Policy DM18: Flood Risk and Water Management

This policy encourages rather than discourages development in flood prone areas,

Amazed to see 'Appropriate flood warning and evacuation plans may be required to ensure that any additional risks etc ...Who would contemplate acquiring property or locating a business in such a risk area?

The Flood risk Assessment document has only considered the effect of climate change on rainfall and fluvial discharge. An assessment of the implications of sea level rise on coastal communities and the level on development along the coastal inlets and the Manhood Peninsular should be made

Remove AL6. It is Flood plain risk 3 and should not have been included.Other less flood risk sites to the north have been removed because of their flood plain 2 status. Hypocrisy ! Unless this is adequately addressed in future iterations of the plan. I will be raising it with the examiner at the appropriate time.

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.

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.

REP1: OBJECTION TO CRITERION 5 OF AL7 - INCONSISTENT POLICY WORDING

Bosham Parish Council is of the view that there is an inconsistency between the policies and their supporting text concerning the treatment of the landscape surrounding Fishbourne and that surrounding Bosham, particularly that part of the village north of the A259. Consequently the policy wording is not effective and will not deliver the most appropriate strategy for the site.

Policy AL10 allocates land at Chidham and Hambrook for 500 dwellings. Policy AL9 allocates land at Fishbourne for 250 dwellings. Criterion 5 of each of these policies considers issues of landscape impact when it states:

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

It is logical to include the same criterion 5 in each of these policies since both settlements are close to the South Downs National Park and the AONB. Bosham happens to occupy a location between Fishbourne and Chidham/Hambrook settlements. Bosham is similarly set between the South Downs National Park and the AONB. It is therefore somewhat surprising that criterion 5 of Policy AL7 relating to Bosham states:

"Provision of landscaping and screening to minimise the impact of development on
Bosham, and the setting of the Chichester Harbour AONB and South Downs National
Park, including views to and from the wider and surrounding area;"

The Parish Council's concern is that the wording of this criterion implies less stringent assessment and appraisal of the landscape setting related to the AL7 allocation than is the case with Policy AL9 and AL10. The criterion merely states "provision of." This is despite Bosham having an arguably more sensitive relationship to the Chichester Harbour area. The consequence of this, is that there is no policy requirement for a "detailed consideration of the impact of development on the surrounding landscape." This means that landscape proposals could be devised which merely introduce buffer planting without actually assessing what depth of planting should take place and the type of plants which are suitable. The criterion 5 wording of AL7 also does not include any requirement for proposals to be "designed to protect long-distance views to the South Downs National Park." This implies that the landscaping and design associated with the Highgrove site (AL7) will be judged against a lower threshold than with the AL9 and AL10 housing allocations. The policy is therefore not effective and neither would it deliver an appropriate design strategy for the site

It is proposed that to ensure that the plan is consistent, sound and recognises the same sensitivity as a result of the proximity of the Chichester Harbour AONB, criterion 5 be amended to state:

"Detailed consideration of the impact of development on the surrounding landscape,
including the South Downs National Park and Chichester Harbour AONB and their
settings. Development should be designed to protect long-distance views to the South
Downs National Park and Chichester Harbour. Provision of landscaping and screening to minimise the impact of development on Bosham, and the setting of the Chichester Harbour AONB and South Downs National Park, including views to and from the wider and surrounding area shall form an integral part of any application;


REP2: OBJECTION TO PARAGRAPH 6.56

This paragraph is preamble to Policy AL7 and sets out the specific issues that need to be taken into consideration when planning the development of the allocated site. In paragraph 6.65 the preamble states that:

"Protecting the separate distinct identity of Fishbourne in relationship to surrounding settlements, including Chichester City;"

This is logical since the development of 250 homes on land around this settlement could result in a design which is out of keeping with the wider character of the area. In addition, Fishbourne is close to Bosham and consideration of design needs to recognise and plan for that proximity.

In the case of Bosham, no issue relating to 'distinct identity' is raised in the supporting text. This is considered to be unsound because the settlement of Bosham has a particular distinct identity and the Highgrove allocation is on the eastern side of the village and would draw development closer to Fishbourne. It cannot be the case that Fishbourne has supporting text which seeks to protect its special identity but Bosham, with a large allocation does not. This would not deliver an effective plan due to the inconsistency and neither would it deliver an appropriate growth strategy for Bosham.

