here in Fishbourne there is now little room left for further housing, within the "built-up-area" as redefined by the new Neighbourhood Plan 2020-2035 currently in preparation. If the newly designated "wildlife corridor", takes up space across potential Clay Lane sites it is arguable the resulting shortfall should be absorbed elsewhere.
Anyone not familiar with the village and area could mistake the Bethwines site as an obvious possibility for easy development now and especially as opening the way to meet new targets in ensuing CDC Local Plans. However attractive this might be to planners under pressure it should not negate genuine planning decisions which provide for the well-being of people and the environment, built and natural into the future. With the example of the classic mess, in planning terms, of Peacehaven just down the road, we should be warned!

1. Within the Fishbourne Neighbourhood Plan 2014-2029, agreed by referendum, a residential area was set taking into account limits to the east (Chichester), north (A27) and south (Harbour area). The value placed by residents on the Bethwines site as a village amenity and as a delineating gap not to be used for housing was clear at this stage. The necessity for a new Neighbourhood Plan superseding the 2014-29 plan does not lessen the objections in any way.
The Bethwines location would be tacked on to the existing built up area, not "well integrated". Access to "facilities" would be mostly by car using roads already congested and in Blackboy Lane crumbling and decrepit, and worsened by potential bus route use. 'Out in the fields' is not 'well integrated'!

3. There are sufficient transport problems already. As for the physical mess a major building development of 250 homes-plus could occasion on Blackboy Lane - the mind boggles! The recent weeks of disruption to traffic of the two house development to the south of Blackboy Lane would be nothing to it. Add to that the potential roadworks improving the A27 by-pass and the Whitehouse Farm development (access for lorries off Clay Lane planned) Fishbourne folk will be in for a number of uncomfortable messy years/decades!

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

Add to this the protection of the distance views to the west of the village across the coastal plain including the spectacular sunsets. This is also an area where the light qualities of the proximity of Chichester Harbour and the open sea can be appreciated. This special reflected light influenced the development of salad crop farming and the fruit tree nursery, once world famous. Bethwines land is also good quality farming land which should be protected. Particular local circumstances suggest that once broached for a relatively few houses, this would open the way to further and further developments reducing or even filling the settlement defining gap between Fishbourne and Bosham and between Chichester and the ribbon development along the A259. Protection of Chichester Harbour requires greater consideration than merely signing it off on the south side of the A259. It is part of the sweep of land down from the Downs and across the coastal plain to the sea. This needs to be evident in the landscape and environment, for the benefit of human beings, and for the benefit of migrating wildlife.

6. Opportunities for the expansion and provision of green infrastructure into the wider countryside including between settlements and facilities;
Fishbourne village has its historic western boundary which is the rural Blackboy Lane. Land to the west of Fishbourne already provides that green infrastructure providing a north/south flight path from harbour to the Downs. Local residents report regular sightings of bats between the Railway Cottage and Bethwines Farm, and also the presence of red kites, sparrow-hawks and peregrine falcons.

7. Demonstration that development would not have an adverse impact on the nature conservation interest of identified sites and habitats;
There is concern over flooding in Fishbourne which has implications for other areas. Run-off is into the Harbour and proximity means it is particularly affected by the tides and the ponding of water at high tide by the prevailing westerly winds. Standing water in the fields in an increasingly common occurrence in this area. Concreting over for housing will exacerbate the problem possibly leading to increased threat of flooding for existing homes in the path of the run-off. This inevitably impacts harbour-side environments

9. Provision of infrastructure and community facilities in accordance with the most up to date Infrastructure Delivery Plan;
This is a fine ideal but as with our Neighbourhood Plan 2014-29 promises can be reneged upon and while pavements and footpaths in existing developments are generally OK, paths between them or linking them to the rest of the village have rarely received adequate attention or maintenance, a pattern that may apply to other things especially in a time of financial restriction and therefore be on-going. Imposing a town-sized population on a rural environment requires more than merely plonking down houses. Plans have to identify what is needed and have the committed means for implementation.

Object

Local Plan Review: Preferred Approach 2016-2035

Representation ID: 2558

Received: 07/02/2019

Respondent: Chichester Harbour Trust

Representation Summary:

Without seeing any site allocation maps showing the potential location of the development (other than the HELAA document), we feel it would be difficult for Fishbourne to accommodate the development of an additional 250 houses without having an impact on:

- The setting of Chichester Harbour AONB
- An impact on water quality in Chichester Harbour SSSI
- An increase in recreational disturbance of migrating bird species, particularly at the head of the Fishbourne Channel

We recognise that the policy tries to address these issues through the masterplanning process and urge that they are given due weight.

