Policy AL13: Southbourne Parish

4.4.2 and Table 3 4.6.4 , 4.7.3 Sustainability Appraisal 010

This Sustainability Appraisal is full of highly subjective notions which leads its impact assessments to be generally questionable ie on whether an option has a positive or negative impact on eg biodiversity.
In para 4.4.2 who were the "further discussions" with to cause scenario 1a to be added ?
Para 4.6.4. in trying to justify the allocation of 1250 dwellings to Southbourne, it talks of the "potential advantages" but does not mention the obvious disadvantages in almost doubling the population of this village. What provisions will the plan make eg to ensure that the Southbourne railway station is capable of handling possibly a doubling of passenger traffic.? The answer is that it can't because investment in the railway network is outside it's jurisdiction. I would only support an option that shares any new housing more evenly between settlements which is more likely to limit the obvious damage that is going to be caused to natural habitats by this Local Plan review.

What improvements or changes would you suggest?

As above.

003 Housing and Econ Devt

This document appears to rely for it's conclusion of new housing numbers on the unbridled continuation of economic growth levels through the Plan period to 2035[par a 1.17].I believe that this is an unsustainable model on which to plan the future for our children and grandchildren.
There is no attempt that I can see to apply some sort of sensitivity analysis to the single end figure of 609 dwellings per annum so that lower numbers could be chosen as a preferred option. There are many factors which could influence housing numbers over the long Plan period so it would seem sensible to start with lower numbers to try and reduce the inevitable negative impact on natural habitats that any increase in human numbers will cause.

What improvements or changes would you suggest? As stated above

5.5 in particular Strategic Wildlife Corridors Background Paper

Whilst supporting the concept of Wildlife Corridors in the Plan [why was this not done 20 years ago ?] I do object to the removal from the Plan Review of the Chidham/East of Nutbourne Wildlife Corridor. If the Southbourne Neighbourhood Plan Review [SNPR] wishes to give more priority to natural habitats then it can devise policies which avoid "the close proximity of...proposed development" cited in paragraph 5.5.
Glossary - Wildlife Corridors are not defined in the Glossary and should be included.

What improvements or changes would you suggest? As stated above.

All but especially sub-areas 82 and 83 Landscape Capacity Study - 007

Apart from it being a useful inventory of landscape types in Chichester District, this document appears to me a rather pointless exercise in Planning fudge. For example on page 496 in is saying that development could be accommodated etc etc at the same time as avoiding any "landscape or visual harm " This sort of language is found all over this document and givers too many opportunities for misunderstanding or misinterpretation.
It would have been helpful to have page numbers for the sub-areas. As it is the location of sections is prolonged.

What improvements or changes would you suggest?

Avoid attempts to give facile conclusions and recommendations.

Paras 5 and 7 various Natural Environment

Para 5.51 [Strategic Policies] suggests the Council will only object to development that causes "significant harm" to the function of the natural environment but there is no definition of this phrase
7.168 Is stating that "providing open space, sport and recreation is part of "protecting and enhancing the natural environment" This is not true as these are all man-made features designed for humans, not for nature.
Para 7.189 and others mention "priority habitats" but I can see nowhere in the Plan Review that identifies the 21 types of these habitats mapped in Sussex* either by list or on a map of the District.These important habitats are often overlooked when development applications are made [eg ref 16/03569/OUT] and this Plan is a good opportunity to draw the public's attention to those in their area.
Para 7.189 refers to a Map 5.1 but gives no easy reference to where this can be found ?
Note: *Sussex Biodiversity Record Centre records these as "Habitats of Principal Importance" - which designation is correct ?
Glossary issues: Priority Habitats are missing and should be included in the Glossary in the Plan Review.

I am writing in response to two particular areas: Land north of Woodfield Park Road (SHLAA ref HT08284) HSB 0006 and adjacent plot HSB0007 which is south of the railway line and north of the A259, behind Southbourne Road.

I feel that development of these two areas is not compatible with the west of city wildlife corridors, and urge you to take these two areas out of the plan for land to be developed in the future. A screen shot of the wildlife corridor is shown on the adjacent map, clearly showing the land areas in question.

In addition, the development of the land HSB0007 (south of the railway line) will seriously impact the amount of green space between Hermitage and Westbourne - your policy states that the identity of the separate settlements should be maintained.

Loss of green space north of the A259 in these two plots of land will mean that even more people will have to use the land adjacent to the harbour, creating even more activity around the harbour and away from the countryside.

Further development of these two areas (HSB 0006 and 0007) will not deliver the 1250 homes due in Southbourne, and I feel that it would be better to have a strategic development area which can better provide facilities and infrastructure for the new homes.

It would be scandalous to use every bit of green space and still have to develop larger tranches of land to deliver the 1250 homes that Southbourne has been allocated - far more than in any other area in the district.

I hope you will take these two areas out of the potential development area for the reasons stated, and look forward to your response.

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

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

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


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


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

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

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

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

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

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

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

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

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

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


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

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

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

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

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

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

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

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

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

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

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

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


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

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

AL1 Land West of Chichester

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

AL2 Land at Shopwhyke (Oving Parish)

No update to original response for this allocation is required.

AL3 Land East of Chichester - previously South of Shopwhyke

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

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

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

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

AL4 Land at Westhampnett / North East Chichester

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

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

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

AL5 Southern Gateway

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

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

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

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

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

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

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

AL7 Bosham

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

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

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

AL9 Fishbourne

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

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

AL8 East Wittering

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

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

AL10 Chidham and Hambrook area

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

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

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

AL11 Hunston

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

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

AL12 Selsey

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

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

AL13 Southbourne

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

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

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

AL14 Tangmere

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

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

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


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

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

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

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

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


Additional Policy Comments

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

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

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

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


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


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


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


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

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

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

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

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

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


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


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

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

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


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


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

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

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


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


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

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


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

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

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


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

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


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


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

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

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

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



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

AL6 extent

Current Flood Zone 3 extent.

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

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

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


Key:
AL6 boundary.

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

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

Map 2 Groundwater flood risk JBA

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


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


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

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


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

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


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

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


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

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


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


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

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

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


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


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


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


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


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


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


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


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

AL13- Southbourne
Southbourne level crossing causes a huge traffic problem as the gates are closed which is quite frequent. Any developments north of that crossing will only exacerbate the problem. Roads to the north of the village are narrow country lanes and cannot sustain any further traffic flow being already heavily utilised. South of the gates is also a problem because of vehicles parked on either side of Stein Road and this is compounded when the gates open.
The propsed plans show that there will be an increase in commercial premises, this again increases traffic especially vans and lorries. With all the current developments in progress I question whether the infrastructure is sufficient? Further development can only make this worse. For example in heavy rain stein road cannot take the surface water now.
No consideration appears to have been made with regard to Doctors surgery and how that is impacted by future development.
This all seems to be village creep along the A259, Southbourne itself is already made up of 3 villages (Southbourne, Breach, Prinsted)

What improvements or changes would you suggest?
The main improvement required is to sort out the traffic problems caused by the level crossing. This would probably require a road bridge across the railway line.

AL13 127-129

We object to the proposed development of 1250 houses in Southbourne, the village had already agreed to take 350 houses which will have a significant impact on this community in terms of doctors/school/traffic pollution. We note that in your documents you do not show the map for Southbourne indicating development sites, however when we attended the local presentation we saw marked sites and we particularly object to any development to the north of the village as this would mean extending this village to an unacceptable level and the loss of green fields which are at present farmed. There are no longer any buses that run through Southbourne the nearest being on the A259 which is 1 mile+ from the north end so therefore any development here would mean more cars per household which would be used to take children to school and would have a significant impact on Stein Road which is already a busy road exacerbated by the level crossing that causes huge queues. There are very few facilities north of the railway.

What improvements or changes would you suggest?

Do not consider north.

Thank you for the consultation on the above document. We have reviewed the document and have the following comments to make in response.

Summary
Overall we are pleased to see that the Plan provides a framework to ensure that new
development will take place in a considered manner to address environmental constraints as well as provide policy hooks for the delivery of environmental enhancements. However, to ensure that the Plan is as effective as possible and meets necessary policy and legislative requirements we have made some recommendations for improvements. These are set out in detail below. Where we support a policy we have also highlighted this below.

We have highlighted concerns with policy AL6 - Land SW of Chichester and have made recommendations for more significant changes to policies in relation to flood risk management (both strategic and development management) and wastewater management and water quality.

As a general comment we note that a significant proportion of the housing numbers
proposed through the Local Plan will be delivered by Neighbourhood Plans. We have
highlighted key criteria for individual locations that we would wish to see considered by those Plans when allocating sites. Where possible we would wish to see these included within the Local Plan policy but as you will be aware we have produced a checklist for Neighbourhood Plan groups in your District which will guide the identification of sites and other key issues and opportunities to be addressed in their Plans.
We would be happy to meet with you to discuss further any of our comments and support the rewording of the policies prior to the production of a pre-submission Plan.

Specific comments

Strategic policies
Policy S12 - Infrastructure
Overall we support the policy. We would recommend that paragraph 3 be amended to
include reference to flood risk management infrastructure.

Policy S17 - Thorney Island
We are currently exploring opportunities for habitat creation in an area on Thorney Island. This is part of our Habitat Creation Programme which seeks to create new habitat to offset losses elsewhere as a result of sea level rise and implementation of coastal and flood risk management infrastructure.
Whilst the policy as drafted, along with other policies in the Plan, would not restrict this opportunity we would like you to consider whether further wording could be included to provide specific support for habitat creation.

Policy S18 - Integrated Coastal Zone Management
We support the continued inclusion of this policy and the specific references to key Plans.
We also support the intention that financial contributions should be sought to deliver both flood risk management infrastructure as well as improvements to the quality of watercourses in the area.

Policy S20 - Design
We support the specific requirements of this policy in point 5 and 8 with regard to green infrastructure and enhancing biodiversity and climate change resilience.

Policy S23 - Transport and Accessibility
The policy includes a new road connecting Birdham Road to the A27 Fishbourne
roundabout. The site includes areas within flood zones 2 and 3 and will cross a number of watercourse. It is essential that the requirements of the NPPF paras 157-8 are satisfied prior to the allocation. We have made detailed comments on this in relation to policy AL6 - Land South West of Chichester.

Policy S25 - The Coast
We are pleased to see the support in this policy for future habitat creation as well as the delivery of flood defences and adaptation to climate change. This supports principles of net environmental gain advocated through the NPPF and the 25 Year Environmental Plan as well as providing necessary policy hooks to support our future plans through our Habitat Creation Programme.
As we highlighted through the Issues and Options consultation this Programme was set up to deliver the compensatory habitat required to address the losses in habitat that would take place as a result of the flood and coastal risk management measures identified in the Shoreline Management Plans. There are specific locations within Chichester District which offer opportunities to provide saltmarsh and coastal grazing marsh in the medium to longer term. These locations include areas in Fishbourne, Chidham and Hambrook and on Thorney Island.

Policy S26 - Natural Environment
We would recommend that the policy wording be extended to say "protect and enhance biodiversity". This is consistent with the NPPF requirements in para 170 regarding net gain and current Government proposals to mandate biodiversity net gain for all new developments.

Policy S27 - Flood Risk Management
We support the intention of the policy, however, we would wish to see changes made to ensure the policy is as clear as possible. We would also recommend you consider what a strategic policy on flood risk management is seeking to achieve in addition to the development management policy. As drafted there are some duplications and/or inconsistencies between the two policies.
It may be more prudent to have a shorter overarching policy that seeks to ensure that flood risk will be taken account of at all stages in the planning process in order to avoid inappropriate development in areas at current or future risk (taking into account climate change) and to direct development away from areas of highest risk. Reference could and should be made to the Strategic Flood Risk Assessment to enable this. We would also support a requirement here for development to seek to achieve a reduction in flood risk for existing communities on and off site.
The principle of point 3 is supported but again should be considered whether it sits best within the development management policy.
We would recommend removing point 4. It is not clear entirely what the rationale behind this is but as drafted it suggests that development within areas with a certain level of flood risk would be approved. This should only be the case when the sequential and exception test have been satisfied in accordance with the NPPF paragraph 157- 8. I would be happy to discuss this further if the intention behind the statement is different.

Policy S29 - Green Infrastructure
We support the policy and are pleased to see specific reference to "blue" infrastructure.

Policy S30 - Strategic Wildlife Corridors
We are supportive of this policy and believe it provides a strong framework for the protection and enhancement of biodiversity within the Plan Area. In particular we support the corridors along watercourses and the links with Biodiversity Opportunity Areas.
As previously highlighted in our Issues and Options response to the Local Plan the
Environment Agency are looking to deliver more natural flood management (NFM) measures to complement and support traditionally engineered flood defenses. This is about working with natural processes in whole catchments and has the potential to help us manage and reduce flood risk in a more efficient, cost effective and sustainable way whilst securing wider environmental benefits. We would be interested to discuss whether the Strategic Wildlife Corridors Background Paper could be expanded upon to consider these opportunities.
A nationally consistent set of opportunity maps to indicate potential for natural flood
management have been produced and I have attached a briefing not which shows how you can access this screening information. The identification and safeguarding of wildlife corridors could support our further work on NFM in the Chichester District and we would welcome the opportunity to discuss this further. In particular we would be interested to discuss whether the Strategic Wildlife Corridors Background Paper could be expanded upon to consider these opportunities.

Policy S31 - Wastewater Management and Water Quality
We support the intention of this policy, however, we recommend that the policy is amended to ensure that specific issues associated with the Apuldram WwTW catchment are addressed and that wider opportunities for the necessary protection and enhancements of water quality in the catchments across the Plan area are taken forward through development. As drafted the supporting text to the policy talks primarily around wastewater treatment capacity and impacts on water quality. However, we would recommend that this is expanded to discuss wider water quality and water resources issues within the Plan area.
This should include reference to the Water Framework Directive and the South East River Basin Management Plan, for which the Council has an obligation to support their delivery.
We would wish to see the Plan include a policy that will ensure that the design and location of development will both protect and enhance water bodies, both surface and groundwater.
We are aware of a few adopted policies regarding water quality that you may wish to review ahead of the further iteration of your Plan. These include policy W DM1 - Water supply and quality in the Arun Local Plan and Policy 31 - Integrated Water Management and the water cycle in the Cambridge Local Plan. The Policy in the Arun Local Plan is subdivided in to 3 sections to cover issues of water supply, water quality and catchment specific measures.
This approach or layout may be useful for you to consider here.
You may also wish to consider whether there are elements of this policy that would be better situated in a development management policy to direct decision making on individual sites.
I would be happy to work with you further to develop this policy, however, to support this the following identifies some key wording that could be included:
"All new development must demonstrate:
* That it has no adverse impact on the quality of water bodies and groundwater, or will prevent future attainment of good status;
* That development contributes positively to the water environment and its ecology and does not adversely affect surface and ground water quality"
This will reflect that impacts on water quality will not solely relate to wastewater infrastructure but can include diffuse pollution as well as physical changes to watercourses.
With regard to the specific requirements for the Apuldram WwTW the policy as drafted broadly reflects the current adopted Plan policy. Would there be an opportunity here for the policy to reflect elements of the recently endorsed Position Statement between the Environment Agency and Southern Water in terms of managing development in the catchment?
The policy makes reference to the higher building regulations standard of 110 l per person per day. We support this standard but would recommend you consider whether this detail is needed in this strategic policy as well as development management policy DM16 - Sustainable Design and Construction.

Site Allocations
Please note we have no additional comments to make on the sites that are being taken forward from the current adopted Local Plan as we consider that the key policy criteria we sought at that stage has been transposed across. We continue to support these requirements.

Policy S32 - Design Strategies for Strategic and Major Development Proposals
We support this policy and specifically requirements for issues such as green infrastructure and SuDS to be fully considered through a Masterplan. Without this overarching vision for larger sites it is often difficult to provide a comprehensive scheme to address key environmental constraints and opportunities.

Policy AL13 - Land East of Chichester
There is a small area within the site located in Flood Zone 2, along with an additional surface water body (lake). We would recommend that the masterplan for this site fully considers these constraints in designing the site including the adopting the sequential approach. We would wish to see built development located solely within Flood Zone 1.

Policy AL 5 - Southern Gateway
We have previously made comments on the proposals for the Southern Gateway through the adopted masterplan for the site. As highlighted there are a number of constraints to development in this area, however, we are pleased to see specific criteria in the policy toensure that these key constraints to the site within our remit are fully considered.
These are:
- Bullet 8 which requires the provision of a wastewater management plan which
demonstrates no net increase in flow to the Apuldram WwTW. This is in line with the
Surface Water and Foul Drainage SPD and the Position Statement on managing new
housing development in the Apuldram (Chichester) Wastewater Treatment Works
Catchment agreed between the Environment Agency and Southern Water.
- Bullet 10 which sets out the requirement for a Flood Risk Assessment to address the
specific flood risk issues on the site. We would recommend that this policy criteria
could be expanded upon to require the sequential approach within the site and to
ensure that more vulnerable uses such as housing be located in the lowest areas of
flood risk.

