Policy DM24: Air Quality

The Policy is more of the same that Chi has had to put up with for the last 10 years ie all words and totally lacking teeth in terms of real action and challenge back to Central Government. CDC performing their statutory duties in gathering data. Even Highways England had concerns during the RIS1 period on the impact to AQMAs during construction of all routes except options 4 and 5. Public Health should trump the housing levels being forced on Chi District. Cap housing levels to meet genuine local needs until such times as the DfT fund a long term solution to the A27. CDC AQ Action Plan states a dependency on this so lets put the health of citizens in the forefront. I wish to raise this with the Examiner as I have zero confidence in the robustness of CDC's AQ Action Plan.

The Peter Brett Associates (PBA) report states in the Executive Summary: Air Quality (page xvii) that ..."Within existing AQMAs, with the Local Plan traffic in place, there are no predicted exceedances of NAQOs."

In Appendix G: Air Quality Assessment of the same report, Tables 4.1 and 4.6 show that the levels of NO2 at Stockbridge have consistently exceeded maximum levels since 2012.

On page xvi of the Executive Summary, Table 1 shows that Stockbridge ranks 5th in priority of construction.

Therefore, it will be many years before any expected improvement in Air Quality at Stockbridge.

This is completely unacceptable.

Para 4: Where development is likely to have a significant negative impact on an AQMA...etc

I have some comments on the Chichester Local Plan I wish to submit:

1) S28 and DM24 Pollution
This policy as it is not detailed enough. I would like to see more monitoring and more measures to be included in this policy to ensure actions are taken. These should include Clean Air Zones introduced, cleaner buses, car free day, workplace parking levy, anti-idling zones, increased pedestrianised areas in our villages and towns, better joined up cycle network

2) Policy AL6 - Land South-West of Chichester
I am opposed to the Stockbridge Relief Road and the allocation of houses to Apuldram and Donnington as it is too close to the AONB, on a floodplain and destroys prime agricultural land.

3) DM 16 Sustainable Design and Construction
The plan should acknowledge the need for the area to become carbon neutral in order to prevent climate change.
Manchester has committed that all new buildings will be net-zero carbon. This should be included in the Chichester Plan.

4) DM17 Stand-alone Renewable Energy
The plan should put aside space for renewable energy as a priority. We need space for wind turbines, battery storage and more solar panels on the roofs. Provision may be required on the coast for enabling the connection of an off-shore wind farm.

5) SA5 Southern Gateway
This policy needs to deliver better plans for people walking and cycling.
The green space should be preserved and an additional pocket park added to the area

The city needs a welcoming bus and train station, a proper public transport hub with toilets, tourist information, waiting area in the dry, warm and shade and proper information with RTPI screens (not just bus stops). The current bus and stations are hideous and unwelcoming and are not in keeping with the rest of the city.

6) S23 Transport and Accessibility
A coordinated package of improvements to junctions within the city is missing from this policy.

The roundabouts on Westhampnett Road near Sainsbury's, New Park Road near the new Coop, Eastgate, Northgate, Westgate and Southgate need redesigning to allocate more space to people on bikes and on foot.

More bus lanes and a linked up and continuous network of proper, protected cycle lanes need to be introduced.

St Paul's Road and Bognor Road need to have less private car parking to enable sustainable means to be prioritised - bus and bike lanes.

Transport measures need to ensure that we reduce our carbon footprint as emissions in this sector are still on the rise.

7) Policy S5 - Parish Housing Requirements
A Second home policy should be introduced to prevent an over dominance of new homes being sold to non-residents.

8) Policy S30
Wildlife Corridors need support but the wording needs to be made stronger so that development within this corridor is not permitted. The plan needs a stronger commitment to the preservation of wildlife within the area, in its current form it is lacking.

All proposals should demonstrate that they will have a net zero impact on climate change in line with the government's commitment in 2008 Climate Change Act as a signatory to COP21 Paris Agreement and the IPCC's report published in the autumn of 2018.

I am a resident of Donnington and am disappointed with the ridiculous scheme which you are proposing. In addition, I have not the slightest confidence that the scheme will be completed within budget and on time. The footbridge at the Stockbridge roundabout was a fiasco and if you cannot complete such a relatively small project, I am not convinced any of you are capable of taking on a much larger scheme.

I agree with all of our parish council recommendations and comments below.