Full text:

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

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

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

Object

Local Plan Review: Preferred Approach 2016-2035

Representation ID: 2665

Received: 04/02/2019

Respondent: Mr Mike Dicker

Representation Summary:

Makes no provision for the road infrastructure impact of a further 250 dwellings onto the A259 and A27.

See attached for full detail.

Full text:

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

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

High level comments received:

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

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

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

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

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

Attachments:

Object

Local Plan Review: Preferred Approach 2016-2035

Representation ID: 2743

Received: 10/01/2019

Respondent: Stephen Sadler

Number of people: 2

Representation Summary:

Fishbourne is not suitable for further large scale housing developments as any likely sites are unsuitable due to the risk of flooding, the loss of agricultural land, the lack of road capacity, and sewage capacity at Apuldram.

No proper thought was given to transport in the recent and current developments and there is no reason to believe any new ones will do any better under the current
regimen.

Already with the numbers of extra dwellings in recent years the local school is turning away pupils.

Full text:

Policy nos. AL9, AL6 and S30

Why 250 extra houses in Fishbourne, is it because not many of influence live here?

It certainly is not because of logic. Fishbourne has had the third most development of
all the towns and villages in Chichester in recent years.

As first general points Fishbourne is not suitable for further large scale housing developments as any likely sites are unsuitable due to the risk of flooding, the loss of agricultural land, the lack of road capacity, and sewage capacity at Apuldram.

No proper thought was given to transport in the recent and current developments and there is no reason to believe any new ones will do any better under the current
regimen.

Already with the numbers of extra dwellings in recent years the local school is turning
away pupils.

There are also far more dog walkers than there were leaving mess and putting pressure on ground nesting and seasonal birds in the Harbour AONB.

We can only assume that the strain on the AONB would increase even further.

Can we suggest that you look at other towns and villages in the district which have so far evaded being lined up to these pressures?

Our Wildlife could also do with some relief from over-development.

Comment

Local Plan Review: Preferred Approach 2016-2035

Representation ID: 2751

Received: 07/02/2019

Respondent: Gleeson Strategic Land

Representation Summary:

Gleeson controls and promotes land to the E of Fbourne - believe that suitably designed resi devt can come forward and would have least impact on surrounding landscape; noise can be mitigated; and is in suitable location to maximise transport links.

Full text:

See attachment

Comment

Local Plan Review: Preferred Approach 2016-2035

Representation ID: 2778

Received: 07/02/2019

Respondent: Sussex Wildlife Trust

Representation Summary:

SWT notes that policy AL9 includes a specific requirement for development to demonstrate that it would not have an adverse impact on the nature conservation interests of identified sites and habitats. We support the inclusion of this requirement, although as per the revised NPPF, it should also require net gains to biodiversity. However we question why this requirement is not included in any of the previous site allocations when they clearly will also impact on 'nature conservation interests'. Despite this requirement, the policy still needs to be strengthened

Full text:

See attachment

Attachments:

Support

Local Plan Review: Preferred Approach 2016-2035

Representation ID: 2782

Received: 07/02/2019

Respondent: Fishbourne Developments Ltd

Agent: ICENI Projects

Representation Summary:

Support so far that parish can accommodate growth. Has ability to deliver above proposed levels - 500 dwellings.

The promoted site North-West of Fishbourne (Bethwines Farm) can accommodate 500 dwellings

Full text:

See attachment

Object

Local Plan Review: Preferred Approach 2016-2035

Representation ID: 2822

Received: 06/02/2019

Respondent: Ms Claire Greenfield

Representation Summary:

Objection to Bethwines Farm:
1. Prime farmland.
2. Wildlife (some of which may be protected) and one of the only remaining open spaces in Fishbourne.
3. Resources and infrastructure are already overstretched.
4. Blackboy Lane was built specifically as a lane - not a road - so that it does not have the appropriate structure to accommodate the amount of traffic it would receive.
5. Flooding.
6. Unclear why Bethewine's Farm would be chosen for development rather than the land on the north side of the A259 just west of Tharfield Kennels.