Policy AL6 - Land SW of Chichester
At this stage we do not support the inclusion of this site within the Plan.
The allocation is composed of housing, employment and a road scheme. Large areas of the allocation falls within flood zones 2 and 3 and we would wish to see further evidence to support this allocation. This may be as part of a Level 2 Strategic Flood Risk Assessment for this site which would then inform a Sequential and if necessary an Exceptions Test. The assessment would need to consider how the proposals could be delivered and identify any mitigation and/or compensation measures that may be necessary to ensure that the development is safe and that there is no increase in flood risk to third parties.
Whilst we note that there are areas outside of the flood plain within the allocation and that some of the development could avoid these areas it is anticipated that the road would cross the flood plain and therefore further detailed understanding of this risk and how it would be managed should be provided.
As drafted the policy makes no reference to flood risk and we would wish to see this
amended.
With regard to housing development we would wish to ensure that all development be located in Flood Zone 1 and that the policy criteria would reflect this.
Other issues include the crossing of watercourses and impacts on biodiversity and water quality. This should be referenced within the policy criteria with requirements for any watercourse crossings to be clear span in design. This will ensure that flood water conveyance is not impeded and protect the habitat associated with those watercourses.
In addition to flood risk we also have concerns with regard to where the sites wastewater would drain to. In line with our Position Statement on managing new housing development in Apuldram (Chichester) Wastewater Treatment Works Catchment allocations within the Local Plan should not drain to the Apuldram WwTW but be directed to alternative WwTW catchments, notably Tangmere WwTW via the new sewer pipeline connection once operational.
It is difficult to understand how this site would connect to an alternative WwTW and therefore would question whether the site would be deliverable.

Policy AL9 - Fishbourne
Fishbourne parish falls within the Apuldram WwTW catchment and we would recommend that the policy makes specific reference to the issues that the Neighbourhood Plan group should consider when identifying sites for their Local Plan.
We would also recommend that specific reference is made to the Source Protection Zone that covers part of the parish in order to ensure that the groundwater, and in turn the drinkingwater supply, is protected.

Policy AL11 - Hunston
There are parts of Hunston that fall within flood zones 2 and 3. We would recommend that if possible the policy makes reference to the fact that built development should be located solely in Flood Zone 1. If this is not possible some reference would need to be made to flood risk and the requirement for the Neighbourhood Plan group to fully consider this through their site allocation process. If sites were to be allocated in flood zone 2 or 3 it is likely that the Plan would need to be supported by a Level 2 SFRA or equivalent.

Policy AL13 - Southbourne Parish
Point 16 identifies the need to ensure that sufficient capacity is available at the relevant Wastewater Treatment Works prior to the delivery of development. This could be expanded to include sewer network capacity. Liaison with Southern Water regarding any necessary phasing of development would be encouraged.

Development Management Policies

Policy DM5 - Accommodation for GTTTS
We support the specific criteria in this policy to ensure that GTTS sites are not located in areas at risk of flooding.

Policy DM14 - Caravan and Camping Sites
We support the particular reference to restricting the occupancy of these sites in flood risk areas. However, there is no specific mention that flood risk areas should be avoided where possible. We would recommend that this should be included within the policy criteria.

Policy DM15 - Horticultural Development
We are pleased to see specific reference to the need to demonstrate adequate water
resources are available and/or water efficiency measures.

Policy DM16 - Sustainable Design and Construction
We support the requirement for new development to achieve a water usage of a maximum of 110litres per head per day.
For completeness we recommend that point 5 should be expanded to include compensation as well as make reference to net gain. This is in line with NPPF para 170.
We support the requirement in point 8 with regard to measures to adapt to climate change.

Policy DM18 - Flood Risk and Water Management
para. 7.115 - reference to the Environment Agency should be removed from this sentence.
The responsibility for surface water drainage and consideration of SuDS sits with West Sussex County Council as the Lead Local Flood Authority for this area.
para. 7.116 - vulnerability - it should be noted that not all development types would be appropriate in all flood zones. Basement dwellings would not be supported in flood zone 3. This paragraph should be amended to reflect this.
We would recommend that you review this policy alongside the strategic policy on flood risk to ensure that they are complementary. Whilst the intention of the policy is good some further clarity could be provided to ensure that all sources of flood risk are considered through decision making.
As drafted there is no reference to the Sequential Test which is a key step in decision
making with regard to proposals in a flood zone. It appears that a number of the criteria included in policy 42 of the current adopted Local Plan have been stripped out. We would recommend further consideration of this for the next iteration of the Plan.
We note that the policy also makes reference to wider water management and does refer tothe South East River Basin Management Plan, however, as per our comments on policy S31 we would wish to see a specific policy that provides for the protection and enhancement of water quality. It may be prudent to consider whether an overarching strategic policy to address flood risk and water management would be best with separate detailed development management policies for each topic.
We would be happy to work with you regarding this detail.

Policy DM20 - Development around the coast
We support this policy and the requirement to safeguard a strip of land behind existing or proposed sea defence or coastal works. Please note that the Environment Agency would seek a 16 metre buffer behind any of our tidal defences.
We support the specific requirement to ensure that development for boat or marine use would not be detrimental to water quality.

Policy DM24 - Air Quality
We are pleased to see that this policy recognises that new development may be located near to existing uses that may be potentially polluting to housing. It is important that the onus should be on the developer/applicant to manage any impact to ensure that they don't leave the existing user affected, e.g. by complaints.

Policy DM26 - Contaminated Land
We support this policy as drafted.

Policy DM29 - Biodiversity
We support this policy as drafted and are pleased to see that specific reference has been
provided to ensure that net gain in biodiversity is actively pursued. Consideration should be
given to the current Government consultation on mandating biodiversity net gain in all new
development and whether this may require further strengthening of the policy wording.
Policy DM32 - Green Infrastructure
We support policy.

See reps

See reps

Paragraph 1.5 of the Local Plan Review states "This Plan seeks to balance the economic, social and environmental dimensions of sustainable development". "Balance" implies some gains and some losses. However, this does not reflect the four bullet points that follow this sentence.
In addition, Paragraph 8 of the National Planning Policy Framework explains that;
"Achieving sustainable development means that the planning system has three overarching objectives, which are interdependent and need to be pursued in mutually supportive ways (so that opportunities can be taken to secure net gains across each of the different objectives)".

We therefore suggest that "balance" is not the most appropriate word.

The three overarching objectives include; "c) an environmental objective - to contribute to protecting and enhancing our natural, built and historic environment......". We therefore welcome the fourth bullet point of paragraph 1.5; "Protecting and enhancing the unique and special qualities of our environment".

Reword the first sentence of paragraph 1.5 as; "This Plan seeks to deliver the economic, social and environmental dimensions of sustainable development in mutually supportive ways".

Paragraph 1.16 explains that the National Planning Policy Framework reiterates the importance of significantly boosting the supply of new dwellings, whilst ensuring provision for other development needs including economic growth.
Whilst not untrue, we consider that this does not fully represent the Government's objectives and policies as set out in the Framework and therefore gives the misleading impression that the Framework is only about housing supply and economic development.
In fact, the protection and enhancement of the natural, built and historic environment is also identified as important in the Framework e.g. in the environmental overarching objective for the planning system as set out in paragraphs 8, 11b)i and 20 d).
Reword the final sentence of paragraph 1.16 as:
"The importance of significantly boosting the supply of new dwellings is reiterated, whilst ensuring provision for other development needs including economic growth and protecting and enhancing the natural, built and historic environment".
Paragraph 31 of the National Planning Policy Framework requires "The preparation and review of all policies should be underpinned by relevant and up-to-date evidence". We previously expressed our concerns about the historic evidence base for the policy framework for the district when commenting on the Issues and Options stage of the Local Plan Review;
"We are aware of the Council's series of Conservation Area Character Appraisals, The Future Growth of Chichester Study and the Landscape Capacity Studies. However, the Council's "Supporting documents" webpage has no historic environment documents and we are not clear if the Council has other historic environment evidence e.g. is there an extensive urban survey of Chichester or other townscape or characterisation study ? Is there an urban archaeological database ? Is there a list of locally important heritage assets ? Has the Council undertaken a survey of grade II buildings at risk ?".
However, looking at the Council's Local Plan Review Preferred Approach Plan - Evidence Base - December 2018 webpage, the only specific historic environment evidence base document identified is the Chichester Historic Environment Strategy and Action Plan. Whilst we welcome the Strategy, we have previously expressed the view that we do not consider that it forms, by itself, an adequate historic environment evidence base for the Local Plan Review.
We are aware that the Council has a list of locally important buildings, but that Chichester was not covered by the West Sussex Extensive Historic Town Surveys - perhaps as it was thought a candidate for the more intensive approach of an Urban Archaeological Database (UAD). However, we are not aware that such a UAD exists, and whilst we are aware of the Council's Historic Environment Record (the availability of which accords with paragraph 187 of the National Planning Policy Framework), we do wonder if the archaeological evidence and significance of the city is fully understood and readily available. We suggested that the Historic Environment Strategy could set out actions to enhance understanding and management of the archaeological resource of the historic city and we would be pleased to discuss how we might be able to assist with this.
We will expect the Council to have an adequate, up-to-date and relevant historic environment evidence base and to demonstrate in the Pre-Submission Local Plan how that historic evidence base has informed and influenced the Plan's policies and site allocations.
The historic environment evidence base for the Local Plan Review should be set out on the Council's Evidence Base webpage. If there are indeed gaps in that evidence base, then these should be filled and that evidence taken on board in preparing the Pre-Submission Local Plan Review document.
Historic England welcomes and supports the reference to the historic environment of Chichester district, and the heritage assets therein, in paragraphs 2.27 and 2.28 as part of the positive strategy for the conservation and enjoyment of the historic environment required by paragraph 185 of the National Planning Policy Framework.

Historic England welcomes and supports, in principle, the identification of "Protect the area's valuable heritage and historic assets" as one of the challenges faced by the Plan.
However, the National Planning Policy Framework requires local plans to deliver an environmental overarching objective which includes "to contribute to conserving and enhancing our natural, built and historic environment" (paragraph 8 c)) and to include strategic policies to make sufficient provision for "conservation and enhancement of the natural, built and historic environment" (our underlining).
The Framework therefore requires local planning authorities, through their local plans, to do more than just conserve the historic environment i.e. to enhance it as well. This should be identified as a challenge (although it is also an opportunity).
Reword the last bullet point of paragraph 2.28 as; "Protect and enhance the area's valuable heritage and historic assets".
Historic England welcomes, in principle, as part of the positive strategy for the conservation and enjoyment of the historic environment required by paragraph 185 of the National Planning Policy Framework, the reference to the historic environment in paragraph 3.1;

"It is the intention of the Council to enable the delivery of infrastructure, jobs, accessible local services and housing for future generations while supporting the historic and natural environment".

However, the National Planning Policy Framework refers to "conserving and enhancing our natural, built and historic environment" (paragraph 8 c)) and the "conservation and enhancement of the natural, built and historic environment". We therefore suggest that "supporting" should be "conserving and enhancing" as terminology more consistent with the Framework and possibly ambiguous than "supporting".

Reword the first sentence of paragraph 3.1 as;
"It is the intention of the Council to enable the delivery of infrastructure, jobs, accessible local services and housing for future generations while conserving and enhancing the historic, built and natural environment".
Historic England welcomes the inclusion of "Have a quality of life that is enriched through opportunities to enjoy our local culture, arts and a conserved and enhanced heritage;" in the Vision as part of the positive strategy for the conservation and enjoyment of the historic environment required by paragraph 185 of the National Planning Policy Framework.
Historic England welcomes "As an historic walled cathedral city, its rich cultural and architectural heritage will be conserved, enhanced and promoted together with the views and landscape value afforded by its setting" in paragraph 3.4 as part of the positive strategy for the conservation and enjoyment of the historic environment required by paragraph 185 of the National Planning Policy Framework.
Historic England welcomes and supports "The conservation and enhancement of the historic environment, the high quality landscapes and the agricultural and other rural activities that support it will remain paramount" in paragraph 3.14 as part of the positive strategy for the conservation and enjoyment of the historic environment required by paragraph 185 of the National Planning Policy Framework.
Historic England welcomes and supports, in principle, the Strategic Objective "Conserve and enhance landscape and heritage" as part of the positive strategy for the conservation and enjoyment of the historic environment required by paragraph 185 of the National Planning Policy Framework. However, we suggest that it could be rather more ambitious e.g. "Conserve, enhance, increase appreciation and enjoyment of and access to heritage"
Paragraph 4.2 states that; "New development must achieve sustainable development principles and must not adversely affect the character, quality, amenity or safety of the built environment, wherever it occurs". The implication is that this is a requirement of the National Planning Policy Framework, but we cannot find this exact wording in the Framework.

However, paragraph 127 of the Framework does set out what planning policies and decisions should ensure of developments, including "are sympathetic to local character and history" and "establish or maintain a strong sense of place". In addition, paragraph 185 of the Framework requires plans to set out a positive strategy for the conservation and enjoyment of the historic environment, which should take into account "the desirability of new development making a positive contribution to local character and distinctiveness".

We therefore consider that the final sentence of paragraph 4.2 should be revised to more closely reflect the requirements of the National Planning Policy Framework.

Reword the final sentence of paragraph 4.2 as ""New development must achieve sustainable development principles, must not adversely affect the history, quality, amenity or safety of the natural, built and historic environment and should make a positive contribution to local character and distinctiveness and establish or maintain a sense of place". (Alternatively, these could be set out as bullet points for clarity).
Historic England welcomes and supports "enhance the quality of the built, natural, historic, social and cultural environments" in Policy S2 as part of the positive strategy for the conservation and enjoyment of the historic environment required by paragraph 185 of the National Planning Policy Framework.
Although the historic environment is not identified as a constraint or as an opportunity for enhancement in paragraph 4.12 as a factor in the definition of the Settlement Hierarchy, we note that paragraph 4.14 does explain that consideration has been given to other factors in determining whether a settlement is a suitable location for additional housing growth. We would like to think that these other factors include the potential effects on the historic environment.
Historic England welcomes and supports "where possible enhances the character, significance and setting of heritage assets" as one of the considerations to guide potential discussions on a possible site for a new settlement in paragraph 4.33 as part of the positive strategy for the conservation and enjoyment of the historic environment required by paragraph 185 of the National Planning Policy Framework.
Historic England welcomes and supports "it is acknowledged that new development needs to be planned sensitively with special regard to the unique character of the city's historic environment and setting, and should be underpinned by historic characterisation assessments" in paragraph 4.90 as part of the positive strategy for the conservation and enjoyment of the historic environment required by paragraph 185 of the National Planning Policy Framework.
Nevertheless, we suggest that reference should also be made to heritage impact assessments to underpin the planning of new development.
Reword paragraph 4.90 to read;
"it is acknowledged that new development needs to be planned sensitively with special regard to the unique character of the city's historic environment and setting, and should be underpinned by historic characterisation assessment and heritage impact assessments".
Historic England welcomes and supports "such development will need to be sensitive to the
historic character of the city" in paragraph 4.91 as part of the positive strategy for the conservation and enjoyment of the historic environment required by paragraph 185 of the National Planning Policy Framework.
Historic England welcomes and supports "conserve and enhance the city's historic character and heritage", "Enhance the city's existing heritage, arts and cultural facilities", "Protect views of the cathedral" and "All development will be required to have special regard to the city's historic character and heritage. Development proposals should be underpinned by historic characterisation assessments and make a positive contribution to the city's unique character and distinctiveness" in Policy S13 as part of the positive strategy for the conservation and enjoyment of the historic environment required by paragraph 185 of the National Planning Policy Framework.
Nevertheless, we would like to see a reference to heritage impact assessments to underpin development proposals.
We also wonder if it would be helpful to have a specific policy to protect important views, allied to or combined with a policy for tall buildings in the historic city ?
Reword Policy SP13 to read "Development proposals should be underpinned by historic characterisation assessment and a heritage impact assessment......".
Historic England welcomes and supports "Any development proposals within the vicinity of the site must clearly demonstrate how the development would protect, and where possible enhance, the operation and heritage of the site as a motor-circuit and airfield" in Policy S15 as part of the positive strategy for the conservation and enjoyment of the historic environment required by paragraph 185 of the National Planning Policy Framework.
Historic England welcomes and supports "All proposals must ensure that the cultural and historical significance of the military facilities (and any other significant archaeological assets) located on the site, are understood and inform the scope of future development of that site" in Policy S17 as part of the positive strategy for the conservation and enjoyment of the historic environment required by paragraph 185 of the National Planning Policy Framework.
However, we would prefer "significant archaeological assets" to be retained in situ.
Reword Policy S17 as;
"All proposals must ensure that the cultural and historical significance of the military facilities (and any other significant archaeological assets) located on the site, are understood and inform the scope of future development of that site, with any significant archaeological assets retained in situ".
Paragraph 2.2 of the Plan notes that the North of the Plan Area has "rich cultural and heritage assets". We are surprised, therefore, that paragraph 4.128 has no mention of these assets.
Reword paragraph 4.128 "This part of the plan area is predominantly rural with few sizeable settlements, characterised by undulating countryside with a high proportion of woodland, typical of the Low Weald landscape. Conserving the rural character of the area, with its high quality landscape and natural and historic environment, is a key objective".
Historic England welcomes and supports "Conserve and enhance the rural character of the area, the quality of its landscape and the natural and historic environment;" in Policy S19 as part of the positive strategy for the conservation and enjoyment of the historic environment required by paragraph 185 of the National Planning Policy Framework.
Historic England welcomes paragraph 5.1 as part of the positive strategy for the conservation and enjoyment of the historic environment required by paragraph 185 of the National Planning Policy Framework.
Strictly-speaking, historic parks and gardens are registered for their special historic interest rather than their protection per se, but one of the purposes of Registration is to encourage appropriate protection and inclusion on the Register is a material consideration in the determination of planning applications.
Historic England welcomes paragraph 5.5 as part of the positive strategy for the conservation and enjoyment of the historic environment required by paragraph 185 of the National Planning Policy Framework.
Historic England welcomes and supports Policy S20, particularly the references to history, historic character and local identity in clause 1, sense of place in clause 2, character in clause 8 and high quality public realm in clause 11 as part of the positive strategy for the conservation and enjoyment of the historic environment required by paragraph 185 of the National Planning Policy Framework.
However, we would also like to see a specific clause relating to heritage assets.
Add a new clause; "conserves or enhances the significance, special interest, character and appearance of heritage assets".
Historic England welcomes and supports paragraph 5.12 as part of the positive strategy for the conservation and enjoyment of the historic environment required by paragraph 185 of the National Planning Policy Framework.
Historic England welcomes, in principle, paragraph 5.13 states that "Where development proposals might affect a heritage asset the Council will identify and assess the particular significance of the heritage asset and seek to avoid or minimise any conflict between the conservation of the heritage asset and any aspect of the proposal" as part of the positive strategy for the conservation and enjoyment of the historic environment required by paragraph 185 of the National Planning Policy Framework.
This very largely reflects paragraph 190 of the National Planning Policy Framework, but the Framework requires local planning authorities to take the particular significance of any heritage asset that might be affected by a proposal into account when considering the impact of a proposal on a heritage asset, "to avoid or minimise any conflict between the heritage asset's conservation and any aspect of the proposal". The requirement is clear - any conflict should be avoided or minimised; it is not sufficient to merely "seek to" avoid or minimise that conflict.

