Updated technical evidence

The Oving junction works are not an improvement. Congestion has not noticeably improved

Paras 2.8 to 2.12
That the bypass at Chichester is running over-capacity has been evident to all for years-including National Highways. Funds to deal with mitigations on four roundabouts in an over-capacity scenario are unachievable: this supports the point 2.1 that the bypass is the responsibility of National Highways to deal with. The A27 at Chichester must be brought into RIS 3.
The ‘Monitor and Manage’ approach ‘try to provide additional reductions in trips on the network .....etc’ (Para 2.11) on only two of four roundabouts is not an effective solution , is an open-ended endorsement of an unacceptable situation.

2.6 & 2.7 We are concerned by the funding shortfall. This must not lead to a situation where building is permitted on the promise/hope of funding for road infrastructure at a later stage.

2.11 We are also very concerned that it is considered acceptable to "try to provide" rather than actually indicate how "additional trips .... through sustainable transport measures" would be achieved. Further that it is proposed to make "other small-scale local highway network interventions" when it has been clear for many years and identified in 2016 that only major work for the Fishbourne roundabout will be credible.

2.11 Representation on the proposed TIMG must seek to include members or organisations who can more accurately report on local trip activities and infrastructure desirability within the affected local highway networks.

2.12 It would be enormously helpful to have the "Infrastructure Constrained Approach" and "Monitor and Manage Process" depicted in flow diagram form to help indicate how they are implemented and act to control congestion on the A27 Chichester Bypass. The former suggests that housing delivery rate and total housing number delivered will be reduced according to incremental congestion feedback detected (on a yearly basis?) on the A27 above the January 2023 levels. The latter Process appears to offer mitigation opportunities (alternative local transport network schemes) over far shorter time-frames under each specific application (Fishbourne then Bognor Roundabouts) of the Approach?

The bypass at Chichester is running over-capacity has been evident to all for years-including National Highways. Funds to deal with mitigations on four roundabouts in an over-capacity scenario are unachievable: this supports the point 2.1 that the bypass is the responsibility of National Highways to deal with. The A27 at Chichester must be brought into RIS 3. The ‘Monitor and Manage’ approach ‘try to provide additional reductions in trips on the network .....etc’ (Para 2.11) on only two of four roundabouts is not an effective solution , is an open-ended endorsement of an unacceptable situation.

• The CATM model has been validated and calibrated using 2014 counts. Using 2014 data means that significant changes such as the opening of Chichester Free School immediately next to the A27 Whyke roundabout, with over 1000 pupils and over 140 staff may not have been considered.

• This data is now 9 years old.
 
• The Transport Assessment states that "it should be noted that even prior to adding in the Local Plan development, all the junctions on the A27 Chichester bypass are over capacity in one or both modelled peak hours. With the exception of Portfield Roundabout, the junctions are also shown to be over or very near capacity in the base year model (2014) before any additional background or Local Plan traffic is added, highlighting the fact that it is not just the Local Plan or committed Chichester development which leads to this situation." 

Whilst only 28% of traffic growth can be linked to committed and proposed Local Plan developments, if the mitigation measures only apply to Fishbourne and Bognor roundabouts, then the problem with over capacity still remains. 

Therefore, the plan is not effectively mitigating the impact of the addition growth and is adding further demands on capacity which is already exceeded, therefore the housing number should be challenged further.

Under the monitor and manage aspects to the A27 junctions, the Local Plan states that a Traffic and Infrastructure Management Group (TIMG) will be set up to oversee the delivery of this process. Improvements to the A27 have been contentious in the past, with the DfT public consultation in 2016 as part of Road investment strategy 1 (RIS1), resulting in no consensus from the consultation feedback on which option should be taken forward. The Local Plan consultation in 2018, also raised significant feedback on the proposed changes to the A27, particularly regarding restricting local movements at key junctions and the Stockbridge Link Road, where the proposals were similar to those options robustly rejected in the RIS 1 consultation. The Local Plan does not provide any details on how representatives will be selected to be part of TIMG, nor how local residents will be consulted on the delivery of any changes as part of the monitor and manage process. This therefore, could present an opportunity for circumventing legitimate local concerns and feedback on any proposals to be delivered under this group.