Full text:

I am writing to state my objections to the proposed development of housing on Bethewine's Farmland in Fishbourne. This is probably the third letter have written over the years and my objections have not changed. Indeed, the recent high level of housing in Fishbourne has demonstrated that they are valid as much of the local area has already been spoiled, changing Fishbourne from a village into a sprawling housing development surrounded by roads which are becoming 'rat runs', making them dangerous and causing long delays to travel.

1. My first objection is that this would be on prime farmland. It is well documented that we could reach the tipping point for the beginnings of a runaway climate change. There are many examples of Britain's government's inability to take action to prevent this, despite the fact that other nations, such as Cuba, have rolled out national schemes. Using prime agricultural land for building houses, as in this case, is another example of short­ sightedness. Instead, we should be sustaining this valuable land so that the people of Britain may be more secure in terms of food and energy supplies in order to be able to weather the economic and environmental changes that are taking place.

2. Secondly, it is stated that the Local Plan Policies 'will ensure that protected habitats and species will not be harmed as a result of new development' and it 'will also protect existing open spaces'. Bethewine's Farm is teaming with wildlife (some of which may be protected) and this site is one of the only remaining open spaces in Fishbourne, housing development having already spoiled many of the fields and farmland. Mention was made of providing alternative spaces, but nothing could replace the views across the farmland which we, who appreciate the countryside and bought properties here because of this, currently take pleasure in. Just yesterday, there was another scientific report about the benefit of the countryside on people's mental health, another issue which appears to be high on the current agenda . Building on this site could, therefore, be detrimental to the mental health of local residents.

3. My third objection is that the resources and infrastructure are already overstretched. I understand that Fishbourne has been chosen as a suitable site because it has the infrastructure required. This infrastructure may have been sufficient for Fishbourne as it was. However, since have lived in Fishbourne (28 years) have seen Salthill Road and Clay Lane turned from country lanes into main roads where traffic travels in excess of 50 mph. The crossroads around the area are now dangerous for pedestrians and drivers and, at peak times, it can take an hour to drive from Fishbourne to the other side of Chichester. The local school is full already, with many local children unable to be accepted.

4. My fourth point relates specifically to Blackboy Lane, which understand was built specifically as a lane - not a road- so that it does not have the appropriate structure to accommodate the amount of traffic it would receive. To upgrade this, in addition to the assumed cost of upgrading the railway crossing, would cause extra expense, not to mention the upheaval it would cause. My house has an open ditch running outside and this floods regularly. Presumably, this would need to be covered over, causing additional expense and inconvenience.

5. Flooding is another concern. It has been an issue for Fishbourne for many years and it is well-documented that the sewage works at Appledram are already unable to manage at the current level. Anyone driving anywhere near it in the summer months would be aware of the stench as they sit for hours in a traffic jam attempting to reach the beach via this road which has become a rat-run.

6. It is unclear to me why Bethewine's Farm would be chosen for development rather than the land on the north side of the A259 just west of Tharfield Kennels. I understand that the landowners (I believe Langmead Farm) are keen to sell this land whilst the owner of Bethewine's Farm does not and this situation has occurred because of a past relative signing a document whilst in a mentally unstable state of mind. After all, there has been such a lot of development along the A259 already, that the amount of traffic to be generated by this development (which understand has been estimated by the Police to ensure that traffic will be backed up to the Bosham roundabout at peak times) would at least be able to use the Main Road to queue rather than blocking the already busy lane which Blackboy Lane has become.

My final objection is a purely selfish one. Like many of the local residents, moved to Fishbourne because wanted to live in a quiet, rural part of the countryside, where there was a good community feeling, not a sprawling, soulless suburb or 'hub' for Chichester and will do everything in my power to ensure that Fishbourne remains the former.

Attachments:

Object

Local Plan Review: Preferred Approach 2016-2035

Representation ID: 2848

Received: 30/01/2019

Respondent: Eve & Peter Mulvany

Number of people: 2

Representation Summary:

- Building at Bethwins will substantially increase the traffic in Clay Lane.
- Blackboy Lane was never designed for the amount of traffic.
- Fishbourne primary school is already at its maximum level.
- No shops in Fishbourne.

Full text:

When we moved to Fishbourne seven years ago we were told by the developers that this estate - Tapestry, now Cuckoo Fields and Fraser Row, was a haven set against a backdrop of the West Sussex Countryside. What a joke. In seven years Clay Lane has become a rat run - recently we nearly had a bad accident exiting from the estate onto Clay Lane as an idiot in a high powered car overtook two cars going westward, the driver had virtually no vision of the road ahead as there is a slight curve in the road, he must have been travelling at well over the 30mph speed limit on this road!