In addition, paragraph 189 of the Framework states;

"In determining applications, local planning authorities should require an applicant to describe the significance of any heritage assets affected, including any contribution made by their setting......Where a site on which development is proposed includes, or has the potential to include, heritage assets with archaeological interest, local planning authorities should require developers to submit an appropriate desk-based assessment and, where necessary, a field evaluation.

There is, therefore, a clear onus to be placed upon the applicant/developer to identify and describe the significance of any heritage assets affected.

Paragraphs 193, 194, 195 and 196 of the Framework set out how local planning authorities should consider the impact of a proposed development on the significance of a designated heritage asset. We believe that this could usefully be summarised in the Plan.

Reword paragraph 5.13;
"Where development proposals might affect a heritage asset the Council will identify and assess the particular significance of the heritage asset and take that significance into account when considering the impact of a proposal on a heritage asset, to avoid or minimise any conflict between the heritage asset's conservation and any aspect of the proposal".
Add new paragraphs;
"For applications which affect, or have the potential to affect, heritage assets the applicant will be expected to describe the significance of the asset and its setting, using appropriate expertise; at a level of detail proportionate to its significance and sufficient to understand the potential impact of the proposal; using appropriate references such as the Historic Environment Record and, if necessary, original survey (including, for assets of archaeological interest, an appropriate desk-based assessment and, where necessary, a field evaluation)";
"When considering the impact of a proposed development on the significance of a designated heritage asset, the Council will give great weight to the asset's conservation. Any harm to, or loss of, the significance of a designated heritage asset (from its alteration or destruction, or from development within its setting), will require clear and convincing justification"; and

"The Council will refuse proposals that would lead to substantial harm to (or total loss of significance of) a designated heritage asset unless it can be demonstrated that the substantial harm or total loss is necessary to achieve substantial public benefits that outweigh that harm or loss, or all of the circumstances in paragraph 195 of the National Planning Policy Framework apply. For proposals that would lead to less than substantial harm to the significance of a designated heritage asset, the Council will weigh this harm against the public benefits of the proposal".

Historic England welcomes and supports Policy S22, which we consider complies with the requirements of paragraphs 17 and 20 of the National Planning Policy Framework to contain strategic policies and for those strategic policies to make sufficient provision for the conservation and enhancement of the historic environment.

We also consider that the policy forms part of the positive strategy for the conservation and enjoyment of the historic environment required by paragraph 185 of the National Planning Policy Framework. We consider that the word "positive" is significant, and we believe that the Plan (and Council) should be proactive in the conservation and enhancement of the historic environment. National Planning Practice Guidance states "Such a [positive] strategy should recognise that conservation is not a passive exercise".
We therefore consider that the positive strategy for the conservation and enjoyment of the historic environment is not a passive exercise but requires a plan for the maintenance and use of heritage assets and for the delivery of development including within their setting that will afford appropriate protection for the asset(s) and make a positive contribution to local character and distinctiveness. We therefore look to local plans to contain commitments to positive measures for the historic environment. We therefore welcome the commitments within Policy S22 to positive actions, including heritage at risk, which paragraph 185 requires to be part of that positive strategy for the conservation and enjoyment of the historic environment. However, we do feel that the supporting text could helpfully explain a little more about the Council's approach to heritage at risk, perhaps borrowing some text from the Chichester Historic Environment Strategy and Action Plan.
We also consider that the positive strategy should comprise recognition throughout the Plan of the importance of the historic environment, of the historic environment's role in delivering the Plan's vision and the wider economic, social and environmental objectives for the Plan area, and of the potential impacts of the Plan's policies and proposals on the historic environment.
We are pleased to have identified a number of references throughout the Plan to the historic environment and we therefore consider that the Plan sets out an adequate positive strategy for the conservation and enjoyment of that historic environment as required by paragraph 185 of the National Planning Policy Framework and that the Plan is therefore compliant with that paragraph.

Add a new paragraph explaining what "heritage at risk" is and the Council's approach to assets at risk e.g.

"Unfortunately, heritage assets can be at risk from neglect, decay or other threats. Designated assets at risk, with the exception of Grade II secular buildings and Grade II places of worship used less than six times a year, are identified on the Historic England Heritage at Risk Register. Within the district outside the South Downs National Park, six assets are on the Register (February 2018): three scheduled monuments, two listed buildings and one conservation area. The Council will actively seek to address threats to heritage assets by recording and monitoring Heritage at Risk in Chichester District, publishing it on our website and working with the owners of heritage assets at risk to find solutions and secure repairs to bring them back into active use, including where appropriate viable new uses and/or proposals for enabling development so they are preserved for future generations."

Historic England suggests that paragraph 5.37 could also refer to the range of heritage assets to be found in the countryside of the Plan area.
Reword paragraph 5.37 as;

"It is valued for many reasons, including agriculture and community food production, its landscape qualities including the special characteristics of Chichester Harbour and Pagham Harbour, the setting it provides for Chichester City and other towns and villages, its range of heritage assets, including historic landscapes, and the opportunities it provides for recreation and biodiversity".
Historic England welcomes and supports clause d of Policy S32; "integrate with the surrounding built, historic and natural environments" as part of the positive strategy for the conservation and enjoyment of the historic environment required by paragraph 185 of the National Planning Policy Framework.
As noted in paragraph 6.12, the Chichester Entrenchments Scheduled Monument lies partly within and partly immediately to the north of the site. Paragraph 194 of the National Planning Policy Framework identifies Scheduled Monuments as being assets "of the highest significance", substantial harm to or loss of which should be wholly exceptional.

We have previously commented (as English Heritage) on the allocation of this site during the consultation on the Key Policies. We explained that development close to the earthworks might harm the historical value of the heritage asset by interrupting views between its parts and introducing incongruous land-use in its immediate surroundings. This in turn would make it difficult to appreciate the asset's open rural setting, its extensive linear nature and its purpose of enclosing large areas of open land.

Accordingly, we initially objected to the form of the allocation in the Key Policies, but subsequently withdrew that objection following amendments to the boundary of the Strategic Development Location on its northern side so that the boundary ran along the south edge of the belt of woodland in which the scheduled monument sits, thereby entirely excluding the monument from the SDL, and the allocation of the northern area of the amended site as open space.
We are therefore pleased to see that the Strategic Site Allocation still excludes the scheduled monument. We also welcome and support the following requirements of Policy AL1, which we consider provide, in principle, adequate protection for the Scheduled Monument in accordance with the National Planning Policy Framework:
6. Landscaped to protect priority views of Chichester Cathedral spire;
7. Keep land north of the B2178 in open use, free from built development, to protect the natural history interest of both Brandy Hole Copse, and the setting of the Chichester Entrenchments Scheduled Monument;
8. Conserve, enhance and better reveal the significance of the Chichester Entrenchments Scheduled Monument and other non-designated heritage assets and their settings and to record and advance understanding of the significance of any heritage assets to be harmed or lost;
However, this comment is without prejudice to any comments we may wish to make on any planning application that may be submitted for the development of this site.
Historic England makes no comment on the principle of the Shopwyke Strategic Site Allocation, which we note is an existing allocation.
However, the Grade II listed barn at Greenway Farm is located to the south-west of the site and the Grade II listed Shopwyke Grange and the Grade II* listed Shopwyke Hall are located to the south-east. Paragraph 194 of the National Planning Policy Framework states "Any harm to, or loss of, the significance of a designated heritage asset (from its alteration or destruction, or from development within its setting), should require clear and convincing justification". The paragraph identifies Grade II* buildings as assets of the "highest significance".

Historic England therefore welcomes and supports, in principle, the following requirement of Policy AL2, which we consider provide, in principle, adequate protection for the listed barn and Shopwyke Hall in accordance with the National Planning Policy Framework:
7. Protect existing views of Chichester Cathedral spire and conserve and enhance the historic significance of the listed barn at Greenway Farm and the cluster of buildings associated with the grade II* listed Shopwhyke Hall, which should be analysed at an early stage of the masterplan.
However, we consider that reference should also be made to the Grade II listed Shopwyke Grange. This comment is without prejudice to any comments we may wish to make on any planning application that may be submitted for the development of this site.
Reword criterion 7;"Protect existing views of Chichester Cathedral spire and conserve and enhance the historic significance of the listed barn at Greenway Farm, the listed Shopwyke Grange and the cluster of buildings associated with the grade II* listed Shopwhyke Hall which should be analysed at an early stage of the masterplan".
According to our records there are no designated heritage assets on this site, although the Grade II listed Shopwyke Grange and Grade II* listed Shopwyke Hall lie to the north-east of the allocated area, Paragraph 194 of the National Planning Policy Framework states "Any harm to, or loss of, the significance of a designated heritage asset (from its alteration or destruction, or from development within its setting), should require clear and convincing justification". The paragraph identifies Grade II* buildings as assets of the "highest significance".

We note that criterion 7 of Policy AL2 requires the development of the Shopwyke Strategic Site Allocation to ".......conserve and enhance the historic significance of the......cluster of buildings associated with the grade II* listed Shopwhyke Hall, which should be analysed at an early stage of the masterplan. We have suggested in our comments on this policy that it include reference to the listed Shopwyke Grange, and we consider that this requirement should also be included in Policy AL3 to provide, in principle, adequate protection for the listed barn and Shopwyke Hall in accordance with the National Planning Policy Framework.

Historic England welcomes and supports criterion 8 of Policy AL2; "Existing views of Chichester Cathedral spire are to be protected". However, this comment is without prejudice to any comments we may wish to make on any planning application that may be submitted for the development of this site.
Reword criterion 8 as;
"Protect existing views of Chichester Cathedral spire and conserve and enhance the historic significance of the listed Shopwyke Grange and the cluster of buildings associated with the grade II* listed Shopwhyke Hall which should be analysed at an early stage of the masterplan".
Historic England makes no comment on the principle of the two sites at Land at Westhampnett/North East Chichester Strategic Site Allocation, which we note were part of a broad strategic development location in the adopted Local Plan.
However, the site abuts the Graylingwell Hospital Conservation Area, the buildings of the former 'pauper lunatic asylum' (including the Grade II listed chapel), the Grade II listed Summersdale Farmhouse and a Grade II registered park and garden. Paragraph 194 of the National Planning Policy Framework states "Any harm to, or loss of, the significance of a designated heritage asset (from its alteration or destruction, or from development within its setting), should require clear and convincing justification".
Historic England therefore welcomes and supports, in principle, the following requirement of Policy AL4, which we consider provide, in principle, adequate protection for these designated assets in accordance with the National Planning Policy Framework:
9. Development should be designed with special regard to the Graylingwell Hospital
Conservation Area, the buildings of the former 'pauper lunatic asylum' and the Grade II registered park and garden in which they sit, and to other listed buildings in the vicinity of the site and their settings. Important views of Chichester Cathedral spire from the area should be protected;
This comment is without prejudice to any comments we may wish to make on any planning application that may be submitted for the development of this site.
Historic England makes no comment on the principle of the Southern Gateway Strategic Site Allocation.
However, the site includes a row of Grade II listed buildings on Southgate and a number of non-designated heritage assets (the southern gateway of the city had Roman roads converging upon it and this is likely to result in enhanced archaeological potential in this part of the city. The development of suburbs in the medieval and later periods is a further factor with both the canal and railway as examples of later uses of the area. There are a number of buildings of interest, including the former Law Courts and Bus Garage). Part of the site lies within the Chichester Conservation Area and there are listed buildings adjacent to the site.
Paragraph 184 of the National Planning Policy Framework states heritage assets "are an irreplaceable resource, and should be conserved in a manner appropriate to their significance, so that they can be enjoyed for their contribution to the quality of life of existing and future generations". Paragraph 194 of the Framework states "Any harm to, or loss of, the significance of a designated heritage asset (from its alteration or destruction, or from development within its setting), should require clear and convincing justification".

Historic England therefore welcomes and supports, in principle, the following requirements of Policy AL5;

3. Respect for the historic context and make a positive contribution towards protecting and enhancing the local character and special heritage of the area and important historic views, especially those from the Canal Basin towards Chichester Cathedral;
9. Include an archaeological assessment to define the extent and significance of any
archaeological remains and reflect these in the proposals, as appropriate;
However, we consider that these requirements should be strengthened to ensure that they provide adequate protection for these assets in accordance with the National Planning Policy Framework. In addition, we consider that Policy AL5 should promote more strongly the opportunity to use the heritage of the area to help define its character and the desirability of new development making a positive contribution to local character and distinctiveness as part of the positive strategy for the conservation and enjoyment of the historic environment required by paragraph 185 of the National Planning Policy Framework.
These comments are without prejudice to any comments we may wish to make on any planning application that may be submitted for the development of this site.
Reword clause 2 as follows;
Proposals should include a high quality distinctive design response appropriate to this gateway location and based on the character and heritage of the area, which establishes a clear hierarchy of streets and spaces, active frontages of buildings which front streets and spaces with clearly defined building lines;
Reword clause 3 as follows;
3. Respect for the historic context and make a positive contribution towards protecting and enhancing the local character and special heritage of the area, including the Conservation Area, listed buildings (both on and adjacent to the site), non-designated buildings of historic interest and important historic views, especially those from the Canal Basin towards Chichester Cathedral;
Reword clause 9 as follows;
9. Include an archaeological assessment to define the extent and significance of any
archaeological remains and reflect these in the proposals;
According to our records, the site Land South-West of Chichester (Apuldram and Donnington Parishes) contains no designated heritage assets. We therefore have no comment on the principle of the allocation, although we would expect its potential for non-designated archaeology to have been assessed, with reference to the Council's Historic Environment Record, in accordance with paragraph 187 of the National Planning Policy Framework which states;
Local planning authorities should maintain or have access to a historic environment record. This should contain up-to-date evidence about the historic environment in their area and be used to:
a) assess the significance of heritage assets and the contribution they make to their environment; and
b) predict the likelihood that currently unidentified heritage assets, particularly sites of historic and archaeological interest, will be discovered in the future.
Historic England welcomes and supports clause 3:
3. Protect existing views of Chichester Cathedral spire and the setting of the Chichester Harbour Area of Outstanding Natural Beauty which should be analysed at an early stage of the masterplan;
This comment is without prejudice to any comments we may wish to make on any planning application that may be submitted for the development of this site.
According to our records, the site at Highgrove Farm, Bosham, contains no designated heritage assets. We therefore have no comment on the principle of the allocation, although we would expect its potential for non-designated archaeology to have been assessed, with reference to the Council's Historic Environment Record, in accordance with paragraph 187 of the National Planning Policy Framework which states;
Local planning authorities should maintain or have access to a historic environment record. This should contain up-to-date evidence about the historic environment in their area and be used to:
a) assess the significance of heritage assets and the contribution they make to their environment; and
b) predict the likelihood that currently unidentified heritage assets, particularly sites of historic and archaeological interest, will be discovered in the future.
This comment is without prejudice to any comments we may wish to make on any planning application that may be submitted for the development of this site.

Historic England has no comments on the principle of land being allocated in the revised Fishbourne Neighbourhood Plan for a minimum of 250 dwellings.
However, we note that one of the specific issues that need to be taken into account in planning for development at Fishbourne identified in paragraph 6.65 of the Plan is "Protecting the heritage assets of Fishbourne and their setting".
We welcome the recognition and identification of this issue, but we consider that it should be included as a specific requirement in Policy AL9, to ensure that the allocation of the site or sites in the Neighbourhood Plan conforms with the National Planning Policy Framework, particularly paragraphs 184 and 194.
Add the following clause to Policy AL9;
"Demonstration that the development would not have an adverse impact on the significance of heritage assets, including listed buildings and the Fishbourne Roman site Scheduled Monument, or the character or appearance of the Fishbourne Conservation Area".
Historic England has no comments on the principle of land being allocated in the revised Chidham and Hambrook Neighbourhood Plan for a minimum of 500 dwellings.
However, we consider that Policy AL10 should include a specific requirement to ensure that the allocation of the site or sites in the Neighbourhood Plan conforms with the National Planning Policy Framework, particularly paragraphs 184 and 194.
Add the following clause to Policy AL10;
"Demonstration that the development would not have an adverse impact on the significance of heritage assets.
Historic England has no comments on the principle of land being allocated in the revised Hunston Neighbourhood Plan for a minimum of 250 dwellings.
However, we note that one of the specific issues that need to be taken into account in planning for development at Hunston identified in paragraph 6.77 of the Plan is "Respecting the setting of listed buildings and the Hunston conservation area".
We welcome the recognition and identification of this issue, but we consider that it should be included as a specific requirement in Policy AL11, to ensure that the allocation of the site or sites in the Neighbourhood Plan conforms with the National Planning Policy Framework, particularly paragraphs 184 and 194.
Add the following clause to Policy AL11;
"Demonstration that the development would not have an adverse impact on the significance of heritage assets, including listed buildings, or on the character or appearance of the Hunston Conservation Area."
According to our records, the site Land north of Park Farm, Selsey, contains no designated heritage assets. We therefore have no comment on the principle of the allocation, although we would expect its potential for non-designated archaeology to have been assessed, with reference to the Council's Historic Environment Record, in accordance with paragraph 187 of the National Planning Policy Framework which states;
Local planning authorities should maintain or have access to a historic environment record. This should contain up-to-date evidence about the historic environment in their area and be used to:
a) assess the significance of heritage assets and the contribution they make to their environment; and
b) predict the likelihood that currently unidentified heritage assets, particularly sites of historic and archaeological interest, will be discovered in the future.

