The 2016 Planning Obligations & Affordable Housing SPD

If this had been adopted and actioned many years ago most of the present problems could have been averted. Does it really take all this red tape and hours of time to produce documents which don't add to the easement of the A27 ? Of course things move on over the years - anticipation is needed. Thousands of new homes mean a three lane A27 will be needed. I suggest that work begins now and not in twenty years time when traffic will have ground to a halt and nothing will move at all.

2016 Planning obligations and Affordable Housing SPD
Para 2.7 “The Council has continued to press for improvements to the A27 Chichester Bypass to be addressed by central government funding and there has been continual engagement between the Council and National Highways over the past decade seeking to achieve this end. However, in spite of these efforts, no other sources of funding have been made available to address the shortfall from the funding secured through development contributions”.
Comment: Pressing National Highways for funding will be fruitless as it regards CDC as solely responsible. As will be shown later, this process will take years, if ever, to be concluded. See Comment in the Planning Contributions section.

CDC needs to demonstrate to our MP (not to National Highways) the pressing need for her to engage with the SoS for Transport with the aim of bringing the A27 at Chichester out of its current uncommitted ‘pipeline’ ranking in RIS 4 (2030 to 2035) back to RIS 3 (2025 to 2030)-see page 94 in the Route Strategy in https://nationalhighways.co.uk/RS-South-Coast-Central.
RIS 3 will take effect before the pursuit of mitigations through increasing developer contributions can (if ever achieved) with costs inevitably continuing to rise along the way and requirements changing. It should also be noted that this will only cover the Fishbourne and Bognor roundabouts and not include the Stockbridge and Whyke junctions, thus delivering an unsatisfactory outcome.

2.3 Given the over capacity of the road use, and the fact that all Fishbourne's facilities and services are fully stretched, this document needs to go further than Policy 9 and remove "where appropriate"

2.6 We are very concerned about the shortfall in funding as a result of inflation and lack of support from HM Government.

2.4 Although the improvement works to Portfield Roundabout and Oving Road junction have been completed, it is debatable whether any improvements have actually been realised as a result. Further improvements must remain a consideration for them.

Pressing National Highways for funding will be fruitless as it regards CDC as solely responsible. CDC needs to demonstrate to our MP (not to National Highways) the pressing need for her to engage with the SoS for Transport to bring the A27 at Chichester out of its current uncommitted ‘pipeline’ ranking in RIS 4 (2030 to 2035) back to RIS 3 (2025 to 2030)

Nothing will come from engaging with National Highways as they regard CDC as solely responsible. In the interim costs will rise, requirements will change and the process will be unnecessarily protracted. Importantly this only covers the Fishbourne and Bognor roundabouts and does not address congestion at the Stockbridge and Whyke junctions. Sidlesham PC has written to our MP encouraging engagement with the SoS for Transport; the aim to bring the A27 at Chichester out of its uncommitted ‘pipeline’ ranking in RIS 4 (2030-35) back to RIS 3 (2025-30). CDC must demonstrate the same resolve

Response to 2.4 It must be noted that the 2013 relevant evidence base was found wanting by the Inspector of the Local Plan, hence her requirement for the Council to revisit this evidence within five years. This was not done and the 2016 Planning Obligations & Affordable Housing SPD was put forward for consultation on evidence that was not subject of examination. PPG advises that it is not appropriate for plan-makers to set out new formulaic approaches to Planning Obligations in supplementary planning documents or supporting evidence base documents, as these would not be subject to examination.
Response to 2.8 The evidence produced to inform the emerging Local plan 2021-2039 has not been examined therefore cannot be relied on at this stage to be robust or correct.

1. Introduction

The proposed Draft SPD re A27Chichester Bypass Mitigation A27 relates to the presumption of future housing developments, their impact on the A27 and related developer contributions to pay for any (unspecified) mitigation measures as a consequence of those developments.

Is the intention of CDC to allocate 100% of Developer contributions for the partial upgrade of some A27
junctions impacted by those developments? How does this ensure that developers pay for a fairer share of affordable housing and other local infrastructure as the Government announced on 17 March 2023?

Setting to one side CDC’s (and WSCC) sorrowful track record of rejecting Central Government's inward investment despite WSCC’s announcement on 25 Jun 2015 (“£350m investment welcomed by WSCC” that
…”confirmed the existing commitment to upgrade the four junctions on the Chichester Bypass”) it was clear that the junction capacity and highway safety issues were known when the funding was on offer from Highways England. Since that time it has become clear that CDC need additional funding to deliver mitigations necessary for the development of a sound Local Plan.

So why in ?2017 did CDC/WSCC inexplicably request the A286 South of Chichester to be removed from available funding from the Major Road Network MRN? Indeed there is no convincing evidence within this SPD which confirms that the Department for Transport has been requested by CDC/WSCC for the A286 South of Chichester be once again included in the MRN funding scheme. By so doing WSCC would play their part in assisting CDC in delivering a robust Local Plan for the benefit of the whole Chichester
Community.