The building at Bethwins will substantially increase the traffic in Clay Lane as many drivers will NOT use the Fishbourne Roundabout (A27). Add to that the increase in traffic due to the development of Whitehouse Farm will also seriously add to the traffic problems in Fishbourne. At the crossing of Clay Lane and Salthill Road there have already been accidents.

Blackboy Lane is a disgrace, it was never designed for the amount of traffic that will reduce the soakaway area considerably, possibly causing flooding in Blackboy Lane.

Fishbourne primary school is already at its maximum level, also there are no shops in Fishbourne and now they are talking of doing away with the 56 bus.

Fishbourne already has the highest dependency of cars in the local area, take away the bus and there will be more cars on the roads.

In the year 2008 Fishbourne was named West Sussex village of the year. Now with the extreme amount of building along the A259 towards Emsworth, Fishbourne is a convenient way into Chichester avoiding the A27 Roundabout, putting more stress on Blackboy Lane, Clay Lane and Salthill Road. We do Not require or Need any more traffic especially by building more houses anywhere in Fishbourne

Attachments:

Comment

Local Plan Review: Preferred Approach 2016-2035

Representation ID: 2873

Received: 07/02/2019

Respondent: Mr and Mis Butterfield and Waldron

Agent: Rodway Planning Consultancy Ltd

Representation Summary:

Consider that leaving allocations to NP is risky, subject to delays and undeliverable.

Policy should be modified to allocate promoted Land at Fourways for devt.

Full text:

See attachment

Object

Local Plan Review: Preferred Approach 2016-2035

Representation ID: 2878

Received: 25/01/2019

Respondent: Susan Folkes

Representation Summary:

Objection to Bethwines Farm:
- Prime agricultural land.
- Skylarks, bats, deer and other wildlife use it as a corridor.
- Loss of a valued view.
- Increased risk of flooding along the A259.
- High water table leading to problems with rising sewage.
- Pressure on already crumbling lanes and roads.
- No Dr Surgery.
- No room at the school
- No local shops
- Extra traffic on the roads, extra traffic, extra pollution.
- Blackboy Lane not suitable for heavy construction vehicles.
- Rural setting lost forever.

Full text:

Proposal to build 250 homes on Bethwines farm. Why this should never happen.

Bethwines Farm is a large piece of farmland on the western edge of Fishbourne north of the railway line which isolates it from the A259 main road. This means that any traffic leaving any future development will have to exit south over the level crossing to the narrow southern end of Blackboy Lane onto the A259 or noth via Clay Lane, already used as a 'rat run' to Tescos and Chichester, avoiding the A27 roundabout. The building of any new homes on Bethwines Farm has the potential to expand very quickly to over 1000. Anyone looking at a map of Fisbourne can see that this development is not sustainable and would have a distructive effect upon the whole of Fishbourne which would require major infrastructure changes. It would destroy the rural setting forever.

There are many reasons why this land should not be used for development.

1. It is prime agricultural land and has been farmed continually for over 80 years.

2. In the spring and summer the sound of skylarks abounds across the farm, bats are numerous in the evenings deer and other wildlife use it as a corridor from the sea to the downs.

3. The loss of a valued view across to Bosham and north to the downs and Kingley Value.

4. Increased risk of flooding along the A259, already a problem when high tides combine with a storm and heavy rain. Something which is becoming more frequent with global warming.

5. Fishbourne has a high water table and this leads to problems with rising sewage at times when there is continual heavy rain.

6. More homes would put more pressure on already crumbling lanes and roads.

7. No Dr Surgery, no room at the school and no local shops puts extra traffic on the roads, extra traffic, extra pollution.

8. Blackboy Lane is narrow and crumbling and not suitable for heavy construction vehicles on a large scale.

9. A rural setting lost forever.

I would ask the District Council to reconsider their proposals for development in Fisbourne. Especially in regard to Bethwines Farm.

Attachments:

Object

Local Plan Review: Preferred Approach 2016-2035

Representation ID: 2900

Received: 25/01/2019

Respondent: Matthew Folkes

Representation Summary:

Objection to Bethwines Farm:

1. Blackboy Lane is very narrow and cannot be widened.
2. School is full.
3. Loss of village identity.
4. Bethwines Farm is good arable land.
5. Bats, Deer, Foxes, Rabbits, Skylarks and many more - need open space.
6. Fishbourne has flooded in the past.
7. Fishbourne has already taken its quota for building in the village and more.
8. Fishbourne Harbour is an AONB.
9. The A27 which is already overloaded.
10. A smaller development on Bethwines Farm, will turn into a larger development of over 1000 homes.