This comment is without prejudice to any comments we may wish to make on any planning application that may be submitted for the development of this site.
Historic England has no comments on the principle of land being allocated in the revised Southbourne Neighbourhood Plan for a minimum of 1,250 dwellings.
However, we consider that a specific requirement should be included in Policy AL13 to ensure that the allocation of the site or sites in the Neighbourhood Plan conforms with the National Planning Policy Framework, particularly paragraphs 184 and 194.
Add the following clause to Policy AL13;
"Demonstration that the development would not have an adverse impact on the significance of heritage assets, including listed buildings, or on the character or appearance of the Prinsted Conservation Area."
Historic England has no comments on the principle of the allocation Land West of Tangmere.

However, the site is close to the Tangmere Conservation Area and a number of listed buildings, including the Grade I listed Church of St Andrew. Paragraph 194 of the National Planning Policy Framework states "Any harm to, or loss of, the significance of a designated heritage asset (from its alteration or destruction, or from development within its setting), should require clear and convincing justification". The paragraph identifies Grade I buildings as assets of the "highest significance".

Historic England therefore welcomes, in principle, clauses 5 and 8 of Policy AL14

5. Protect existing views of Chichester Cathedral spire and reduce any impact on views from within the National Park;
8. Conserve and enhance the heritage and potential archaeological interest of the village, surrounding areas and World War II airfield, including the expansion or relocation of the Tangmere Military Aviation Museum.
However, we consider that clause 8 should be strengthened to ensure that it provides adequate protection for these assets in accordance with the National Planning Policy Framework. In addition, we note that paragraph 6.95 of the Plan identifies, as one of the specific issues need to be taken into account in planning the development and site layout at Tangmere, "Conserving and enhancing the setting of the historic village (particularly the Conservation Area"). We consider that this should be included within Policy AL14.
This comment is without prejudice to any comments we may wish to make on any planning application that may be submitted for the development of this site.
Reword criterion 8 as follows:

8. Conserve and enhance the heritage and potential archaeological interest of the village, surrounding areas and World War II airfield, particularly the Conservation Area and the Grade I listed Church of St Andrew and including the expansion or relocation of the Tangmere Military Aviation Museum.
Add a new criterion as follows:
""Conserve and enhancie the setting of the historic village, particularly of the Conservation Area".
Historic England welcomes and supports clause b of Policy DM3 as part of the positive strategy for the conservation and enjoyment of the historic environment required by paragraph 185 of the National Planning Policy Framework.
Historic England welcomes and supports clauses 1 c and 2 e of Policy DM5 as part of the positive strategy for the conservation and enjoyment of the historic environment required by paragraph 185 of the National Planning Policy Framework.
Historic England welcomes, in principle, clause 2 of Policy DM13 but considers that the policy should be, in the first instance, to avoid adverse impact on the historic environment as part of the positive strategy for the conservation and enjoyment of the historic environment required by paragraph 185 of the National Planning Policy Framework. We consider that the wording used in Policies DM3 and DM5 would be appropriate.
Reword clause 2 of Policy DM13 as:
"Is located so as not compromise the essential features of nationally designated areas of landscape, historic environment or nature conservation protection".
Historic England welcomes and supports clause 1 of Policy DM17 as part of the positive strategy for the conservation and enjoyment of the historic environment required by paragraph 185 of the National Planning Policy Framework.
Historic England welcomes and supports clause b of Policy DM20 as part of the positive strategy for the conservation and enjoyment of the historic environment required by paragraph 185 of the National Planning Policy Framework.
Historic England welcomes and supports paragraph 7.129 as part of the positive strategy for the conservation and enjoyment of the historic environment required by paragraph 185 of the National Planning Policy Framework.
Many farm buildings that are now redundant for modern farming needs are likely to be of historic interest - it is acknowledged that farm buildings are generally under-represented on the National Heritage List for England. Historic England considers that Policy DM21 should include stronger protection for such buildings as part of the positive strategy for the conservation and enjoyment of the historic environment required by paragraph 185 of the National Planning Policy Framework.
Add a new criterion to Policy DM21 as follows:

"Features of architectural or historic significance are retained and, where the building forms part of a historically significant complex of buildings, consideration is given to the future use(s) of those buildings and the impact of the proposal on the integrity and character of the complex".
Historic England welcomes and supports, in principle, paragraphs 7.154 - 7.161.
However, we consider that paragraph 7.154 should be reworded to clarify the distinction between designated and non-designated heritage assets (the latter including buildings on the Local Buildings List for Chichester).
Reword paragraph 7.154 as follows:
"There are a large number of "Heritage Assets" (as defined in the National Planning Policy Framework), both designated and non-designated, in the plan area. Designated assets are Listed Buildings, Scheduled Monuments, Conservation Areas and Registered Historic Parks and Gardens. Non-designated assets include archaeological sites (although the remains may be of national significance equivalent to scheduled monuments, and which should be considered subject to the policies for scheduled monuments) and non-listed buildings which have been identified as locally important, such as those on the Local Buildings List for Chichester City and 'positive' buildings within Conservation Areas."
Historic England welcomes and supports in principle, Policy DM27 both as part of the positive strategy for the conservation and enjoyment of the historic environment as required by paragraph 185 of the National Planning Policy Framework and also as a non-strategic policy for the conservation and enhancement of the historic environment as suggested by paragraph 28 of the Framework.
However, we consider that clause e. should specify the (wholly) exceptional circumstances in which permission for a proposed development that would lead to substantial harm to (or total loss of significance of) a designated heritage asset would be granted i.e. where it can be demonstrated that the substantial harm or total loss is necessary to achieve substantial public benefits that outweigh that harm or loss, or all of the circumstances in paragraph 195 of the National Planning Policy Framework apply.

We would also welcome the policy being more detailed in terms of the considerations to be taken into account when assessing development proposals affecting the different types of heritage asset, as do, for example, Policies EH10, EH11, EH14 and EH15 of the West Oxfordshire Local Plan 2031. These policies were developed with Historic England and the Inspector that examined the Local Plan 2031 shared our concern that the historic environment policy in the Local Plan 2031 provided inadequate locally specific detailed policy guidance and considered the more detailed policies necessary for the Plan to be sound.

(However, we do acknowledge that the Inspector that examined the Key Policies development plan document considered the modified historic environment policy (Policy 47) put forward by the Council with our support was sufficient for the Plan to be sound, and that Policy DM27 in the Local Plan Review very largely repeats Policy 47).

Reword clause e. of Policy DM27 as follows;
"Development involving substantial harm to or loss of designated heritage assets will
only be granted in exceptional circumstances (wholly exceptional circumstances for
designated assets of the highest significance) i.e. where it can be demonstrated that the substantial harm or total loss is necessary to achieve substantial public benefits that outweigh that harm or loss, or all of the circumstances in paragraph 195 of the National Planning Policy Framework apply.

More details of the considerations to be taken into account when assessing development proposals affecting the different types of heritage asset. We would be pleased to work with the Council on a revised policy or policies.

Paragraph 7.195 of the Plan notes that the remnants of canals "are important early 19th Century historic features in the landscape of the coastal plain and warrant protection".
Historic England agrees with this statement, but Policy DM33 makes no mention of protecting the historic significance of the remaining canal sections.
Reword the first paragraph of Policy DM33 as follows;
"Development that makes provision of through navigation or enhancement of the Chichester Ship Canal and the Wey and Arun Canal will be supported where it meets environmental, ecological, historical and transport considerations."
Historic England welcomes and supports clause 3 of Policy DM34 as part of the positive strategy for the conservation and enjoyment of the historic environment required by paragraph 185 of the National Planning Policy Framework.

It is very hard to reconcile how the building of over 1,000 new homes in Southbourne on farmland is consistent with the council's aim to protect the countryside, or the stated aim to: "protect the countryside in the plan area from the urbanising impacts of development which can arise from the impact of buildings, structures, lighting, traffic and other activities"

The scale of the proposal for Southbourne is wholly inappropriate. Whilst it might be possible to mitigate the effects with a more modest development - it will be impossible to do so with the nature of the proposals outlined.

Spatial Vision
Portsmouth Water note that there are significant additional housing allocations to the west of Chichester and on the coastal strip. These sites will need to be assessed for water supply and funding included in the Infrastructure Charging scheme. (See Map 4.1 Key Diagram)

It is not clear what water storage capacity is being referred to in Section 3.19. Portsmouth Water will review the provision of Service Reservoirs, for day to day use, and has re-started development of a large raw water storage reservoir at Havant Thicket. The reservoir, when combined with Portsmouth Water's existing sources and enhancements to its groundwater sources, would create sufficient
surplus to support an additional flexible daily transfer of treated water from Portsmouth Water are to Southern Water without detriment to Portsmouth Water's resilience.

Southern Water requires this transfer to help meet a significant deficit in its Southampton East, Southampton West and Isle of Wight resource zones. This deficit arose after Southern Water agreed to reduce its abstraction licences on the Rivers Test and River Itchen at a public inquiry in March 2018, to help protect the environment.

It is not clear that the water demands of the Horticultural Development Areas have been assessed. It is possible that these businesses will rely on rainwater harvesting and storage but changes in licencing regulations mean that 'Trickle Irrigation' is no longer exempt from abstraction licencing.

Groundwater abstraction in the coastal plain will require an impact assessment under the Habitats Regulations. (Section 4.75)

Spatial Strategy

Policy S12 sets out how development can make effective use of existing infrastructure. Portsmouth Water agree that the siting and timing of development can assist with the economic provision of water resource infrastructure. It also states that safeguarding existing infrastructure, such as water mains and aquifers, is important. Portsmouth Water would urge developers to check for existing infrastructure and for source protection zones that may limit development options.
Water infrastructure is not funded through CIL but a separate 'Infrastructure Charge' payable for each individual house. This is designed to pay for all off-site water infrastructure such as mains reinforcements, service reservoirs and supply. Development to an agreed program will help this system work effectively.

Strategic Policies

Policy S27 'Flood Risk Management' refers to Sustainable Drainage Systems (SuDS) and the need to control surface water run-off. It should also refer to aquifer protection and the need for caution when using infiltration systems especially deep bore systems. This applies particularly when the site is in, or close to, a source protection zone.

Policy S31 'Wastewater Management and Water Quality' refers to higher standards in the Building Regulations for water consumption to reduce pollution in the harbours. Portsmouth Waters 'Water Resources Management Plan' is based on lower per capita consumption and we have an aspiration for all customer to reach 100 litres/head/day by 2050. This is no substitute for reducing overall flows
to sewage treatment works by the control of groundwater infiltration and surface water drainage.

Strategic Site Allocations

Policy AL1 'West of Chichester' does not mention water supply so we assume that the site has reverted to a conventional system with sewerage pumped to Tangmere WWTW and water supplied by us. Portsmouth Water has provided provisional designs for this system and there are no existing large diameter water mains on the site. Costs for reinforcement of the water mains will be recovered by the new Infrastructure Charge and on site mains are likely to be provided by a third
party. Information on how reinforcement of the water mains is recovered by the Infrastructure Charge can be found in Portsmouth Water's Developer Charging Arrangements on our website under https://www.portsmouthwater.co.uk/developers/.

Policy AL2 'Shopwyke' is already under construction and has a conventional water supply system with all elements provided by us. Costs are being recovered via the Infrastructure Charge and on-site charges.

Policy AL3 'East of Chichester' is a new strategic site and there are no large diameter mains crossing it. This is an old landfill and may contain material that can damage plastic pipes. On site mains may need to be protected or be more expensive to ensure water quality is maintained.

Policy AL4 'Westhampnett' Phase 1 is already under construction and account has been taken of the large diameter main that crosses the site. Phase 2 is an extension of the existing Greylingwell site but it is not clear if this has been allowed for in the design of this 'Inset Appointment'. Portsmouth Water do not own the mains and there may be a single point of supply.

Policy AL5 'Southern Gateway' is an inner city development with a good water supply system. The reference to the 'efficient use of water' is confusing because many of the other strategic development sites also drain to Apuldram WWTW. All sites need to be water efficient but not follow the example of the 'Code for Sustainable Homes'. Sites were developed in Chichester that used rainwater harvesting to meet the Code objectives but were able to use higher water use fittings such as power showers. This led to properties producing more sewage than equivalent water efficient homes. This did not achieve the objective at Apuldram. An alternative provision might be to reduce infiltration but it is not clear how this would be funded or who would carry out the work.

Policy AL6 'South West Chichester' is crossed by a large diameter main that will have to be reflected in the road layout or diverted. The proposed link road may offer an alternative route for the main.

Policy AL7 'Bosham' is situated on the old A27 and there are no large diameter mains in the area.

Policy AL8 'East Wittering' is at the extremity of the distribution system and may be expensive to supply.

Policy AL9 'Fishbourne' allocation is not site specific and it is difficult to comment on the feasibility of water supply. Any off site costs will be recovered via the new Infrastructure Charge. Portsmouth Water have public water supply abstractions in the area and development is likely to be located in a source protection zone for our Fishbourne public water supply abstraction. Under this policy, where development is in a source protection zone, the policy should also refer to groundwater quality
protection and the additional requirements when using infiltration systems in particular deep bore systems. Further guidance on Portsmouth Water's preferred approach to development relating to groundwater quality within our catchments can be found within 'Portsmouth Water's Groundwater Protection Guidance notes' which are attached to this response and also available to view on our website under https://www.portsmouthwater.co.uk/developers/groundwater-protection/.

Policy AL10 'Chidham and Hambrook' is a large site and may need to be considered in combination with 'Southbourne' and 'Bosham'. There are no large diameter mains in the area and mains reinforcements may be required.

Policy AL11 'Hunston' allocation is not site specific.

Policy A12 'Selsey' is at the extremity of the distribution system and has seen previous housing growth. Reinforcement of the water mains may need to be provided.

Policy AL13 'Southbourne' is supplied from a different distribution system to Chichester. This is a very large housing allocation and this may need to be considered in combination with 'Hambrook' and 'Bosham'. There are sufficient water resources for all the housing allocated to Portsmouth Water's area of supply. It is the location of the housing site in relation to existing trunk mains and
service reservoirs that determines the cost to supply. Local reinforcement of the water mains may be required.

Policy AL14 'Tangmere' housing allocation has increased by 30% and we may need to repeat the modelling that has already been done. There is also uncertainty about the water supply to the HDA which seems to rely on rainwater harvesting for future growth. The housing development and the HDA could have an impact on our source protection zone. Under this policy, where development is in a source protection zone, the policy should also refer to groundwater quality protection and the
additional requirements when using infiltration systems in particular deep bore systems. Guidance should be sought from Portsmouth Water's Groundwater Protection Guidance for development.

Policy AL15 'Land at Chichester Business Park, Tangmere' Portsmouth Water have public water supply abstractions in the area and the site allocation is likely to be within a source protection zone for our Aldingbourne public water supply abstraction. As above, where development is in a source protection zone, the policy should also refer to groundwater quality protection and the need for caution when using infiltration systems in particular deep bore systems. Please refer to Portsmouth Water's Groundwater Protection Guidance for further information.

Development Management

Policy DM10: 'New Employment Sites' Development proposal should be compatible with other policies in the Plan, in particular DM9 'Existing Employment Sites' to ensure that the development is otherwise acceptable. Policy DM9 states that development should 'not generate unacceptable levels of water pollution' and this should include groundwater pollution. This requirement should also be applied to Policy DM10, especially when the site is in, or close to, a source protection zone.

Policy DM15 'Horticultural Development' Developments at Tangmere HDA have relied on infiltration to dispose of excess surface water. This policy states that development should 'not generate unacceptable levels of water pollution' and this should include groundwater pollution. Portsmouth Water have public water supply abstractions in the area and the potential impacts must be assessed for any SUDS. The EA 'Abstraction Licencing Strategy' (ALS) may give an indication about the
availability of groundwater but it does not cover the derogation of existing supplies.

Policy DM16 'Sustainable Design and Construction' covers the use of Building Regulations to control water use. Portsmouth Water have an aspiration to reduce overall water use to 100 litres/head/day and this policy will help to achieve that aim.

Policy DM18 'Water Management' using SUDS needs to take account groundwater quality and should avoid direct infiltration into the chalk aquifer. This is especially important within the source protection zones.

Policy DM29 'Biodiversity' Portsmouth Water has legal duties to protect and where practical enhance biodiversity and has an active program of work on it's own land. This work is now expanding to include projects on other people's land in association with 'Catchment Management' activities. We would look to CDC for support in areas such as Bosham Stream, Lavant Stream and Fishbourne Stream where schemes could be developed in partnership with local housing developments.

Policy DM35 'Equestrian Development' can have a direct impact on water quality including groundwater quality. Portsmouth Water support the protection of water courses and aquifers.

Appendix 'E' Monitoring Framework

Policy S12 covers the provision of infrastructure but it is not clear how records of completed projects will be collected or stored.

Policy S26 covers biodiversity improvements and Natural England should be consulted on priorities and record keeping.

Policy S31 covers water consumption which is only available for the whole Company area in the WRMP Annual Review.