DONNINGTON PARISH COUNCIL OBJECTIONS
Donnington residents will be hugely disadvantaged by proposed changes to A27 access arrangements under Policy S23 and the Peter Brett Associates report - effectively no access to the East from Donnington (or the Manhood Peninsula) via A27 unless residents either head West first, encountering the amended Fishbourne Roundabout which will prioritise through traffic and will include an additional junction. Alternative routes to the East are either through the City or via unsuitable "back roads", increasing traffic levels through Hunston and North Mundham. Increased traffic from Whyke (facing the same issue) will cause even more congestion between Donnington and Fishbourne.
* Site AL6 Land South West of Chichester (Apuldram and Donnington parishes) includes a flood plain. Using data from CDC's flood plain assessment, the average height of flood water on the River Lavant is 2.05 metres (6.07 feet) above datum (sea level). This means that the road will have to be elevated by at least 2.5 metres and more with the supporting structures and road thickness itself. Therefore nearer 4 metres (13 feet). This would destroy the iconic views of the cathedral framed by the South Downs. The protection proposed by para 3 of Policy AL6 is unachievable. REMOVE POLICY AL6
* Each of the five junction modifications will require three years of work. This means 15 years of misery for Chichester residents whilst the junction works take place. We all remember the chaos caused by the replacement of one footbridge in Stockbridge, bringing gridlock to the area. (Policy S23 and Peter Brett Associates Transport Assessment)
* Overall, the plans for improvements to the junctions are to the advantage of through traffic not local residents. The proposals bear a marked similarity to Option 3a from the Highways England Improvements to the Chichester A27 Bypass consultation, which were emphatically rejected by the local community - in Donnington and across the whole of Chichester. (Policy SP23 and Peter Brett Transport Assessment)
* Air Quality will further deteriorate as a result of the proposed plans. Stockbridge already exceeds the recommended air quality levels and development on this scale will increase the problem. This has serious health implications for residents. (Policy DM24 & SP28)
* The South Downs National Park should take its allocation of 41 dwellings per annum - without some low level development in the Park, particularly social housing, communities there will not thrive. (Policy S3, Policy S5 & Policy S19 )
* There are no proposals for any new primary schools in the Manhood Peninsula. This will only increase pressure on current schools to provide more places, and lead to increased traffic on the roads as parents are forced to commute to schools outside their local area where spaces may be available.
* Impact on ecology - the Chichester Harbour and surrounding area are designated as an Area of Outstanding Natural Beauty and have the status of being a Special Protection Area, Special Area of Conservation, Site of Special Scientific Interest and is a Ramsar site. It is wholly inappropriate to consider development on this scale in such close proximity to an area with this status. There will be a significantly adverse impact on the ecology of the area and mitigation is not sufficient. (Policy S18 Integrated Coastal Management Zone Manhood)
* Green tourism is a very important part of the Manhood Peninsula economy and to overdevelop and spoil the natural environment which attracts this trade would be inappropriate and hugely detrimental (Policy S18 Integrated Coastal Management Zone Manhood)
* A viable alternative site is available for industrial development within the buffer zone at Goodwood and the employment land should be allocated there. (Policy AL6, S15, S16)

The policy is not nearly forceful enough. It allows for developments to assess air quality, to put in mitigation measures, but still permits them. They should not be allowed until after improvement in air quality has taken place.

Policy DM24 Air Quality + S28 Pollution + Statement in Para 1.2.1 do not appear to be an integrated or coherent approach. The statement on using the IP model , with the AM and PM peak hour models , would have the effect of flattening the spikes that occur in AQMAs in peak times where the NO2 & fine particulates, will be at their highest pollution levels. Recent medical evidence has reported that being exposed to the spikes are when the public, and particularly children, are at greatest risk.

Resident of West Wittering
Air Quality has not been addressed in the past. Even though the planned developments on the Manhood Peninsula have already been met, that is in the first five years of the adopted Local Plan, as yet none of the required mitigation has been put in place and the is no scheduled plan to do so. Jacobs 2013.

The policy must take into account medical research which has demonstrated that particulate pollution from cars (petrol hybrid and electric) has profound deleterious effect on health which is directly related to the distance from the road. this particularly effects the very young and the elderly, increasing rates of respiratory disease and dementia. This policy should ensure that housing is not buit adjacent to the A 27

AL6 is already part of the Stockbridge Air Quality Management Area and would be a pollution triangle surrounded by the A27, A286 and the proposed SLR, not to mention the changes to the Fishbourne and Stockbridge junctions at either end. Any dwellings are going to be surrounded on all sites with associated health risks and rather than mitigating will cause significant damage.

Air Quality Management Areas have been identified in three locations, however I am surprised this is not expanded further to include most of the A27 roundabout junctions. The stationary traffic build-up from emsworth to Fishbourne roundabout every weekday of a few miles must have a significant local air pollution impact and local evidence of pollution impact on soot and particulates eg from NO2 suggests further impact assessments are warranted. I would request a more thorough and regular air pollution monitoring approach is adopted.