Full text:

I am writing to object very strongly to any proposed building on Bethwines Farm.

Here are my reasons:
1. Blackboy Lane is a very narrow lane, that can not be widened. Any building on Bethwines Farm will create too much traffic for Blackboy Lane and create bottle necks at both ends where the lane narrows.
2. Fishbourne school is already full and can not take any more.
3. I always used to hear people say Fishbourne is a nice place to live, well it will no longer be a nice place to live with any building on Bethwines Farm. Any development will soon turn into a large development and will be very detrimental to Fishbourne.
Fishbourne will lose its village identity.
4. Bethwines Farm is perfectly good sustainable arable land and has been farmed on for over 80 years. It must not be built on.
5. On Bethwines Farm I see and hear wildlife passing by all the time. There are Bats, Deer, Foxes, Rabbits, Skylarks and many more, they need that vital wide open space, which will be devastated if there is any building on Bethwines.
6. Fisbourne has flooded in the past, any building on Bethwines Farm will make it worse.
7. Fishbourne has already taken its quota for building in the village and more. It is not sustainable to build on Bethwines Farm.
8. Fishbourne Harbour is an area of outstanding natural beauty and will be in grave danger of being over used, if there is more building, especially on Bethwines Farm.
9. The A27 which is already over loaded, is not currently being improved. So therefore no more building can be allowed to take place.
10. A smaller development on Bethwines Farm, will turn into a larger development of over 1000 homes. This is not sustainable.

I am very angry with the idea of building on Bethwines Farm. I have lived in Fishbourne all of my life and do not wish to see any more developments.
When will we stop and really think about environment around us, because if we do not look after it, then it can not look after us.

Attachments:

Support

Local Plan Review: Preferred Approach 2016-2035

Representation ID: 3028

Received: 06/02/2019

Respondent: William Lacey Group

Agent: Strutt and Parker LLP

Representation Summary:

Support allocation of 250 dwellings however recommend amend policy wording to make NP review should consider meeting need through allocation of mix of small and large sites

Full text:

See attachment

Object

Local Plan Review: Preferred Approach 2016-2035

Representation ID: 3055

Received: 06/02/2019

Respondent: Mrs J C Fellows

Representation Summary:

- Residents against development on Bethwines Farm
- Lack of infrastructure - medical facilities, no shops, no post office, shortage of school places, possible reduction in bus services, condition roads.
- Traffic getting worse
- Blackboy Lane and Clay Lane unsuitable for additional vehicles.

Full text:

See attachment

Attachments:

Object

Local Plan Review: Preferred Approach 2016-2035

Representation ID: 3081

Received: 29/01/2019

Respondent: Mr Ronald Gawen

Representation Summary:

- Clay Lane - too much traffic, unsafe for pedestrians and cycle route.
- Drainage problems - new development will take away any natural green fields drainage.
- Fisbourne should remain as village and not an extension of Chichester and Bosham.
- Blackboy Lane should keep the SPA line as it has been.
- The school is at its capacity.
- The doctors are at their limit. Chichester hospital is at capacity.
- Infrastructure around the village is poor.

Full text:

See attachment

Attachments:

Object

Local Plan Review: Preferred Approach 2016-2035

Representation ID: 3091

Received: 06/02/2019

Respondent: Chichester Harbour Conservancy

Representation Summary:

Object on the following grounds:
* Major development on the fringe of the AONB.
* Affect buffer zone outside the AONB.
* Breach of current and emerging AONB Management Plan
* SSSI Interest Impact Risk Zone, which affects the SAC, SPA and Ramsar designations.
*Wildlife
* Views
* Highest quality agricultural land
* Urbanisation
* Light, air, noise, and soil pollution.
* Wastewater
* Inadequate mitigation

Full text:

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Object

Local Plan Review: Preferred Approach 2016-2035

Representation ID: 3123

Received: 01/02/2019

Respondent: Mr Roy Bailey

Representation Summary:

Object on the basis of the following:
- School at capacity
- Apuldram sewage works have no more capacity
- Bethwines farm is grade 2 farmland
- Bethwines farm is wildlife friendly
- Bethwines farm is in designated gap