Policy S31
Southern Water is the statutory wastewater undertaker within Chichester District, also supplying water to the northern area of the district, within the South Downs National Park, as well as the north eastern corner of the District outside the National Park.
Through Chichester District Council's (CDC) Water Quality Group, Southern Water has been working with CDC and other stakeholders to help identify and address river and estuarine water quality issues within the District. Southern Water has in recent years invested in solutions that have either been implemented, or are in progress. In tandem with this, an important contribution through the Local Plan will be to ensure that new development does not cause detriment to the existing situation.
By adopting higher water efficiency measures and ensuring that surface water from new development is prevented from discharging to the foul network, Southern Water believes these measures will be effective in helping to mitigate the impact of new development. This approach is supported, in conjunction with a requirement to phase development to align with the delivery of new or improved infrastructure as set out in Policy S12(5). The combination of these measures, together with those submitted for inclusion within individual site allocations which seek to prevent occupation of new development ahead of necessary sewer improvements, will contribute to reducing the risk of sewer flooding that may otherwise have
been exacerbated.

Policy AL1
Southern Water is the statutory wastewater undertaker for Chichester. Taking into account preceding work that has already taken place and existing consent at this site, Southern Water will connect development at Land West of Chichester to Tangmere Wastewater Treatment Works. The necessary infrastructure is scheduled for delivery by the end of 2020.
The existing provision within Policy AL1 relating to wastewater conveyance and treatment is noted, and was supported by Southern Water during historic consultations on the current Chichester Local Plan Key Policies 2014-2029. However, since OFWAT's new approach to water and wastewater connections charging was implemented from 1 April 2018, we have adjusted our approach accordingly. Southern Water will need to work with site promoters to understand the development program and to review whether the delivery of new infrastructure aligns with the occupation of the development, and this is reflected in the proposed amendments below.

Having regard to the above, Southern Water proposes the following amendment to Policy AL1:
Occupation of development is phased to align with the delivery of infrastructure for adequate wastewater conveyance and treatment to meet strict environmenta standards.

Policy AL2
Southern Water is the statutory wastewater undertaker for Oving Parish. Taking into
account preceding work that has already taken place at this site, Southern Water will
connect development at Land at Shopwyke to Tangmere Wastewater Treatment Works.
The necessary infrastructure is scheduled for delivery by the end of 2020.
The existing provision within Policy AL2 relating to wastewater conveyance and treatment is noted, and was supported by Southern Water during historic consultations on the current Chichester Local Plan Key Policies 2014-2029. However, since OFWAT's new approach to water and wastewater connections charging was implemented from 1 April 2018, we have adjusted our approach accordingly. Southern Water will need to work with site promoters to understand the development program and to review whether the delivery of new infrastructure aligns with the occupation of the development, and this is reflected in the
proposed amendments below.

Having regard to the above, Southern Water proposes the following amendment to Policy AL2:
Occupation of development is phased to align with the delivery of infrastructure for adequate wastewater conveyance and treatment to meet strict environmental standards.

Policy AL3
Southern Water is the statutory wastewater undertaker for Oving Parish. Taking into
account preceding work that has already taken place at the adjacent Shopwyke site,
Southern Water will connect development at Land East of Chichester to Tangmere
Wastewater Treatment Works. The necessary infrastructure is scheduled for delivery by the end of 2020.
We note the existing provision within Policy AL3 relating to the need to demonstrate capacity within the sewer network and wastewater treatment works. Southern Water supports this provision, however since OFWAT's new approach to water and wastewater connections charging was implemented from 1 April 2018, we also will need to work with site promoters to understand the development program and to review whether the delivery of new infrastructure aligns with the occupation of the development. This is reflected in the proposed additional policy provision below.

Having regard to the above, Southern Water proposes the following additional criterion to Policy AL3:
Occupation of development will be phased to align with the delivery of sewerage infrastructure, in consultation with the service provider.

Policy AL4
Southern Water is the statutory wastewater undertaker for Westhampnett and North East Chichester. Taking into account preceding work that has already taken place at this site, Southern Water will connect development at this site to Tangmere Wastewater Treatment Works. The necessary infrastructure is scheduled for delivery by the end of 2020.
The existing provision within Policy AL4 relating to wastewater conveyance and treatment is noted, and was supported by Southern Water during historic consultations on the current Chichester Local Plan Key Policies 2014-2029. However, since OFWAT's new approach to water and wastewater connections charging was implemented from 1 April 2018, we have adjusted our approach accordingly. Southern Water will need to work with site promoters to understand the development program and to review whether the delivery of new infrastructure aligns with the occupation of the development, and this is reflected in the
proposed amendments below.

Having regard to the above, Southern Water proposes the following amendment to Policy AL4:
Occupation of development will be phased to align with the delivery of infrastructure for adequate wastewater conveyance and treatment to meet strict environmental standards.

Policy AL6
Southern Water is the statutory wastewater undertaker for Apuldram and Donnington
Parishes. In accordance with this, we have undertaken an assessment of the existing
capacity of our infrastructure and its ability to meet the forecast demand for this proposal.

The assessment reveals that local sewerage infrastructure in closest proximity to the site has limited capacity to accommodate the proposed development. Limited capacity is not a constraint to development provided that planning policy and subsequent conditions ensure that occupation of the development is phased to align with the delivery of wastewater infrastructure.

Proposals for 100 dwellings at this site will generate a need for reinforcement of the
wastewater network in order to provide additional capacity to serve the development. Since OFWAT's new approach to water and wastewater connections charging was implemented from 1 April 2018, this reinforcement will be provided through the New Infrastructure charge, but Southern Water will need to work with site promoters to understand the development program and to review whether the delivery of network reinforcement aligns with the occupation of the development. Connection of new development at this site ahead of new infrastructure delivery could lead to an increased risk of flooding unless the requisite works are implemented in advance of occupation.

Southern Water has limited powers to prevent connections to the sewerage network, even when capacity is limited. Planning policies and planning conditions, therefore, play an important role in ensuring that development is coordinated with the provision of necessary infrastructure, and does not contribute to pollution of the environment, in line with paragraph
170(e) of the revised National Planning Policy Framework (NPPF) (2018).

Proximity to Wastewater Treatment Works

In addition, we note that part of the site is opposite Apuldram Wastewater Treatment Works (WTW), and our concern is that the proximity of any 'sensitive' development to the WTW, such as housing, would have an unacceptable impact on the amenity of the site's future occupants arising from the WTW's essential operational activities.

Such impacts may include odour from wastewater processing and noise and vibration from operational vehicles and equipment. Paragraph 6.3.5 of the West Sussex Waste Local Plan 2014 (p42) states that 'existing waste sites and infrastructure will be protected from inappropriate neighbouring developments that may prejudice their continuing efficient operation' and that 'sensitive' uses need to consider a buffer that will depend on 'the nature of the proposed 'sensitive' use and on the specific impacts of the current waste operation'.

Having regard to the above, it is important that the layout of any development scheme should be informed by an odour assessment, to ensure there is adequate separation between sensitive new development and the WTW. This approach is further supported by The Institute of Air Quality Management (IAQM) 'Guidance on the assessment of odour for planning', paragraph 2.1 which states that 'the planning system has the task of guiding development to the most appropriate locations: ideally, significant sources of odour should be separated from odour-sensitive users of the surrounding land (sensitive receptors) [...].
New proposals for such developments may require an odour impact assessment to be
submitted'.

Existing infrastructure

We have also made an initial assessment of this site and ascertained that Southern Water's sewerage infrastructure crosses the site, which needs to be taken into account when designing the layout of any proposed development. An easement width of 6 metres or more, depending on pipe size and depth, would be required, which may affect site layout or require diversion. This easement should be clear of all proposed buildings and substantial tree planting.

Having regard to the above, Southern Water proposes the following additions to Policy AL6:
Occupation of development will be phased to align with the delivery of sewerage infrastructure, in consultation with the service provider.

The development layout must provide sufficient distance between Apuldram Wastewater Treatment Works and sensitive land uses, such as residential units, to allow adequate odour dispersion, on the basis of an odour assessment to be undertaken in consultation with Southern Water.

Layout of the development must be planned to ensure future access to existing sewerage infrastructure for maintenance and upsizing purposes.

Policy AL7

Southern Water is the statutory wastewater undertaker for Bosham Parish. In accordance with this, we have undertaken an assessment of the existing capacity of our infrastructure and its ability to meet the forecast demand for this proposal. The assessment reveals that local sewerage infrastructure in closest proximity to the site has limited capacity to accommodate the proposed development. Limited capacity is not a constraint to development provided that planning policy and subsequent conditions ensure that occupation of the development is phased to align with the delivery of wastewater infrastructure.

Proposals for 250 dwellings at this site will generate a need for reinforcement of the
wastewater network in order to provide additional capacity to serve the development. Since OFWAT's new approach to water and wastewater connections charging was implemented from 1 April 2018, this reinforcement will be provided through the New Infrastructure charge, but Southern Water will need to work with site promoters to understand the development program and to review whether the delivery of network reinforcement aligns with the occupation of the development. Connection of new development at this site ahead of new infrastructure delivery could lead to an increased risk of flooding unless the requisite works are implemented in advance of occupation.

Southern Water has limited powers to prevent connections to the sewerage network, even when capacity is limited. Planning policies and planning conditions, therefore, play an important role in ensuring that development is coordinated with the provision of necessary infrastructure, and does not contribute to pollution of the environment, in line with paragraph 170(e) of the revised National Planning Policy Framework (NPPF) (2018).

Having regard to the above, Southern Water proposes the following addition to Policy AL7
(new text underlined):

Occupation of development will be phased to align with the delivery of sewerage infrastructure, in consultation with the service provider.

Policy AL9

Southern Water is the statutory wastewater undertaker for Fishbourne Parish. We note that the spatial distribution of the allocated 250 dwellings will be determined through a revision of the Fishbourne Neighbourhood Plan. Until sites are determined Southern Water is unable to carry out an assessment of the impact of development on the local sewer network.
However, in order to minimise flood risk and other impacts on the environment, sewer capacity will need to be considered, as well as wastewater treatment capacity.

Having regard to the above, Southern Water proposes the following amendment to Policy AL9 (new text underlined):

Ensure sufficient capacity within the sewer network and relevant Wastewater Treatment Works before the delivery of development as required.

Policy AL12

Southern Water is the statutory wastewater undertaker for Selsey Parish. In accordance with this, we have undertaken an assessment of the existing capacity of our infrastructure and its ability to meet the forecast demand for this proposal. The assessment reveals that local sewerage infrastructure in closest proximity to the site has limited capacity to accommodate the proposed development. Limited capacity is not a constraint to development provided that planning policy and subsequent conditions ensure that occupation of the development is phased to align with the delivery of wastewater infrastructure.

Proposals for 250 dwellings at this site will generate a need for reinforcement of the
wastewater network in order to provide additional capacity to serve the development. Since OFWAT's new approach to water and wastewater connections charging was implemented from 1 April 2018, this reinforcement will be provided through the New Infrastructure charge, but Southern Water will need to work with site promoters to understand the development program and to review whether the delivery of network reinforcement aligns with the occupation of the development. Connection of new development at this site ahead of new infrastructure delivery could lead to an increased risk of flooding unless the requisite works are implemented in advance of occupation.

Southern Water has limited powers to prevent connections to the sewerage network, even when capacity is limited. Planning policies and planning conditions, therefore, play an important role in ensuring that development is coordinated with the provision of necessary infrastructure, and does not contribute to pollution of the environment, in line with paragraph 170(e) of the revised National Planning Policy Framework (NPPF) (2018).

Having regard to the above, Southern Water proposes the following addition to Policy AL12 (new text underlined):

Occupation of development will be phased to align with the delivery of sewerage infrastructure, in consultation with the service provider.

Policy AL13

Southern Water is the statutory wastewater undertaker for Southbourne Parish. We note that the spatial distribution of the allocated 1,250 dwellings will be determined through a revision of the Southbourne Neighbourhood Plan. Until sites are determined Southern Water is unable to carry out an assessment of the impact of development on the local sewer network, however, in order to minimise flood risk and other impacts on the environment, sewer capacity will need to be considered, as well as wastewater treatment capacity.

Having regard to the above, Southern Water proposes the following amendment to Policy AL13 (new text underlined):
Ensure sufficient capacity within the sewer network and relevant Wastewater Treatment Works before the delivery of development as required.

Policy AL14

Southern Water is the statutory wastewater undertaker for Tangmere. Taking into account preceding work that has already taken place at this site, Southern Water will connect development at this site to Tangmere Wastewater Treatment Works. The necessary infrastructure is scheduled for delivery by the end of 2020.

The existing provision within Policy AL14 relating to wastewater conveyance and treatment is noted, and was supported by Southern Water during historic consultations on the current Chichester Local Plan Key Policies 2014-2029. However, since OFWAT's new approach to water and wastewater connections charging was implemented from 1 April 2018, we have adjusted our approach accordingly. Southern Water will need to work with site promoters to understand the development program and to review whether the delivery of new infrastructure aligns with the occupation of the development, and this is reflected in the
proposed amendments below.

Having regard to the above, Southern Water proposes the following amendment to Policy AL14:

Occupation of development will be dependent on the provision phased to align with the delivery of infrastructure for adequate wastewater conveyance and treatment to meet strict environmental standards.

Para 3.2 bullet points 5, 9 & 10 - these objectives are supported
The Local Plan Strategic Objectives
Para 3.19 Health & Well-Being bullet point 1 - this objective is supported
Policy S18 Integrated Coastal Zone Management for the Manhood Peninsula : Objective 5 - while the objective is supported it should apply to all Non-Motorised User (NMU) activity. This could best be achieved by ensuring at least one multi-user route is provided around and through developments linked to the existing Public Right of Way (PRoW) and wider access networks.
Design : Policy 20 bullet point 5 - the objective is supported but should recognise that this includes multi-use PRoW for the use and benefit of all.
Planning for Health and Well-being Para 5.9 - this objective is supported but should encourage all NMU activity not limited to walking and cycling.
Transport Infrastructure
Para 5.15 - the inclusion of bridleways is welcomed but there should be specific inclusion of PRoW
Para 5.16 - the wording is misleading as the provision of bridleways on the Coastal Plain is very limited, restricting access for cyclists and equestrians. Upgrading suitable PRoW to bridleways would improve access for all NMUs and contribute to the West Sussex Transport Plan (2011-2016) to improve safety for all road users.
Policy S23 : Transport and Accessibility bullet point 8 - inclusion of PRoW is welcomed
Policy S32: Design Strategies for Strategic and Major Development Sites
Bullet points b, e & g - the aims of these are welcomed but any new routes are linked from new developments to the wider PRoW and access networks
Policy AL1 : Land West of Chichester
Para 4 - this development provides an opportunity to improve access links to the wider access network
Para 10 - there is an opportunity here to provide a multi-user PRoW for all NMUs
Policy AL2: Land at Shopwyke (Oving Parish)
Para 9 - any bridge should be for all NMUs, including equestrians, to reinstate the route severed when the A27 was re-aligned.
Policies AL3 - AL14 - opportunities for the provision of green infrastructure links to the wider countryside within these Policies are welcomed. It is particularly relevant to the Coastal Plain where the current provision of multi-user routes is very limited. Improvements in this area would comply with the objectives of the West Sussex Rights of Way Management Pan 2018-2028.

DM15 Horticultural Development - there is an opportunity within the Runcton area to enhance and upgrade routes for NMUs should the land be used for housing at a later date.
Policy DM23 Green Infrastructure
Para 7.185 - the examples should specifically include PRoW.
Bullet point 4 - more positive wording to recognise the improvement proposals could make to the access networks is preferred.
Policy DM34 Open Space, Sport and Recreation.... - the aim to retain, enhance, enhance access and increase the quantity and quality of PROW and the links to them is supported. This would be of great benefit to all NMUs is all new routes/links are multi-user.

I am very concerned about the impact of these proposals on the transport infrastructure in Southbourne particularly. Currently the roads around the railway crossing in Southbourne are gridlocked on a daily basis (at the time of schools starting and finishing, much more so than at 'rush hour' when traffic is far lighter). With the degree of expansion of housing proposed in this area there is likely to be a significant impact around the railway crossing with likely increased pollution as a result of stationary cars in traffic. How much has the traffic been assessed at this site at around 9am and 3.15pm? Assessing the traffic at 5pm for instance would give an entirely false picture of how the road is used. The current infrastructure would not cope with a significant increase in traffic and I can't see evidence of this being addressed.

There is also likely to be a very significant knock-on effect in Westbourne village in terms of traffic as this is the quickest way to drive to Havant from Southbourne. The traffic situation through Westbourne is already really quite dangerous at key times and at two points traffic is unable to flow in both directions. Increasing the traffic that flows through Westbourne from Southbourne would be a real concern,

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.