The settlement or village of Bosham is comprised of two built up areas. A neighbourhood called Broadbridge to the north of the A259 and an area located around the historic harbour. Whilst physically separate, they each form part of 'the village' and are interrelated in terms of activity and service offer. The allocation of 250 new homes at Highgrove is a significant number when compared to the existing number of dwellings in Bosham. Consequently, it is important that the identity of Bosham is carefully considered when designs are drawn up. The NPPF continues to advise that design should be of a high quality and certainly this is an important issue when setting the policy context for AL7.

It is recommended that a new bullet point be added to paragraph 5.56 which states:

" Protecting the separate distinct identity of Bosham in relationship to surrounding settlements, including Fishbourne;"


REP3: OBJECTION TO CRITERION 3 OF AL7

Policies AL9 and AL10 both include criterion 3 which state:

"Provision of suitable means of access to the site(s) and securing necessary off-site
Improvements (including highways) to promote sustainable transport options;"

However, criterion 3 of AL7 states:

"Provision of a satisfactory means of access from the A259;"

Bosham is a village with two centres severed by the A259. For reasons of social cohesion and to ensure that the new development has satisfactory pedestrian links with the facilities to the south of the A259, including the small employment areas and community facilities, it is essential that some form of pedestrian crossing and other pedestrian infrastructure is installed to support the new development. At the moment the strategy being promoted by the Council cuts against social cohesion and is clearly an inappropriate strategy compared with the alternative which is to require a crossing. Criterion 3 should therefore be more appropriately worded to allow these issues to be delivered. It is recommended that criterion 3 should be redrafted to state:

Provision of primary access from the A259, consideration of an emergency access and pedestrian access to the western side of the site and securing necessary off-site improvements (including highways) to promote sustainable transport options. This would include an appropriately located pedestrian crossing and a footpath link;


REP4: OBJECTION TO POLICY AL7

Bosham Parish Council is concerned that the policy fails to give appropriate guidance on matters of environmental importance and this is contrary to the NPPF. In both policy AL9 and AL10, a criterion states:

"Demonstration that development would not have an adverse impact on the nature conservation interest of identified sites and habitats;"

However, in the case of the Highgrove allocation AL7 environmental assessments have already taken place in connection with application 17/03148/FUL and the site allocations document which allocates a smaller part of Highgrove Farm for 50 dwelling units. This research has identified a population of slow worms on the site. It is also the case that Brent Geese, a species protected under Law, have used the open fields for landing. Given that there is ecology of acknowledged importance, it is considered that to be compliant with NPPF a criterion should be added which protects the habitat and ecology of the area. This would comply with NPPF and be consistent with the way other sites have been treated. The new criterion should state:

"Demonstration that development would not have an adverse impact on the nature conservation interest of identified sites and habitats;"


REP5: OBJECTION TO POLICY AL7

Policy AL9 and AL10 include a criterion which states:

"Provide mitigation to ensure the protection of the SPA, SAC and Ramsar site at Chichester Harbour as a result of water quality issues relating to runoff into a designated site, and loss of functionally linked supporting habitat;"

Policy AL7 does not include this criterion yet the allocation is as close to the protected Harbour and water courses that flow into it as the sites promoted at AL9 and AL10. In the case of Highgrove Farm there is a drainage ditch running along the southwest corner which would need effective management to ensure hydro carbon pollutants do not enter the catchment. It is therefore inconsistent and contrary to NPPF that AL7 does not have the same criterion. A new criterion should be included which states:

"Provide mitigation to ensure the protection of the SPA, SAC and Ramsar site at Chichester Harbour as a result of water quality issues relating to runoff into a designated site, and loss of functionally linked supporting habitat;"


REP6: OBJECTION TO POLICY AL7

A consultation exercise carried out by Bosham Parish Council in December 2018 revealed widespread local concern, and photographic evidence, concerning the ability of the site to drain safely and effectively. The drainage ditch to the southwest corner regularly floods as a result of it being of insufficient capacity and poor management. There is no robust or credible evidence to suggest that this issue should not be specifically identified as a criterion in Policy AL7.

The approved development of 50 houses at Highgrove (17/03148/FUL) has a significant area within the development site which is required for storm surface water balancing ponds/SuDS /underground storm water crates within the open space area. These areas occupied some 0.5ha of the 2.2ha allocated. For a 250 house scheme the requirements would be significantly higher. Any area required for drainage should sit outside of that required for open space, ecological mitigation and other community infrastructure.