National Highways cannot argue against the fact that the A27 at Chichester has been running at overcapacity for a number of years. The situation is getting worse. CDC cannot fund the critical mitigations on four roundabouts in this over capacity scenario: supporting 2.1 that the bypass is the responsibility of National Highways. Para 2.11, ‘Monitor and Manage’, to ‘try to provide additional reductions in trips on the network” is not an effective solution and, by only considering the Fishbourne and Bognor junctions, appears an open-ended endorsement of an unacceptable situation. The A27 at Chichester must be brought into RIS3.

On behalf of our clients, Rydon Homes Ltd we hereby provide comments on the draft A27 Chichester Bypass Mitigation SPD. Please find attached the completed representation forms which set out the basis of our objections together with suggested modifications.

Our objections are made in light of a current planning application that has been submitted by our clients for land to the north-west of 56 Stane Street (Rohan Stables), Halnaker for 26 dwellings (CDC ref: BX/23/02169/FUL).
The comments draw on expert transport advice provided to our clients by RPS Transport which is set out in the enclosed Technical Note.

Our clients object to the requirements placed on developments arising from the proposals
set out in the SPD for the reasons set out in the four enclosed representation forms.

We trust that the representations are clear and that the District Council will consider
these carefully as part of the ongoing consultation process.

Thank you for the opportunity to comment on the A27 Chichester Bypass Mitigation Supplementary Planning Document (SPD). Please see below the officer comments from WSCC. The comments highlight key issues and suggest changes to the SPD. We look forward to working with CDC officers in the preparation of this document.

Paragraph 1.2: Comment

The technical evidence base assesses the impact of new development on the transport network as a whole, not just on the A27 Chichester Bypass. Also, the mitigation package is likely to include interventions on A27 and local roads.

Change required: the SPD introduction section should acknowledge the impact on the transport network rather than focusing solely on the impact on A27.

Paragraph 2.2: Comment

National planning and transport policies place emphasis on reducing the need to travel and promoting use of sustainable modes of transport.

Change required: It is expected that a sustainable transport package would be provided to serve as part of the package to mitigate the impacts of development on the transport network. Within the City and on other local roads, it is expected that sustainable transport interventions will be prioritised to encourage use of active travel and shared transport and avoid encouraging more traffic into the City. The sustainable transport package should include schemes such as those being developed as part of the West Sussex Transport Plan. In general, these schemes are multi-modal and intended to improve the experience for all users of the transport network. These will help to mitigate the impacts of development from the adopted Local Plan and improve facilities for existing users so will attract funding from other sources.

Paragraphs 2.13, 3.3, 4.10, 4.24: Comment

The SPD makes various references to a ‘cap’ on the level of development that can come forward but it is unclear whether this approach is consistent with Paragraph 111 of NPPF as development should only be refused on transport grounds if there would be an unacceptable impact on highway safety or the residual impacts on the road network would be severe.

Clarification requested: CDC should consider whether these references should be changed to comply with NPPF Paragraph 111.

Sections 2 and 4: Comment

The SPD currently places heavy reliance on highway capacity improvements at the A27 junctions to mitigate the impacts of development. Whilst the County Council acknowledges that improvements are needed to mitigate the impacts of development on the A27, the design of mitigation measures and the location of these measures should be influenced by a range of factors including, for example; the location of development, the effectiveness of measures to minimise traffic growth, and the timing of developer contributions towards mitigation.
Change required: We suggest that the SPD should be less specific about the nature and sequencing of the improvements. Instead of that, we suggest that CDC should be invested in a range of schemes, including local road improvements that improve sustainable transport facilities alongside A27 improvements. The rate and sequence by which these are brought forward should be under the overview and recommendation of the Transport and Infrastructure Management Group. That way the envisioned delivery will not only be focused on highway infrastructure and/or traffic control.