"Children are especially vulnerable (to air pollution) because they are growing rapidly. It seems clear that pollution particularly affects the development of organs. Whether it is the brain or the lungs" Professor Chris Griffiths, Centre for Primary Care and Public Health. https://www.bbc.co.uk/news/av/science-environment-46876997/clean-air-do-low-emission-schemes-improve-children-s-lungs

Editorial published in The Medical Journal (December 2018) evidenced that primary aged children exposed to vehicle emissions are slower in their development. It also stated that older people are at a 40% higher risk of dementia caused by vehicle emissions. Indisputable facts. The editorial called for bold action by Government and Local Authorities.

Simon Ballard, CDC Senior Environmental Protection Officer has attributed 4.1% of Chichester's deaths are due to PM2.5, just one pollutant of the many pollutants from vehicle emissions. CDC Environmental Officers have had an automatic air quality device recently installed in Westhampnett Road and the funding to get data has been approved. Potentially two new AQMAs will be put in place and not before time, when you consult Sussex-air's map of pollution in and around Chichester.

Chichester already has 3 AQMAs, the most of any area in West Sussex. To add to this is alarming data is the un arguable fact that the majority of our children and grandchildren's schools are situated close to these AQMAs and, on the walking routes, resulting in them breathing these pollutants. The extensive use of sat nav is causing traffic to find routes avoiding the gridlock on the A27, resulting in the ever-increasing risk to pollution in the City and surrounding area.

As discussed in my response to Transport and Infrastructure Peter Brett's Traffic proposal only increases air pollution and congestion throughout the City, Manhood and East - West Corridor.

However, note the facts that Kingsham Primary School and Chichester High School (senior) are on the A27 north side between the Stokbridge and Whyke Junctions, The Free School (primary and senior) is close to the Whyke junction on the south side of the A27. The Central C of E Junior School is within the Orchard Street AQMA. Bishop Luffa School (senior) and Parklands Primary School are close to the proposed Via Ravenna/Sherborne Road junction. CDC need to take bold action within this plan to decrease not increase air pollution for the health and wellbeing of Chichester's future generations.

Policy DM 24 is just going through the motions and not actually relating it to the local area's major issue, the 48% of through traffic on the A27. This Policy needs to address the longterm solution as well as the effects during construction. This 5 point Policy with 4 supporting points 7.144- 7.147 lacks substance and is not robust in its plan to address Chichester's fatal Air Quality conditions. It requires rewriting addressing all factors of this serious problem.

Representation #470 also refers.

In an article in the Times on 5th Feb 2019 (copy att.), references are made to the Unicef and Royal College of Paediatrics and Child Health survey on the harm caused by pollutants, specifically to children.

The Stockbridge and Whyke junctions are both adjacent to schools with (in total) almost three thousand pupils with ages ranging from 4-19 years.

Stockbridge is an AQMA that has exceeded recommended NO2 levels for many years.

The DEFRA spokesperson quoted in the article also referred to a "...forthcoming environment bill [that] will include new primary legislation on air quality".

It is simply not good enough to "maintain" current levels of air pollution through the plan period.

Chichester has a known air pollution problem that has never been adequately addressed. We can not continue to ignore this issue, only requiring an air quality assessment with possible mitigations detailed. This is not good enough, action is needed.
There is considerable scientific evidence about the negative impact this has on the development of children's organs, link to dementia and such. This policy doesn't do enough for local people in this respect.
The Stockbridge AQMA is located near 3 schools and a local plan must do better to ensure equality and that resident's health is not being adversely impacted.

Paragraphs 4 and 5 state that where development or traffic is likely to have a "significant impact" on air quality an assessment will be required. It does not quantify how the judgement of "significance" will be made nor what decision would be made based on adverse assessments. The creeping pattern and cumulative effect of air pollution sources is just as damaging as one significant addition. There could be a temptation to allow a deterioration in air quality if development would provide lots of Section 106 funding.
Makes no commitment to take prevailing wind direction into account when locating such developments.

I can see no recommendations for the reduction in air pollution and the management of AQMA. Contrary to bland statements I can only see increases in air pollution and movement of the problem from, for example, the Stockbridge roundabout to the proposed Apuldram roundabout and the proposed link road. That coupled with the extra journey miles with no right turns at Stockbridge and Whyke will only increase the pollution problem not reduce it. The only solution is to endorse the mitigated Northern route and separation of through and local traffic which will remove the AQMAs. Nothing in this plan will solve this problem as it currently stands. Unless this is adequately addressed in future iterations of the plan I will wish to raise this with the examiner at the appropriate juncture.

DM24 air pollution. I can see no recommendations for the reduction in air pollution and the management of AQMA. Contrary to bland statements I can only see increases in air pollution and movement of the problem from, for example, the Stockbridge roundabout to the proposed Apuldram roundabout and the proposed link road. That coupled with the extra journey miles with no right turns at Stockbridge and Wyck will only increase the pollution problem not reduce it.