It is therefore considered that some on site Suds or attenuation pond will be necessary as part of the scheme. The area necessary would need to be established through studies and would need to be independent of the overall open space requirement of the site. AL7 should link to Policy DM18 and the requirements contained in that policy.

Criterion 11 of AL9 also makes reference to securing sufficient capacity within the relevant Waste Water Treatment Works. Paragraph 5.70 states that during the life of the Plan "measures will need to be put in place at each WwTW... in order to tackle current and future water quality issues to support future housing growth." Clearly some form of criterion is essential to ensure that commencement of the development cannot occur until such works are completed. The recently completed Hospice to the south of the draft allocation within the AONB required additional foul sewer capacity upgrades in order to be occupied. In view of this evidence and the approach taken with Policy AL9, Policy AL7 should include a criterion requiring offsite infrastructure improvements to address foul sewage.


REP7: OBJECTION TO POLICY DM18 FLOOD RISK AND WATER MANAGEMENT

In view of Bosham Parish Council's representations relating to surface water flooding at AL7, it is considered that this policy should include an additional criterion making it clear that development proposals will need to outline a robust strategy for addressing surface water drainage and flood risk.


REP 8 - OBJECTION TO POLICY S31 AND APPENDIX E RELATING TO WASTEWATER MONITORING

As a result of Bosham Parish Council's representations to AL7, it is considered that S31 should be amended to include an additional criterion which makes it clear that planning permission will only be granted where enhancements to necessary foul water infrastructure occur prior to the commencement of development. On site schemes which discharge into nearby water courses should not be deemed acceptable, particularly those within proximity of the Chichester Harbour AONB. Appendix E should include a requirement that the District Council discusses Southern Water's current 5 year investment programme and only allow commencement of development when suitable infrastructure enhancements have taken place.



REP9 - OBJECTION TO POLICY DM34 - OPEN SPACE

The revised Open Space, Sport and Recreation Study including Indoor Sports Facilities and Playing Pitch 2018 has reduced the requirement for open space by almost a third across the whole district. There is no evidence and justification for this reduction. The District wide reduction in open space requirements may penalise those Parishes where an existing shortfall exists. It is not an appropriate strategy compared with the previous standards for open space. It is not based on any credible evidence to justify a change.

The information in Table 14 of the Chichester open Space Study (Main Report) September 2018 shows that Bosham has the third highest shortfall in the parishes in the District of Parks and Recreation Grounds combined. The extract of the table below shows that in every category Bosham has a significant deficiency.



It is considered that the new standards should not form the basis for the open space requirements at Highgrove Farm and that the previous standards should be retained to address the unique circumstances of Bosham.


REP 10 - OBJECTION TO LANDSCAPE CAPACITY POLICY DM28 NATURAL ENVIRONMENT AND DM19 CHAONB

The draft Landscape Capacity Study (published by Terra Firma, November 2018) concludes that The AL7 draft site allocation has only medium/ low capacity for landscape change and states "Great care would need to be taken to avoid any landscape or visual harm ensuring the separate identities of the settlements are protected and considering valued views".

At the present time the Landscape Capacity Study is in draft form only and its conclusions are currently based on a summer assessment. It would be the case that the same assessment during the winter months would yield a greater degree of landscape sensitivity. The evidence base, as currently published, is not robust and the AL7 policy wording "development of a minimum of 250 dwellings..." is not based on robust and credible evidence. The landscape sensitivity suggests that the 250 dwelling number should be a maximum cap and that the policy should be re-worded to say "up to 250 dwellings..."


REP 11 - OBJECTION TO AL7 - DENSITY AND NUMER

Bosham Parish Council has concerns regarding the policy wording which sets a minimum threshold for the number of dwellings "minimum of 250 dwellings".
Concern about the numbers of dwelling and density proposed taking account of the issues raised namely the need for onsite SUDS and drainage, a 2 form entry school, suitable landscaping and mitigation, and suitable ecological mitigation. Any development must also have regard to the character of the area and a density which reflects that of the surrounding area. There is no credible evidence to suggest that more than 250 dwellings can be achieved when all these considerations are taken into account. It is noted that Draft Policy DM3 explains at criterion 'b' that locations adjacent to sensitive locations may justify lower densities.

The policy should be reworded to ensure the 250 dwelling amount is an upper threshold.

OTHER

We support the 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 co-ordinated 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 cyclists including 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.

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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