Introduction
I agree with most of the points made in the Introduction, not least the points about affordable housing, (para 2.9) for which there is a clear demand and inherent because of the 0.75%pa rise in population and the yawning gap between incomes and house prices.
I will acknowledge that I am writing as a baby boomer, but I note the above average presence of senior citizens in the CDC area and your anticipation that it will rise to 35% by 2015 (para 2.8). This surely has implications for the facilities that CDC, and probably more so WSCC because of its responsibilities for social care, will need to provide, and I do not notice any focus on this in your introductory section. In fairness I am slightly more encouraged when I read paragraph 3.19
I would also ask how many of the young people educated in the area return here to live and work after qualifying. And if the number is low, why, and what do you propose to do to ameliorate the haemorrhage?
Spatial Vision and Strategic Objectives
I agree with your list of items in paragraph 3.2. That said, I note that you state that people should be able to "move around safely and conveniently with opportunities to choose alternatives to car travel (my emphasis). This surely has major implications for public transport, for walking, and for cycling, and surely these should be highlighted in this introductory summary. I shall look forward to seeing what you have to say about these later in the document.
I agree with paragraph 3.3 - but what do you mean by your hope to "balance the ageing population"? That could sound horribly ominous!
In para 3.4 I understand the wish to diversify the local economy - but where are these new organisations to go? You talk about "new sustainable neighbourhoods on the eastern, western and southern sides of Chichester, which could, especially when one thinks of Whitehouse Farm, appear to presage a level of growth which will frighten many. I think that the example of Summersdale, where I live, does not bode entirely well, for it is largely devoid of any community centres and has no public transport in the evenings.
In para 3.6 you speak of a "highly accessible transit corridor" Do you really mean this, says he thinking of the state of Chichester by-pass, the queues that I see coming east on to the Fishbourne roundabout in the morning, and the rush-hour queues from Bognor? Perhaps I could add what the all too predictable impact of Whitehouse Farm will be on both the Fishbourne roundabout and the Northgate gyratory.
Re para 3.10, my understanding is that rather more than "moderate levels of growth" are proposed between Fishbourne and Southbourne, and I shudder at the impact on the A259, all the more so when I think of all that traffic passing through the narrow main road at Fishbourne and also coming out on to what is already a very dangerous Fishbourne roundabout, which I do my best to avoid now!
Turning to paragraph 3.19 I welcome, amongst the other points you make there, the references to affordable housing, to air quality, to the section on health and well-being, and (at a time of fears about global warming) to the reference to flood risk.
Spatial Strategy
I welcome the list of services and facilities mentioned in paragraph 4.12, as that most certainly is not the case in present-day Summersdale.
In fairness I recognise the increased demand for housing as mentioned in para 4.22, as this is inherent in an area of rising population and probably more single-person households (which I have not seen mentioned). I suspect, for instance, that I am far from alone in living singly since bereavement in the family house where I have lived for forty years and from which I have no plans to move. That said, enormous care will be needed in selecting the areas for expansion and the implications for infrastructure and community buildings. Moreover you are clearly right in para 4.30 to refer to longer term growth.
You are clearly right to talking of "meeting the housing needs of the plan area and tackling homelessness" in para 4.34. In all honesty I was appalled when I saw the numbers of people sleeping out late a night when I happened to walk home at a late hour last March. I did not think that such an inhuman state of affairs obtained in Chichester, and am horrified that it still apparently does. I strongly agree with paragraphs 4.43 and 4.44. I welcome the policy statement S6, even if I think that we really need is a return to council house building, as was used to solve even worse problems in the decades after 1945.
Re para 4.66 I have very mixed feelings. It has pleased me not to see the extent of boarded up properties that one sees elsewhere. That said:-
* I write as one who detests shopping and does very little within Chichester city centre; I probably use only about half a dozen shops and those only occasionally.
* I know that my wife always preferred to go to Worthing and can think of a friend who prefers Southampton.
* I think that you have to recognise as a fact of life that more people are going to shop on-line, not least for reasons of price, and that that inherently impacts on traditional retail shopping.
* I tend to do my shopping on the edge of town as that is where the big supermarkets are and parking is easy. I would take some persuasion to change that.
* Looking at policy S9, do you really need more shipping in the Southern Gateway at a time of decline of town centre retail shopping?
Providing Supporting Infrastructure and Services
Paragraph 4.80 should also include cycle tracks and bus routes if you really want to move away from the use of private cars.
I note that paragraph 4.81 includes a reference to "appropriate revenue support". I fully agree and wish that I could believe that this present austerity-obsessed government would actually provide it.
Your policy S12 seems right to me.
East-West Corridor
I think that you are somewhat optimistic in paragraph 4.88. The 700 bus service is very good, but what about other routes, especially in the evening? The present state of the Chichester by-pass is dreadful, and the Fishbourne roundabout is a particular source of danger, moreover one likely to be made worse by more traffic coming from Whitehouse Farm and from further development along the A259.
Policy S13 seems fine to me.
Paragraphs 4.95-98 describe a situation that I know only too well. I would add that as a cyclist I find the western end of The Hornet and St Pancras to be by far the most dangerous pieces of road in Chichester, and I write as one who usually does not mind where he cycles.
I do not agree with paragraph 4.101 - I think that a park and ride is badly needed, arguably from both the west and the south.
Re policy S.14:-
* Re peripheral car parks, if you want to revive the city centre, is that really the answer? What about those who find walking difficult or who do not want to carry heavy shopping half a mile to their car?
* I shudder what the queues will be like with a bus lane up to the Bognor roundabout.
* I think that the present bus/rail interchange is quite good, though I think that you need safer crossing of the road and seats in the bus station
* I do not notice any statement about solving the problems caused by the level crossings by Chichester Station. Having had to wait there for over five minutes yesterday while a train was sitting in Chichester Station I feel bound to ask whether there cannot be some mechanism to bring the gates down just before a train is due to leave, and when you are going to have either a bridge or an underpass there.
Re paragraphs 4.103-105, wshat consideration has been given to the transport consequences of such development, especially given the absurd decision to remove the Oving lights?
Given that I live in Maplehurst road, you will not be surprised that I have noted policy S15. Essentially I welcome this policy, not least, as having some pretentions to being a musician, I am very aware of noise, and the weekends where un-silenced racing is allowed are truly a misery, which ideally would be stopped as unbelievably selfish and insensitive and at very least should not be allowed to expand beyond the one such meeting per year. In fairness the banks erected some years ago have made a difference, and for the most part aircraft do behave themselves. I also think that any housing development closer to Goodwood Airfield should be out of the question, as the noise would be intolerable to anyone with normal hearing. In policy S16, point 2 I think that un-silenced racing should not be allowed despite their loss of amenity, as the consequent noise is not reasonable.
Re paragraphs 4.111-115, what do you think is going to be the impact of 1600 new houses in that area - to amenity and the rural aspect; to the A259; to traffic through Fishbourne; and the already dangerous Fishbourne roundabout? I think that the scale of this development is highly questionable for these reasons.
Strategic Policies
Looking at policy S20, I agree with all the points that you make. I would add:-
* The need for a public transport system that does not stop in the evening, and
* The need for good bicycle access. When I think that at least twice a promised access to Centurion Way has not been delivered, I think it fair to make that point, especially if you really do want to get people out of their cars.
Re paragraph 5.16 I find it sad that you do not mention in your strategic corridors that the cycle track adjacent to the A259 going west from Chichester is part of cycle route NCN2.
Re paragraph 5.22 our roads are going to be even more over capacity with significantly more housing development. I have already referred several times to my concerns over the dangerous Fishbourne roundabout.
Re paragraph 5.27 I welcome the interest in cycling provision. Living in Summersdale it takes me less than ten minutes to cycle into the city centre - in fact by far the quickest way I can get there. For the most part it is safe, I think, but with the glaring exception of the Northgate gyratory. Whoever designed that clearly forgot that a cyclist is at his/her most risk when pulling away, so to expect cyclists to stop at each exit is a massive deterrent. This cyclist prefers not to use the cycle lane in order to have safer crossing at each exit. I find the St Pauls Road exist especially dangerous. I would also like to have paint markings on the raised kerbs at each exit for safety in the dark.
More generally, if you are in the Low Countries, it is exceptional for cyclists can have two way traffic in what it is a one-way street for motorists - I have seen so many no-entry signs there with "uitgezonderd fietser" below. In fairness there is some of this in Chichester, but I think that there is scope for more.
I also think that Chichester centre needs increased provision for cycle parking, for instance adjacent to the Little London car park, where there is plenty of potential space, and at the eastern end of East Street, where I find the present racks often to be full.
I would also like you to think how cyclists can be safer at the western ends of The Hornet and St Pancras, which are the two roads in Chichester which make me feel very chary.
With the additions of the points made in the previous paragraphs and also restating a need for evening bus services, I generally support the points made in policy S23, though I would repeat what I have already said about expecting people to park too far away from the city centre if you really want people to come there, and I would extend this point by saying that if you are going for distant parking, a park and ride becomes essential. I am agnostic about the Birdham Road to Fisbourne proposal, as I do not know enough about it to comment.
Re policy S24 I would make a particular plea for the Lavant Gap, which is important both to Lavant and Summersdale especially as an important part of our amenity. And we did not fight to save it to have a northern by-pass trundling through there!
I agree with policy S27 and would add that I can remember the floods some fifteen years ago and looking out at the River Lavant east of Maplehurst Road to see how far the waters were going to spread. That too me (besides proximity to Goodwood) would be a major factor in my opposing any development there. I am aware that the Pagham Rife project subsequently ameliorated the risk, but I still think that it needs to be borne in mind, especially given the impact of global warming.
I agree with policies S28 29, 30, and 31. I would make a particular point of air and noise pollution.
Strategic Site Allocations
I agree with policy S32,
How can you write paragraph 6.8? You will know as well as I do that cycling links are not good, and will be worse if Centurion Way is to be diverted. Also how are cyclists supposed to get into the city from the northern end of Whitehouse Farm - down St Paul's Road and coming on to the Northgate Gyratory (which will also be receiving significantly more motor traffic? Please!! I hope that you also know that the plans could well include a really dangerous junction on Centurion Way that is the entrance from Bishop Luffa Close.
As for motor traffic, the same point about St Paul's Road applies. And as for the southern end, surely you know what that is going to do to local roundabouts, not least the dreadful Fishbourne roundabout?
In terms of recreational disturbance, (para 6.12) why is there no reference to Centurion Way?
The points above all are relevant to policy AL1.
Re policy AL2 I do not know enough to comment in much detail. That said, I am concerned about transport access. I know that I am not alone in detesting coming up to the Bognor roundabout from Bognor and often prefer the safer route via the Oving traffic lights. Has any account been made of how such traffic, which is not inconsiderable will be affected, and how this will make the journey from Bognor to Chichester significantly worse than it presently is?
Re policy AL5 I accept the case for redevelopment, though was far from impressed with the last proposal I saw and commented on at the time; I thought, and still think, that the road alternations then proposed were insane and asking for more rather than less jams. I welcome the references to access for cyclists and pedestrian. I am not clear when there are references to the bus depot as to whether that includes the bus station. If you want people to come to Chichester centre, bus access needs to be close; moreover the present bus station is properly close to the railway station, which is important for integrated travel. I do not see any reference to taking away the present crossing gates, which are a serious impediment to traffic at the moment, both on Stockbridge and Basin Road; I think that that is a bad omission.
Re policy AL9 I lack the detailed knowledge usefully to comment, but would ask how far the present state of the A259 has been borne in mind in planning both in Fishbourne and further west from Chichester. It is narrow and at times congested now - major development can only exacerbate such problems.
Re policy AL10 I can comment only as one who fairly often cycles east-west along the A259. The exit from the cycle track on the southern side of the A259 to the east side of Chidham is presently dangerous because of the road layout and the warning sign about cyclists being several; yards too late and often obscured by foliage. Where there is a cycle track in Chidham, parking on that track is not uncommon. There is also a significant gap in the cycle track through much of Chidham. Moreover this is part of a national cycling route, and will become even more significant with more development in Chidham and points west.
Re policies AL11 and AL12 please bear in mind the need for cycle access and for the proposed cycle track between Chichester and Selsey (via Hunston) to develop, especially if you really mean to develop non-motor transport (and also as a valuable and healthy amenity) and bearing in mind how dangerous the B2145 is.
Re policy AL13 cycling provision to the west of the roundabout presently is reasonable; it is not good west of the roundabout. My comments about NCN2 refer here too.
Development Management
I am especially pleased to see paragraphs 7.2, 7.4, 7.6, and 7.8, as with an ageing population and baby bookers such as me passing 80 within ten years or so, increased specialist provision is inevitably going to be necessary. This is not to downplay other specific groups, eg students - I simply write from an area of specific knowledge. I agree with policy DM1.
The principles behind policy DM2 seem right to me and I am pleased to see recognition of the need for affordable housing. I would make specific reference to resolving homelessness, young families with not much money, and people in the twenties moving to a new area to start work.
I agree with what you are saying in policy DM8. I have raised my concerns about such issues as cycling routes, bus services, parking and the impact on existing crowded and/ or dangerous routes earlier in this response.
I can see why you are seeking to protect the city centre and prevent an excessive dominance of out of town areas, all the more so as I have seen this in the USA. That said, I find shopping on the edge of town a lot easier -things are in the same place; parking is easier; prices tend to be better. And how far are you crying for the moon as on-line shopping takes off? I for one would take a lot of persuasion to do much shopping in a city centre especially with poor parking. So, while I accept most of what you say in policy DM12, it is with this big proviso.
I agree with policies DM13 and DM14.
I think that any new building should have to incorporate solar panels (re policy DM16). I know how much electricity my solar panels have saved me, and, were I younger and further solar installation not so expensive (it would take me more than a decade to get my money back) I would seriously consider more to provide solar energy for heating and electricity storage.
We are now so aware of air quality issues that I am very pleased to see policy DM24. I also agree with policy DM25 and would add that this should be a significant issue (because of the noise pollution emanating from Goodwood) for any development east of Maplehurst Road.
Re policy DM33, last time I was there I thought that the canal towpath was very dangerous at the western end, particularly for anyone trying to ride a bicycle there.
My apologies but I do not know enough about the later policies usefully to comment.

Summary
In case it helps for me to summarise what I have been seeking to say:-
* As a cyclist I have inevitably had a lot to say about present inadequacies in the network. These need remedy if you really want people to get their bikes out in a city that is made for cycling and feel safe in so doing. Moreover there are the clear health and pollution gains from more cycling, and it is actually often the quickest way from a resident anywhere in the city to get into the centre.
* Housing is important - to resolve homelessness; to provide affordable housing; to meet the needs of young families with not much money or young singles moving here to begin a job/ career.
* There are particular issues re an ageing population and the increased needs are so predictable now even if perhaps not immediate.
* If you really want people on buses, fares have to be lower so that they are competitive with the marginal cost of a car journey for a family, which they are not at present. Services need to be good and to include the evenings.
* I think that there is a danger of Canute tendencies re retail when I think of the attractions of edge of city shopping let alone on-line trading.
* This is linked with car parking - reasonably central car parking and/or a park and ride are crucial if you really want to maintain/expand the city centre.
* The present situation over the level crossing is unacceptable.
* The Fishbourne roundabout is unacceptably dangerous, and the present "by-pass" is a denial of your hopes of an easy east-west transit.
* I am pleased to see the sections on air and noise pollution, and also the encouragement of solar electricity, and I hope that these will really mean something

S3, S4, AL13
Strategic policy should be included that consider the area west of Chichester as a whole rather than as a series of unrelated settlements along the A259 transport route, which is implied by it being referred to as the "east-west corridor". A number of common issues would benefit from collective and co-ordinated attention eg waste water treatment, traffic congestion/management, landscape protection, wildlife corridors and the need to prevent coalescence (para 6.87). The area is expected to provide for a minimum 2250 new dwellings, in addition to the allocations in the current Local Plan (475), and is under great pressure due to its being squeezed between Chichester Harbour and the National Park, both being areas having the benefit of particular protection. This pressure is exacerbated by the National Park not accommodating its fair share of new development and by substantial development in neighbouring Emsworth, Hampshire, that adds to the pressures on the Chichester Harbour AONB and West Sussex infrastructure including road traffic and the capacity of Thornham Wastewater Treatment Works.
Supplementary Planning Guidance is required to address the issues specific to this area, provide clarity of guidance for developers and enable co-ordinated solutions.
S6
Affordable housing should relate more closely to local income levels. Local residents have made the point many times, during the preparation of the current Neighbourhood Plan and more recently in connection with the Neighbourhood Plan review, that local people cannot afford local housing, either to buy or rent. The Parish Council intends to commission a Local Housing Needs Survey which could help identify the quantity and type of need in the Parish.
(add to end of para 4.34) This means housing is unaffordable to many people in the Plan area and why income levels will be taken into account in establishing house prices and rent controls. 80% of the local market rent is the maximum, but lower rents are likely to be justified in some instances.
Developers must deliver their "affordable" requirement if sufficient housing to meet local needs is to be provided. This should not be a problem if proper account is taken of the cost of land acquisitions and development at a sufficiently early stage. Subsections 1 and 5 in Policy S6 allow too much flexibility, especially the use of the word "appropriate" in subsection 1 which is too subjective.
Delete or amend subsections 1 and 5, as appropriate.

DM2
The Parish Council fully supports Policy DM(2). It considers that there is likely to be a need in the Parish for more rented accommodation, especially social rented, than is proposed in Policy DM2. It is understood that this is one of the most expensive areas for housing in the country and young people, in particular, struggle to find accommodation they can afford close to their families. A Local Needs Housing Survey of the Parish is likely to be undertaken in preparing the review of the Neighbourhood Plan to help identify the extent of local need and investigate ways to meet it. Accordingly, an alternative housing mix may be prepared for Southbourne Parish (para 7.19)
Local consultation has revealed a shortage of specialist housing, especially for the elderly and the disabled. It is considered that creative policies promoting adaptable "lifetime" dwellings are required to enable the elderly to remain in the community for longer. The Local Housing Needs Survey of the Parish is expected to confirm this.
The market housing 4+ bedroom % needs to be reduced in favour of more single person accommodation. The Parish Local Housing Needs Survey is expected to confirm this
S20, DM1, DM2
Local consultation has revealed a shortage of specialist housing, especially for the elderly and the disabled. It is considered that creative policies promoting adaptable "lifetime" dwellings are required to enable the elderly to remain in the community for longer. The Local Housing Needs Survey of the Parish is expected to confirm this.
Add "the disabled" into the policy.