Full text:

See attachment

Attachments:

Object

Local Plan Review: Preferred Approach 2016-2035

Representation ID: 3149

Received: 31/01/2019

Respondent: Alastair Alexander

Representation Summary:

Object to Fishbourne allocation on the following grounds:
- Proposal against government policy
- Infrastructure
- Traffic congestion and air pollution
- School at capacity
- Lack of retail
- Poor public transport
- Impact on Chichester Harbour AONB, SSSI, SPA and SAC
- Lack of information on proposed wildlife corridors

Full text:

See attachment

Attachments:

Object

Local Plan Review: Preferred Approach 2016-2035

Representation ID: 3158

Received: 07/02/2019

Respondent: Mrs Rosamond Ticehurst

Representation Summary:

Object on the basis of the following:
- Arable field
- Liable to flooding
- Sewage, Apuldram limitations
- Light pollution, noise and traffic.
- Blackboy Lane cannot cope with any more traffic
- Loss of wildlife
- School is full
- No public transport
- Doctors oversubscribed

Full text:

See attachment

Attachments:

Object

Local Plan Review: Preferred Approach 2016-2035

Representation ID: 3159

Received: 22/01/2019

Respondent: Annie Stephens

Representation Summary:

Object on the basis of the following:

- Fishbourne should not a service village
- Primary school is full. Children travelling to Chidham and Southbourne.
- No shops, only a few small businesses
- No doctors
- Village dentist is private
- Apuldram at capacity
- Flood risk/high water table
- Bethwines farm outside settlement and within designated gap
- WSCC struggling to maintain roads
- Loss of wildlife
- Grade 2 farmland should not be built on
- NP allocated sites but did not include Bethwines Farm
- Major developments will ruin village individuality
- House sales slowing down

Full text:

See attachment

Attachments:

Object

Local Plan Review: Preferred Approach 2016-2035

Representation ID: 3163

Received: 06/02/2019

Respondent: Maurice Bradbury

Number of people: 2

Representation Summary:

Objection to Bethwines Farm:
- extends village into open countryside
- Clay Lane, Blackboy Lane and Salthill Road unsuitable for current levels of traffic
- Urban sprawl from Chichester to Bosham
- Pressure on Doctors and School

Full text:

See attachment

Attachments:

Object

Local Plan Review: Preferred Approach 2016-2035

Representation ID: 3164

Received: 30/01/2019

Respondent: Maurice and Jane Young

Number of people: 2

Representation Summary:

Objection to Bethwines Farm:
- Arable land
- Loss of strategic gap
- High water level
- Shortage of school places
- Overstretched doctors
- Traffic jams - unhygienic atmosphere

Full text:

See attachment

Attachments:

Support

Local Plan Review: Preferred Approach 2016-2035

Representation ID: 3225

Received: 07/02/2019

Respondent: The Feltham Family

Agent: Henry Adams Planning Ltd

Representation Summary:

Support policy and offer Land east of Clay Lane as available for resi devt (23 dwellings approx.)

Full text:

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Support

Local Plan Review: Preferred Approach 2016-2035

Representation ID: 3230

Received: 07/02/2019

Respondent: The Smith Family

Agent: Henry Adams Planning Ltd

Representation Summary:

Support policy - promote land south of Clay Lane - could accommodate 15 units.

Full text:

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Support

Local Plan Review: Preferred Approach 2016-2035

Representation ID: 3259

Received: 07/02/2019

Respondent: WSCC (Estates)

Agent: Henry Adams LLP

Representation Summary:

Promote land to east of Deeside Avenue, available for at least 50 units.

Land is currently identified as community purposes in NP but the land is locked therefore NP proposal is not implementable.

Full text:

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Support

Local Plan Review: Preferred Approach 2016-2035

Representation ID: 3276

Received: 06/02/2019

Respondent: Landacre Developments Ltd

Agent: Genesis Town Planning

Representation Summary:

Support allocation of land for minimum 250 dwellings at Fishbourne as reflects ranking in settlement hierarchy as a larger service village. Prefer principle of having more than one site to meet strategic allocation as part of a dispersed strategy across the District. Spreading development over more than one site assists short term housing delivery and minimises long lead in times. Associated community infrastructure could still be delivered over more than one site in accordance with the Infrastructure Delivery Plan's requirements in policy S12 and the CIL levy.

Full text:

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