Section 4: Comment

Although cost estimates have been produced, it should be acknowledged that these schemes are at an early stage of development and may change in scope as schemes mature in response to further technical work on design and consultation with stakeholders. Therefore, the final cost of schemes is not fixed, as anything produced at this stage is only an outline design stage estimate (from low to highpoint) and general inflation is not the only feasible reason why costs could change over time.

Change required: We consider that the SPD should explain this. In particular, schemes requiring major earthworks or potential use of third-party land such as the diversion of Terminus Road from Fishbourne junction to Cathedral Way will require feasibility stage design to increase certainty over delivery cost and land take, which may affect the cost estimate.

Overall, there is a range of transport infrastructure improvements that could be used to mitigate the impacts of development and the County Council considers that a wider range of projects should be taken into account in the calculations for developer contributions. Other than those to be delivered directly by developments, the following multi-modal schemes should be considered when calculating developer contributions due to the role they could provide in mitigating the impacts of development. In general, the County Council aims to secure around 50% of the cost of these schemes from developer contributions with the remainder coming from other sources:

• A285 Chichester – Tangmere Sustainable Transport Corridor – cost £6,600,000
• City Centre to Portfield (via Oving Rd) Sustainable Transport Corridor - cost £3,500,000
• Northgate Gyratory Improvement – cost £7,300,000
• A259 Chichester to Bognor Regis Sustainable Transport Corridor Improvement Scheme - cost £45,103,000 (this scheme would include developer contributions from Arun District, as well as Chichester District)

Change required: As the cost of the improvements is likely to exceed what it is viable to secure through the planning system, the County Council requests that references to such potential improvements are referenced generically. This should also help to provide flexibility in how developer contributions are utilised.

Paragraph 2.12 – change required

In line with the above, it is best not to fix the implementation of an improvement at the Fishbourne junction as necessarily being ahead of the Bognor Road junction

Background Section 2.11

Mention is made of the need for ‘sustainable Transport measures’ being part of improvements required to the two junctions and ancillary works; however nowhere in the policy does it specify the type of sustainable measures required. The policy needs to amended.

The policy needs to be amended to require that at least 25 % of the financial contributions should be used for sustainable and active travel measures, including mitigation measures to reduce the number of private vehicle trips. See also my objection to submitted Local Plan in relation to Policy 8a, section 8.

Planning Obligations Section 4.1

In quoting from the STANTEC Jan. 2023 no reference is made, other than trip generation, as to how Sustainable and Active travel will be encouraged and provided for in the use of the financial contributions sought. The ‘monitor and manage’ approach seems to assume that the current modal split of use of these junctions and associated roads will continue and be perpetuated when the improvements take place. This in turn will give even greater preference to current road vehicle use. How will modal shift be achieved?

As with my previous objection this requires a clear policy requiring at least 25% of contributions to be spent on sustainable and active travel improvements which will result in reduced trip generation and greater longevity to the necessary improvements. This will, et al, provide better value for money.

Background Section 2.11

Mention is made of the need for ‘sustainable Transport measures’ being part of improvements required to the two junctions and ancillary works; however nowhere in the policy does it specify the type of sustainable measures required. The policy needs to amended.

The policy needs to be amended to require that at least 25 % of the financial contributions should be used for sustainable and active travel measures, including mitigation measures to reduce the number of private vehicle trips. See also my objection to submitted Local Plan in relation to Policy 8a, section 8.

Planning Obligations Section 4.1

In quoting from the STANTEC Jan. 2023 no reference is made, other than trip generation, as to how Sustainable and Active travel will be encouraged and provided for in the use of the financial contributions sought. The ‘monitor and manage’ approach seems to assume that the current modal split of use of these junctions and associated roads will continue and be perpetuated when the improvements take place. This in turn will give even greater preference to current road vehicle use. How will modal shift be achieved?

As with my previous objection this requires a clear policy requiring at least 25% of contributions to be spent on sustainable and active travel improvements which will result in reduced trip generation and greater longevity to the necessary improvements. This will, et al, provide better value for money.