AL13

It seems likely that most of the 1250 dwellings proposed (and this is a minimum figure) will be in Southbourne village. Some sections of the local community are very concerned about the change that an over 50% increase in households, over and above the current new development of 300 dwellings, will bring. Some consider that it provides an opportunity to bring some creative thinking to the future format of the village. Whatever increase in development may come, it appears that most residents do share the view that the 30% "affordable housing" proposed in the Local Plan should be truly affordable for those people in the Parish who are in housing need, and the Parish Council has made comments on the relevant policies in this Plan accordingly.
However, at present, it is clear that Southbourne is not in a position to successfully accommodate 1250+ further dwellings due to inadequate infrastructure. While it is recognised that Southbourne village may qualify as a "hub" due to existing services, it must be recognised that a number of these are currently inadequate and substantial improvement is required before development on this scale is delivered. It is understood that new development cannot be required to pay for current deficits, but it is unacceptable to add to these problems without some "up-front" provision to cater for increased needs. Three examples serve to make the point:-
(1) Crossings over the railway, both road and pedestrian, are required before any delivery of 1250 new dwellings. Even if this development is phased, it could be assumed that there will be a completion rate of some 80 dwellings a year (1250÷15). The additional pressure on the Stein Road level crossing arising from a combination of construction traffic and new residents will create unacceptable congestion, pollution and waiting times at the barriers. Inlands Road and Cooks Lane are not suitable for lorry routing. AL13(4) "Opportunities as they arise to improve the situation relating to the various existing or planned railway crossings" is much too weak to secure timely delivery. While this may be addressed in the review Neighbourhood Plan Masterplan, support at District level is required with appropriate priority in the CDC Infrastructure Delivery Plan (IDP) (Policy subsection 14).
In addition, no attention has been given to traffic management, either on the A259 or within the village, in the Preferred Approach. Strategic sites of a broadly similar scale around Chichester have integral transport proposals, but they are lacking in Southbourne. One key issue is that all along the A259 from Emsworth to the Apuldram junction it is becoming increasingly difficult for traffic entering onto the A259 (whether heading east or west) due to the high volume and at times seemingly continuous flow of traffic in either direction: this is a cause of driver frustration and potential cause of road accidents.
(2) The Parish Council has raised the issue of Wastewater treatment many times, and there have been difficulties arising from the current development sites. Reassurance is required that AL13 subsection 16 will be adhered to (16 - Ensure sufficient capacity within the relevant Wastewater Treatment Works before the delivery of development as required).
Stormwater discharges to Chichester Harbour appear to be on the increase and this is not satisfactory. The issue needs to be addressed and resolved by the Wastewater Water Quality Group (para 5.71).
(3) The Parish requires a significant increase in Public Open Space. The proposed Green Ring has received considerable public support and a Trust has been established by the Parish Council to deliver it. Some sections of the Green Ring will not be able to rely on developer delivery and while the project is included in the IDP it is accorded almost no priority (Policy subsection 14). This needs to be remedied.
Specific commitment in the Preferred Approach to the delivery of crossings over the railway, assured delivery of timely and appropriate Wastewater Treatment and specific commitment to the delivery of the Green Ring.
6.88 - To sustain and enhance Southbourne's role as a hub it is VITAL that development is properly phased AND that necessary infrastructure provision is made prior to new occupations.
Policy AL13 item 12: the protection of the SPA, SAC and Ramsar site at Chichester harbour necessitates the reinstatement of the Ham Brook wildlife corridor as part of giving the harbour and wildlife that uses it 'breathing space' and a ladder to the SDNP and as part of the strategy to relieve the pressure imposed upon the harbour by walkers and dogs.
7. Expansion and provision of community infrastructure potentially to include early years' childcare provision, community hall/centre and expansion of doctors' surgery plus flexible space for employment/small-scale leisure use;
As the open space and pitch reports put the improvement of the Bourne college facilities and the recreation ground improvements as a high priority project, this should be mentioned in this point
7. Expansion and provision of community infrastructure potentially to include early years' childcare provision, community hall/centre and expansion of doctors' surgery plus flexible space for employment/small-scale leisure use;

As the open space and pitch reports put the improvement of the Bourne college facilities and the recreation ground improvements as a high priority project, this should be mentioned in this point

DM3

The Preferred Approach advocates a flexible approach to housing density. While an average of 35 dwellings per hectare is recognised as a reasonable guideline, the Parish Council considers that some areas of a higher density would be appropriate, especially where single person accommodation could include small privet patios, terraces or balconies (for flats) in recognition that not all householders want a large private garden, provided that appropriate public open space is delivered as an alternative. Higher densities, as appropriate, also reduce land take.
S23
Southbourne Parish Council responses on the Jacobs Chichester Area Transport Model Report (March 2013), Chichester District Council Chichester Local Plan - Key Policies 2014-2029 and Chichester Local Plan Issues and Options Consultation has consistently drawn attention to the restricted scope of the transport studies undertaken to establish the impact of proposed development allocations within the Plan area. Studies have been concentrated on establishing the effects in the immediate vicinity of Chichester, particularly on the junctions of the A27. Traffic movements generated within/or destined for Southbourne Parish are assigned to a single Traffic Zone (TZ73). These movements are aggregated with other movements in the other TZs of the Western Corridor in order to assess the impacts at the cordon boundaries of the County boundary with Havant/Hampshire but most significantly the point of contact with the A27. Mitigation requirements have been assessed solely in respect of reducing increased congestion at A27 junctions. In respect of Southbourne generated movements these relate to the Fishbourne Roundabout.
CDC, in association with WSCC Highways, has failed consistently to examine local network impacts other than those projected to arise on the 19 junctions in the immediate vicinity of Chichester and the A27. This remains the situation with the update by Peter Brett associates of the Jacobs Study. However, in respect of the Bourne Villages this approach fails to take into account the impacts likely to arise within the local road network of the respective traffic zones. In particular, this lack of examination fails to take account of the potential impact arising from the scale of proposed housing allocations in this corridor. The adopted Chichester Local Plan Key Policies 2014 - 2029 document allocated a total of 620 additional houses comprising: Westbourne 45, Southbourne/Nutbourne 350, Chidham & Hambrook 35, Bosham 70 and Fishbourne 70. The Review Document proposes additional housing allocations (minimum) at Southbourne 1250 houses, Chidham & Hambrook 500, Fishbourne 250, Broadbridge/Bosham 250 - a total of 2,250 additional houses, an increase of + 246% over previous allocations and with these villages taking a 46% share of proposed total additional allocations in the Local Plan Review area.
CDC together with WSCC Highways should undertake to provide specialist advice to those Parish Councils chosen to implement proposed strategic housing allocations through Neighbourhood Plans in order to assess the impacts of the scale of such allocations on the local highway network. Such advice should be provided in order to aid site selection prior to any master planning of the subsequent development proposal and to help find solutions to traffic problems arising.
The above comments/representations also relate to the following Plan references:
Strategic Development/Design Strategies, pages 92-93, paras 6.1-6.6. Policy S32
Strategic Site Allocations - Southbourne, pages 127-129, paras 6.68-6.90; Policy AL13
Transport & Accessibility, pages 148-149, paras 7.4-7.52; Policy DM8.
Spatial Vision and Strategic Objectives
Objection
3.4 Given the huge amount of development proposed for the settlements to the west of Chichester we object to the emphasis placed on Chichester in the special strategy at the expense of the settlements on the receiving end.
There needs to be a fresh look at the cumulative impact on the settlements along the A259. We are not primarily an East-West corridor; we have our own distinct identities and histories. While the term 'East-West corridor' describes the road and rail links to the west of Chichester it is not a sufficient description of the Bourne villages.

3.7 Maintaining and enhancing the relationship between the SDNP and the Harbour AONB requires the reinstatement of the proposed Wildlife Corridor at Ham Brook. Without this corridor, this aspiration has no teeth.
3.8 Southbourne's "good transport links" have recently been downgraded with loss of all north-south buses which will be needed to connect any new housing growth north of the railway line to both the station and the A259. The station itself needs nearby parking and/or drop-off points, electric car chargers and secure cycle storage.
We suggest that the Bourne villages area be considered a 'green / blue ladder' between the AONB and the National Park rather than an East-West transit corridor. Varied countryside views from the Bourne villages towards the SDNP and AONB should be protected, as should views from the A259 and railway of the local countryside and countryside gaps. This will require properly contoured development and good screening.
Sustainable Development Principles
Objection
A reliance upon national 'sustainable development' principles is insufficient as these national policies are inadequate for delivering genuinely sustainable development.
There needs to be an emphasis on economic, social and environmental sustainability. The built environment and history, so frequently lumped in with environmental sustainability, should be considered as part of economic and social sustainability where this conflicts with natural environmental sustainability.
The construction industry is a significant contributor of carbon emissions and while we recognise that there is limited scope to make requirements beyond those mandated by national legislation the Local Plan should nevertheless indicate the direction of travel. It should set out what the community will increasingly come to expect from the industry in the years ahead, including the increasing weight that may in future be given to developments and developers which are making serious attempts to become carbon neutral.
The objective of the Local Plan should be to aim higher. While recognising that not everything is possible, we suggest referring to the principles set out in the Wildlife Trust's 'Homes for People and Wildlife' policy guidance: https://www.wildlifetrusts.org/sites/default/files/2018-05/homes_for_people_and_wildlife_lr_-_spreads.pdf and the World Health Organisation's 'Urban Green Spaces - A Brief For Action': http://www.euro.who.int/en/health-topics/environment-and-health/urban-health/publications/2017/urban-green-spaces-a-brief-for-action-2017 .
See comments in section above.
S17
Object
We welcome the presence of the military base and recognise that the needs of the military will determine policy while the base is maintained, including the need for an upgrade of the housing stock on the base.
However, should Thorney Island cease to be required for military purposes, rather than masterplanning for new development, the island should receive at least equal protection to other areas within the AONB, including the presumption against new development. Any proposed development should follow the principles laid out in the Chichester Harbour Conservancy's Planning Principles policy: www.conservancy.co.uk/page/planning.
In addition, while not seeking anything that would compromise the base's security, the policy should be to expand the Dark Skies sites and, where necessary, to take additional steps to support the existing ones e.g. by upgrading or redirecting street lighting. It should be possible to reduce vertical light pollution without any negative consequences for the existing use of the base. Further information on possible measures that could be considered may be found in the SDNP Technical Note here: https://www.southdowns.gov.uk/wp-content/uploads/2018/04/TLL-10-SDNPD-Dark-Skies-Technical-Advice-Note-2018-2018.pdf
We welcome the presence of the military base and recognise that the needs of the military will determine policy while the base is maintained, including the need for an upgrade of the housing stock on the base.
However, should Thorney Island cease to be required for military purposes, rather than masterplanning for new development, the island should receive at least equal protection to other areas within the AONB, including the presumption against new development. Any proposed development should follow the principles laid out in the Chichester Harbour Conservancy's Planning Principles policy: www.conservancy.co.uk/page/planning.
In addition, while not seeking anything that would compromise the base's security, the policy should be to expand the Dark Skies sites and, where necessary, to take additional steps to support the existing ones e.g. by upgrading or redirecting street lighting.
S24
Support
However, much of the language in this section is weak and aspirational rather than strong and definitive.
5.37 The coastal, alluvial agricultural plain has a particular historic and environmental character which we value greatly. This includes, but is not limited to recognition of its value for agriculture / food production. While we do not expect that this landscape will have the same protection as that inside the SDNP, it forms part of the setting for the National Park and deserves some recognition of the threats facing it from piecemeal (though rapid) development.

The draft Plan in its present form does not give sufficient recognition to the inherent value of the land. It would make sense for this to be rectified as part of a strategy or vision for the whole of the Bournes area, perhaps in a supplementary planning document.
We would like to see the preservation, protection and even reintroduction of bees and their habitats be given real consideration, given their ecological importance. It makes sense to do this as part of a policy covering countryside gaps so as to avoid conflict with humans.
We call for greater support to be offered to the establishing of community orchards and nut plantations. Doing so would also contribute to improving the balance between people and nature, enhancing social sustainability goals and promoting wellbeing.
5.40 We strongly support the "encouragement of proposals that enhance the woodlands and recreational links to and within this area."
5.41 There needs to be greater engagement with the SDNP and greater recognition from the SDNP that it is at risk of becoming an island, which will have serious negative impacts upon the park. We need the National Park to be more flexible in accepting a greater amount of housing within the park in order to relieve some of the pressure on the park's surroundings. While development is concentrated around the Park, we need to know that the Park will not object to the provision of infrastructure that such development needs to be sustainable, provided that it is planned sensitively.
5.42 We strongly support the maintenance of individual settlement identities. Southbourne would like to have a significant input into the formation of a settlement gap policy (and expects other communities along the A259 to feel the same). We would like a meaningful input at an early stage so that we can help shape a policy that commands wide public support.
S25
Object
This policy is very weak. A policy for protecting and managing the coast simply must address the wholly inadequate waste water infrastructure capacity and the frequent discharging of untreated waste into the Harbour.
It must also include a robust strategy for mitigating pressure on the harbour and coastal habitats from walkers and dog walkers by providing for alternative, attractive routes. This should clearly link up with policies promoting wildlife corridors, countryside gaps and green/ blue space.
The Plan should also seek to work with agriculture and horticulture businesses to reduce the impact of chemical and nutrient run-off into the Harbour. We recognise that there are constraints both in terms of national policy and market forces but the Plan should make clear that the direction of travel is towards greater environmental sustainability and reducing the environmental impact from businesses.
S26
Object

This policy is too weak.
5.52 & 5.53 The Plan should seek to work with agriculture and horticulture businesses to reduce the impact of chemical and nutrient run-off into the Harbour. We recognise that there are constraints both in terms of national policy and market forces but the Plan should make clear that the direction of travel is towards greater environmental sustainability and reducing the environmental impact from businesses.
We note that the adopted Local Plan links its Natural Environment strategy to that which protects and promotes biodiversity, but this link seems to have been dropped in the draft proposal. We recognise that there is a section on biodiversity but question the implication of the breaking of this link.
The policy needs to be strengthened.
S27 and S30
Object
It is very disappointing not to see a much stronger role for the use of green / blue space in mitigating flood risk. E.g. reed banks and areas designated for wildlife can form both a natural flood defence and promote other environmental goals of the Plan. Tree planting should also form part of this strategy, as should other measures to strengthen the land's resistance to flood degradation.
The reinstatement of the Ham Brook Wildlife Corridor would provide an opportunity to introduce many of these features in a part of the District prone to the flooding of homes and to storm-related discharges of untreated wastewater into the harbour.
The policy must think beyond what individual sites can do to mitigate the risk of flooding on small areas of land and look at the wider picture and what a more ambitious strategy could achieve.
The reinstatement of the Ham Brook Wildlife Corridor would provide an opportunity to introduce many of these features in a part of the District prone to the flooding of homes and to storm-related discharges of untreated wastewater into the harbour.
The policy must think beyond what individual sites can do to mitigate the risk of flooding on small areas of land and look at the wider picture and what a more ambitious strategy could achieve.
S28
Object
We are astonished that this policy is so thin. There needs to be a strategy which recognises different forms of pollution, including air quality, inland and coastal water and carbon emissions (not least from the construction industry). We need more detail on strategies to address the different forms of pollution and to be looking to a less polluted future, not simply mitigating against the deterioration of the status quo.
S29
Support
However, there needs to be an explicit recognition of the sometimes conflict of interest between green infrastructure primarily intended to be of human / community use and enjoyment and that intended to protect natural habitats and which may require restrictions upon access by the community.
There also needs to be much more thought given to coordinating the creation and protection of multiple green / blue infrastructure sites across the Plan area (or sub-sections of it). Many opportunities will be lost if sites are considered separately rather than as part of something larger. 'Islands' of green space are of much less benefit to humans and wildlife than larger, linked green and blue infrastructure. Again, this supports the reinstatement of the Ham Brook Wildlife corridor.
S30
Support
We are delighted to see a wildlife corridor policy included within the Neighbourhood Plan, as this builds upon the aims pursued in the made Southbourne Neighbourhood Plan and the work of the Southbourne Environment Group. We do however very strongly object to the removal of the previously proposed Hambrook Wildlife Corridor, referred to only obliquely in the Background Paper. It should be reinstated.

Doing so would work towards the policy objectives of S30 and complement its specific proposals.
1) There are a great many "preferable sites available outside the wildlife corridor" so reinstatement would not hinder the District or Parish's ability to meet its housing target.
2) Without prejudging the community consultation, it is conceivable that proposed development sites WITHIN the proposed corridor could be approved provided they do "not have an adverse impact on the integrity and function of the wildlife corridor".

In considering alternatives to the Chidham / East of Nutbourne Wildlife Corridor, paragraph 5.5 of the Background Paper states that "West of Nutbourne there are a number of ecological features but the close proximity of residential areas and proposed development, mean that the [proposed] corridor may be too narrow to act as a suitable functional strategic corridor." This actually prejudges the review of the Southbourne Neighbourhood Plan and we reject this argument. The proposed Ham Brook Wildlife Corridor is or could easily be as wide as others in the policy paper and it is for the community - through the Neighbourhood Plan - to determine where development goes ahead. The community cares very deeply about the local environment and could easily choose to focus development outside of the proposed route of the Ham Brook Wildlife Corridor.

There is no national or local policy reason why there should be no more than one wildlife corridor in a single Parish, especially where there is no conflict with the points above / in policy S30 and where the parish is one of the largest in the District and is home to several distinct communities. On the contrary, reinstating the Ham Brook corridor would strengthen the goals set out in paragraphs 5.64 and 5.65 of the Local Plan, namely, allowing the "movement of species between areas of habitat by linking wildlife sites and reducing the risk of small, isolated populations becoming unsustainable and dying out... They also function as green infrastructure."