Without any evidence of seeking and securing alternative funding sources the Chichester community are now being asked to accept that additional funding for infrastructure upgrade is to be funded by future housing developments but only in respect of the impact of those developments. The impact of course will simply add to the infrastructure deficit that has now reached its nadir in the Chichester area.

There needs to be a clear correlation between the capacity of the landscape to absorb new housing numbers, certainty from National Highways, MRN and others in relation to funding improvements to alleviate the current congestion and certainty from Southern Water as to when their improvements are to be completed to the sewerage infrastructure.

We object to the proposed draft SPD because the infrastructure remains deficient to support more housing
and secondly CDC would forever be indebted to the commercial vagaries of developers set against a moving target of viability tests with new more affordable housing models. It is entirely dependent on the granting of planning approvals and potential developer funding.

This is not a sustainable solution and the draft mitigation SPD should therefore be dismissed.

OTHER RELATED MATTERS

1. Ministerial comments from the Secretary of State for Levelling-up, Housing and Communities (Housing Today 27 June 2023) and the letter sent to MPs state that the Levelling-up and Regeneration Bill would be amended to abolish local mandatory house building targets as
"there is no truly objective way of calculating how many new homes are needed in an area".

2. This change makes the centrally determined target a "starting point", with councils able to propose building fewer homes if they faced "genuine constraints" or would have to build at a density that would "significantly change the character of their area”.

3. The Secretary of State has also been quoted as saying that the planning system is "not working as it should" and that new development must have "the support of the local communities" and added that it must be accompanied by the right infrastructure.

4. Constraints to more housing development are manifest and include the erosion of the character of our erstwhile rural Sussex and losing some of the most productive and versatile land for agriculture.

5. Some development allocations in the draft Local Plan do not meet the criterion of being remotely acceptable to the local population who despair regarding infrastructure deficit whilst housing proliferates. Further depletion of our green fields coupled with new housing adding to the already outdated and failing sewage system detract from the area as a tourist destination and the discharges of raw sewage into our rivers and sea are hitting the local economy.

6. The draft SPD provides no funding for upgrading the A27 junctions to alleviate the current congestion. Such future developments as proposed should therefore be disallowed until such time as the A27 upgrade has been implemented to cater for the existing traffic issues.

7. There is a lack of certainty that the developer contributions sums will not be adjusted downwards as the result of developers contesting the viability studies. At the very least the quantum of affordable houses are likely to be reduced.

8. With the uncertain UK economic environment due in part only to climate change which will affect what and where we build there is no guarantee that this proposal will be realised as envisaged. The proposed SPD is not therefore a sound basis for the upgrading of the
infrastructure to meet any agreed future housing needs.

9. Local residents in general feel there needs to be a moratorium on large scale development that do not address local housing needs until the sewage and roads issues are resolved. In terms of future housing, we need to prioritise social housing and low-cost starter homes as these are needed by local people in a low wage economy. It would help greatly to have a housing target that is both realistic and recognises local need.

1.7 The logical approach to mitigation of the traffic congestion at the SRN Chichester A27 junctions is firstly
for National Highways and others to fund and to carry out such work to normalise the current congestion. In addition for CDC with WSCC to source additional funding other than the SRN/ MRN. A “cocktail of funding sources” was promised by WSCC). Developer contributions would then be available for other mitigation issues where developments impact on existing infrastructure.

This “new approach to A27 mitigation” means CDC propose to fund the mitigation of the impact of future
development whilst leaving the current congestion untouched. This ‘kicking the can down the road’ is not a
solution and neither is granting further permissions for housing without dealing with the current infrastructure
deficit.

2. Background

2.6 The improvement works to the Fishbourne, Bognor, Stockbridge and Whyke junctions were all included in the HE funding offer rejected by CDC and WSCC in ?2018 Thus there was not an “absence of Government funding” (ref4,1). It would never (despite inflation and cost escalation) have been affordable from developer contributions.

2.7 It is an egregious error to claim that no funding was available from central government over the past decade. The absence of Government funding was due to the decision by CDC and WSCC not to accept what was on offer.

Have CDC/WSCC followed funding from the MRN programme. It is understood that this was also turned
down by WSCC in?2018. Can it be rejuvenated for the A286 south of Chichester? Is the Bognor road junction a candidate?

2.15 The viability was presumably based on the historical housing models so favoured by developers to maximise their profits. In future the housing models need to change because affordability will become a major criterion for purchasers. This will lead to different types of housing that are affordable and therefore challenge the historical viability studies.

4. Planning Contributions

4.1 There is little evidence to provide confidence that funding sources from Government and others have
been robustly pursued.

Have CDC/WSCC fully explored funding via the MRN (funding stream remote from RIS) which they had
previously rejected despite being available for the A286?