This last point is itself emphasised by the Plan's policy AL13 for Southbourne and many objectives would be advanced by reinstating this particular Wildlife Corridor. i.e.:

8. It COULD provide for some public open space for the Parish (not all of which is, will be part of or will be connected to Southbourne VILLAGE's Green Ring).
9. It would enhance the setting of the SDNP and reduce settlement coalescence (without restricting development elsewhere in the Parish).
10. It would expand provision for green infrastructure.
11. As per background paper paragraph 5.5. referenced above, it would reconcile the need to avoid an adverse impact on the nature conservation interest of identified sites and habitats while maintaining a wildlife corridor wide enough to be of ecological value.
12. It would provide mitigation to ensure the protection of the SPA, SAC, Ramsar site at Chichester Harbour.

As per Supporting Document 024, Solent Recreation Mitigation Strategy, paragraph 2.12, there is a requirement for the creation of a Suitable Alternative Natural Greenspace (SANG). Furthermore, Southbourne's made Neighbourhood Plan's Green Ring policy specifically aims to provide alternative routes for dog walkers to relieve pressure on the harbour. As per paragraph 4.12 "these could be created by a developer as part of a very large housing scheme [such as is proposed for Southbourne] or alternatively will be implemented through the Solent Recreation Mitigation Partnership."

The Background Paper does not present any, let alone the full picture of the area's ecological importance. The Ham Brook follows a natural environmental feature from the AONB to the SDNP. This natural water course is home to water voles (seen by CDC Wildlife Officer and local environmental volunteer as recently as January 2019) and the land north of Priors Leaze Lane is a Barn Owl Habitat (as referenced in Chidham and Hambrook Parish's made Neighbourhood Plan). There is ancient woodland either side of the railway line next to the trout farm and this is a dormouse habitat too.

In conclusion, S30 is an excellent policy but it MUST be strengthened by the reinstatement of the Ham Brook Wildlife Corridor. Doing so would not compromise any development objectives of the Local Plan. Indeed, doing so would advance several objectives and policies within it.

S23 and AL6

Object
To the proposed Birdham Road to the A27 Fishbourne Roundabout.
With so much new development - and traffic - proposed for settlements along the A259, our road is going to be the focus of a huge amount of new congestion, with all of the associated negative impacts on air quality and sustainable transport goals. Feeding more traffic into the Fishbourne roundabout will only make it harder for drivers from the A259 to get onto / across the A27.
In addition, the proposed link road goes straight through a flood plain and site of great environmental importance - one which links the coast to the city of Chichester. Furthermore, the proposed link road would have a significant negative impact upon views from the coast to the city and the SDNP and from the city and SDNP to the coast and Manhood Peninsula. It would also negatively affect the setting of the proposed Fishbourne Wildlife Corridor.
We support creation of an integrated and sustainable transport plan for the District, or at the very least for the area west of Chichester. This plan should draw upon the ongoing work of the ChEmRoute group's investigations and proposals for the National Cycle Route 2 (NCN2) and be coordinated with WSCC with the goal of introducing high quality and separated cycle links between the villages along the A259 and Chichester. The route or routes may include a fast but safe link along the A259 aimed primarily at experienced cyclists and commuters as well as a slower, more meandering and leisurely route north of the A259 (and perhaps the railway). To make these cycle routes sustainable they will need connections and feeder routes from new and existing developments.
In developing a more ambitious and safer scheme for cyclists care must also be taken to ensure that pedestrian routes are protected too. The vision must be to ensure that both cycle and pedestrian traffic is encouraged and supported and not brought into competition with each other.

Spatial Strategy, Transport Infrastructure , Page 78 s5.27
In addition, the County Council is expected to continue to support new development through a package of transport improvements which will continue to aim to reduce congestion and encourage people to use sustainable modes of travel such as walking, cycling and public transport.
This supports Southbourne's desire for a pedestrian bridge over the railway line as that will encourage people to walk rather than drive, as well as supporting a road over the railway line as this will also reduce the walking time for many residents wherever the road is placed. It may avoid current routes which involve walking through fields and over unmanned rail crossings. A road would be safer and more useful to pedestrians. The requirement for bridge should be included in policy S23.
DM34
Object due to issues in the supporting evidence.
Chichester Infrastructure Delivery Plan, Southbourne Parish - Local Plan Review Policy SA13 page 90 section 15.4
In the title, play space (children) is given, when the project is actually children and youth combined.
The heading needs to be amended to Play Space (Children and youth)
Chichester Open Space, Sport Facilities, Recreation Study and Playing Pitch Strategy: Open Space Study Sub Area Analysis (Part 2 of 2) Page 13 table 4
This table says there is good provision for childrens play space, when section 2.3 table 3 shows there to be a shortfall throughout the district.
Object due to issues in the supporting evidence.
Chichester Infrastructure Delivery Plan, Southbourne Parish - Local Plan Review Policy SA13 page 90 section 15.4
In the title, play space (children) is given, when the project is actually children and youth combined.
The heading needs to be amended to Play Space (Children and youth)
Chichester Open Space, Sport Facilities, Recreation Study and Playing Pitch Strategy: Open Space Study Sub Area Analysis (Part 2 of 2) Page 13 table 4
This table says there is good provision for childrens play space, when section 2.3 table 3 shows there to be a shortfall throughout the district.
Water Quality Assessment
Housing allocation: The Thornham evaluations have been based on a housing increase in the Thornham catchment area, over the period covered by the report (2020-35), of 1,000-1,500 dwellings. In view of the fact that the Havant-Emsworth plan also has many hundreds of new builds planned in this catchment area, this estimate would seem to be grossly under-estimated ref. Page 25, Table 26. Page 15: "Westbourne" should be added to Table 1.1. Page 60 para. 3.10.2 claims to include Havant but Havant is excluded in other parts of the report e.g. Table 1.1.
Climate change: it is disappointing that any effects of climate change have been specifically excluded (page 28).
Assessment of Headroom: in assessing headroom, AMEC's report states that the Environment Agency guidelines, specify 150 litres/person/day and five people per dwelling. The report has used different figures i.e. 120 litres/person/day and 21/2 people/dwelling. Their justification for this (para. 3.2.12) is that Southern Water prefer these figures. The effect is to reduce the Thornham WwTW's current headroom from 1,063 dwellings down to 400. Any calculations must be formally agreed with the Environment Agency. Page 29 para 3.2.4 suggests that this has yet to be agreed. There is considerably inconsistence in the quotation of dry weather flow (DWF) and Headroom. Page 60 para. 3.10 indicates that consented DWF (hence Headroom) is already in excess of consent (consented DWF 6,565 m3/day, current DWF is 6,580 m3/day). Statement of headroom, without dates, or methodology are meaningless.
Discharges: some assessments are omitted on WwTW, which discharge directly into estuary/coastal waters and Thornham WwTW has been put into this category (table 2.2). In practice, Thornham discharges onto Eames Farm from where it flows through Little Deep, into Great Deep before discharging into the shellfish beds (already classified as "unfavourable") at Prinsted (Chichester Harbour) as in Page 61 para. 3.10.13. Page 21, Table 2.3 is incorrect. In its objectives (page 10), the report indicates that it should be considering any impact on shellfish. No impact on these shellfish beds seems to have been assessed.
Storm discharges and shellfish: the report (Page 61 para. 3.10.9) states that storm discharges have been a significant problem for the Thornham WwTW. However, it specifically excludes any consideration of storm discharges over this period (2020-2035). It does not assess the effect of large quantities of primary-treated sewage (filtered only) on the Eames Farm marshland or the Prinsted shellfish beds (Page 23 para. 2.2.12, Page 25 para. 2.2.19). The AMEC report seems to suggest that the discharges processed through Thornham WwTW will have a minimal affect. This observation does not take into account, the very large levels of (Grade 1) untreated storm discharge.
Data: There are significant areas, where Thornham WwTW's data has not been provided and National Average data used instead.
Objectives not met: Page 9 Objective "investigate demonstrably deliverable ways of dealing with Wastewater treatment capacity". The MWH Report (2010) page 17 clearly indicates that expansion of Thornham WwTW was not viable. No comment or way of dealing with capacity limitation has been investigated.
Clear statements of exactly what additional works and what realistic dates are required.
5.69-5.72 , Section 9.1 of the Surface Water and Foul Drainage SPD and its referenced Headroom Tables are out of date, need to be updated, and its guidance amplified, to cover the timescale of the Local Plan Review 2019 to 2035 and the impact of future housing development.
Reasoning
Headroom Table 2 of the Water Quality Assessment Report states that as at 31st October 2018 the Estimated remaining headroom (households) was 1,020. This is well below the combined Southbourne and neighbouring West Sussex parishes Local Plan Review planned housing development numbers without even taking into account that Thornham WwTW also serves the Emsworth area in Hampshire which is is the subject of increased and significant additional housing development.
This issue is of particular importance given the large scale development proposed for the Southbourne Parish under the Local Plan Review, that this SPD is "a material consideration when assessing planning applications or appeals for any new dwelling(s)" and that the Local Plan Review itself states that "measures will need to be put in place at each WwTW and their associated catchments and sewer networks in order to tackle current and future water quality issues to support future housing growth." These measures include "Upgrades to physical capacity and Upgrades to sewer networks".

5.72, Policy S31 states that "Proposals for development within the Plan area should be able to demonstrate no adverse impact upon the quality of receiving waters" It is proposed that this statement should be amended to be clearer and more appropriate to local circumstances, as follows: "Proposals for development within the Plan area must be able to demonstrate no adverse impact upon the quality of receiving waters including with regard to the capacity and condition of existing wastewater and sewage systems, local storm discharge risk and the capacity of the Wastewater Treatment Works. The Council as planning authority will look to satisfy itself on these matters including to ensure sufficient capacity within the relevant Wastewater Treatment Works before the delivery of development as required."
Reasoning
The referenced Surface Water and Foul Drainage SPD is out of date and insufficiently clear and rigorous in its guidance and requirements. The SPD needs strengthened with regard to new development requirements and potential adverse impacts on Chichester Harbour AONB, on the small watercourses feeding into the Harbour waters, given known local problems with the sewer network (as referenced in Para. 2.4) e.g. at Nutbourne, and as Para. 2.3 of the Surface Water and Foul Drainage SPD states "The condition of the water environment is not currently good enough to meet the required standards (of the European Water Framework Directive). Policy AL13 for Southbourne Parish also states that "Development will be expected to address the following requirements (including), !6. Ensure sufficient capacity within the relevant Wastewater Treatment Works (i.e. Thornham) before the delivery of development as required".

Characteristics of the Plan

Proposed Supplementary Planning Guidance
Object
Objection is raised to the use of the term East-West Corridor with regard to west of the City of Chichester. The use of the term corridor implies the focus of policy is on transport and through movement to the detriment of a more balanced focus on local settlement, existing residential, local countryside and amenity issues.

There is a lack of vision, clarity and coherence of planning policy towards the Bourne Villages, their character and the surrounding countryside that lies between the South Downs National Park and Chichester Harbour AONB. The current piecemeal policies approach that focuses on the individual settlements and individual thematic policies is detrimental to the coherence and effectiveness of planning policy, the character of these settlements and their surroundings and to the South Downs National Park and Chichester Harbour AONB.
The Preferred Approach fails to take account of the potential impact arising as a result of the scale of proposed allocations. The adopted Chichester Local Plan Key Policies 2014 - 2029 document allocated a total of 620 additional houses: Westbourne 45, Southbourne/Nutbourne 350, Chidham & Hambrook 35, Bosham 70 and Fishbourne 70. The Review Document proposes additional housing allocations (minimum) at Southbourne 1250 houses, Chidham & Hambrook 500, Fishbourne 250, Broadbridge/Bosham 250 - a total of 2,250 additional houses, an increase of + 246% over previous allocations and with these villages taking a 46% share of proposed additional allocations in the Local Plan Review area.
The absence of a Countryside Settlement Gaps Policy at Local Plan Review stage is regretted and one is only verbally promised for June 2019. The lack of a coherent vision for the Bourne Villages is at odds with the approach taken to other Chichester areas and their communities which is reflected in a statement made by Cllr Tony Dignum (Leader of CDC) on 18 October 2018 in the Chichester Observer: "there is no doubt that we live and work in one of the most beautiful areas of the country and we want to keep it that way. We aim to deliver improvements within our city and towns so that our area continues to be one of the best places to live, work, and visit in the UK. These improvements are being expressed through 'vision' projects for the city and for each of our towns" (Selsey, Midhurst and Petworth are cited as examples).
There is at least an equally strong case for there to be a vision for the Bourne Villages, the band of settlements, countryside and amenity land that lies between Emsworth and Chichester, the South Downs National Park and Chichester Harbour AONB. Not to have a coherent vision for this area is detrimental to the Bourne villages and to the neighbouring areas. Much of the character of these settlements, especially Southbourne, derives from the wider area within which they are situated.
1 Chichester District Council should prepare Supplementary Planning Guidance on a vision for the Bourne Villages, comprising Westbourne, Lumley, Hermitage, Prinsted, Southbourne, Nutbourne, Chidham, Hambrook, Bosham and Fishbourne, the surrounding countryside and their relationship with neighbouring Emsworth/Havant, the City of Chichester, the South Downs National Park and Chichester Harbour AONB.
2 The use of the term East-West Corridor with regard to west of the City of Chichester be restricted and only be used for transport issues and the A27 itself, and not be applied to the Bourne Villages and their surroundings..
The above comments/representations also relate to the following Plan references:
i) Page/para nos: page 22 §2.29
Policy reference: Character of the Plan Area.

ii) Page/para nos: p24 - 25; §3.3 - §3.10
Policy reference: Spatial Vision & Strategic Objectives: East-West Corridor
iii) Page/para p35
Policy reference: Spatial Strategy - Policy S3: Development Strategy
iv) Page/para nos: p82 - 84; §5.34 - §5.42 & §5.44
Policy reference: Strategic Policies - Countryside S24: Coast S25
v) Page/para nos: p 92; §6.4 - §6.6
Policy reference: Strategic Development - S32

We object to the lack of comprehensive guidance for the east-west corridor. This should be provided by a new Local Plan Policy & subsequent Supplementary Planning Guidance (SPG).

The development strategy seeks "to focus the majority of planned sustainable growth at Chichester and within the east-west corridor"(S3).

The description "corridor" implies that it is little more than ribbon development along a transport route and a better term could be found. In reality, the Bourne villages are vibrant communities with quite different individual characters.

We have calculated that some 40% of the new housing proposals (S4 : total 5595 dwellings) are being allocated to this area (2250 dwellings). While Neighbourhood Plans will probably be reviewed to allocate particular housing sites there will be attendant problems that will be difficult for Neighbourhood Plans to deal with individually. These include:-

1 Traffic on the A259. It appears that despite the quantity of new development being put forward, there has been no analysis of the impact locally. There are no proposals to manage the additional traffic on the A259. For example, there is scope for a co-ordinated approach to keep speeds down, provide village gateways and more pedestrian crossings. Cycle lanes are sporadic;

2 Waste Water Treatment There has been concern for a number of years about whether there is adequate capacity both at the Thornham Works and in the pipe network. There have been occasions when sewers have surcharged. Storm water discharges of sewage, which has only had primary treatment, into Chichester Harbour have been increasing. This issue needs to be addressed for the Bournes area as a whole;

3 Coalescence No doubt Neighbourhood Plans (NPs) will address this but it would have been helpful to have had the results of the District Council's "Countryside Gaps" study and Local Plan Policy to help maintain appropriate Gaps. It is hoped that the NP reviews will be able to inform this Study. Gaps will be under considerable pressure from developers, therefore in the meantime we suggest that Neighbourhood Plans should contain policies relating to land outside Settlement Boundaries (ie Countryside Gaps as defined locally) to ensure their proper protection. Local Plan Policy need not await the next review but could be embodied in SPG which could be issued earlier;

4 Green Space The provision of wildlife corridors should be consistent throughout the east -west area and SPG would underpin this. Furthermore, a substantial amount of green space in Southbourne is envisaged in the current Southbourne Parish Neighbourhood plan (SPNP). through the proposed Green Ring. Currently it includes a proposed road and pedestrian route over the railway on the west side of the village and a proposed pedestrian footbridge over the railway on the east side. Parts of it may be secured via new development and it should also attract independent funding. The Green Ring is intended to alleviate the problems of disturbance to birds in the Harbour caused by visitors, especially some of those with dogs, and provide a local alternative multi-purpose recreational route. The development of 1250 dwellings is likely to generate significant additional pressure on the Harbour and an increase in the need for public green space generally, which is already underprovided in the Parish. The Green Ring could fall within the definition of a SANG (Suitable Alternative Natural Greenspace) and provide an opportunity for some funds already collected from local developers for the Solent Mitigation Strategy to be spent in Southbourne to alleviate the problems arising directly from new development here. A comprehensive green space policy for the Bournes area could reinforce the importance of this proposal and help secure funding.

A new road bridge over the railway line in Southbourne is required if 1250 new dwellings are to be accommodated satisfactorily. The provision of infrastructure at the right time is essential. Sufficient land for 1250 dwellings is unlikely to be found anywhere other than north of the railway line and this would make existing congestion at the Stein Road level crossing considerably worse. The construction of 1250 dwellings at a completion rate of some 80 dwellings a year would lead to continual building for the next 16 years. The associated construction traffic would make the situation even worse. In these circumstances the northbound queues could back-up onto the A259. A separate footbridge on the east side of the village is also required as is the closure of existing at-level and uncontrolled pedestrian routes across the railway line.

Policy AL 13 (4) only proposes "Opportunities as they arise to improve the situation relating to the various existing or planned railway crossings". This is too weak. The policy should require the provision of these new rail crossings to support the proposals set out in the current Neighbourhood Plan.

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.

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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.

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