Having trawled through the CDC Local Plan, which I have to say at the outset is the least user friendly document I have had the misfortune to read in a long time. The sceptic amongst me , would claim that CDC has deliberately done its best to make it as inaccessible as possible and these points go to explain my reasons for coming to that conclusion.

:- It was released just before Christmas, when CDC knows that people are busy.
:- It was released with very little advertising and only now has there been a little more effort but still not enough..
:- Very few public exhibitions have been put on or advertised , many actually put on by local communities horrified at what has been included.
:- Only available really to those who have access to the internet as there is a charge of £15 for a paper copy so excluding many of the older generation who do not have access to the internet.
:- the fact that the software being used only allows one response from an email address. Any others are not acknowledged.

I would like these issued raised and acknowledged. For such an important Consultation to be conducted in this matter is harmful and actually against a democratic process.

I have commented electronically but because of the constraint of 100 words this makes commenting properly very restrictive , I am therefore submitting this email as well and insist that both my electronic comments/objections are taken together and that neither is excluded.
I welcome a need for a Local Plan to safe guard the uniqueness and sustainability of our beautiful city, but this plan is wholly unfit for purpose. In places it is so biased and contradictory , it has actually made me laugh ! This is a Local Plan so why has there only been development in the South , East and West. For some reason Goodwood and the North has either been included and then removed or excluded completely. This is not a LOCAL PLAN, this is a biased and incomplete plan because of this exclusion.

The Southern and western areas that border Chichester Harbour AONB have been repeatedly included in the plan for significant development despite having the a same or greater criteria for exclusion than Goodwood and the area to the south SDNP which have been excluded. This invalidates the Plan as it contradicts all the criteria used and makes a mockery of the Plans integrity.

TRANSPORT

The transport study done by Peter Brett Assoc (PBA) is completely unfit for purpose. The study has only explored short term transport infrastructure which is completely unacceptable for this Plan which specifically states that is should be looking at short, medium and long term transport models especially the considering the Plan is supposed to last until 2035. It has included a link road in AL6 which was roundly opposed in the democratic Highways England (HE) consultation of 2016 along with hybrids of Options 2 and 3 also rejected, so it should not have been included unless all other options including the preferred Mitigated Northern route had also been included.

There has been no detail of how these large housing developments (over 2000 homes) along the A259 are going to access the A27 which is already at full capacity at the Fishbourne Roundabout. There is also no evidence that the required consultations between CDC, PBA and HE have taken place so any inclusion of link roads and junction upgrades are invalidate and should be removed and if not adequately addressed in future iterations of this plan , I will raise it with the examiner at the appropriate time .The PBA actually claims that there will not be an increase in air/noise/pollution by the building of a link road. REALLY ! You are proposing to build an elevated road (due to it being on a floodplain 3 zone !) which would have to be 4 metres high in an open flat topography, bordering the highly sensitive Chichester Harbour AONB with dark skies and noise/air pollution protection and restricting right turns only, necessitating Stockbridge and Whyke roundanabout traffic to travel twice as far and the report states that there would be no increase in air pollution.Absolutely ridiculous and totally unrealistic.They also state that there will be no further increase in air pollution despite traffic volume increasing year on year. Chichester, especially Stockbridge Roundabout has frequently breached air quality limits in recent years and continues to do so. So this part of the report is just nonsense.(DM24/SP28)
There is also no mention of any realistic funding. Again you cannot include junction upgrades which come under the jurisdiction of HE and for which no consultation evidence has been shown in the report. CDC Local Plan should not include any upgrades that they do not have confirmed funding for when the plan is produced. Anyone can produce a plan with a nice wish list but this does not make a professional /viable document .
CDC said itself that "any highways improvements should mitigate congestion on the A27"....the limited detail in this plan actually adds to the congestion it does not mitigate it and it again hugely disadvantages local traffic.

All the proposed developments along the A259, at Chidham/Hambrook, Bosham, Southbourne and Fishbourne all claim that they are sustainable because they have good transport links in the form of bus and rail links. They do not and these transport link viabilty and frequency cannot be influenced by CDC as they are run by independent companies. At present the bus service is fairly frequent at peak times but other times is not so cannot be relied upon. It is also not a very cheap option for many people. Rail links have been cut significantly in recent years with timetable rearrangements and places like Bosham and Southbourne have one train stopping once an hour at peak times, to and from Chichester. Not what I would call good links. and again is expensive..£2.80 for a single from Fishbourne...a journey of 5 minutes !! So these developments would realistically rely on cars again so increasing the burden on the Fishbourne of Emsworth junctions that are already running at full capacity.

Unless these issues are adequately addressed in future iterations of this plan, i will raise it with the examiner at the appropriate time.

HOUSING

( including 3.17,S3,S5,S19,4.3 )

Why is CDC not insisting that SDNP take back responsibility for the allocation of 41 houses a year . It would remove the need for CDC to find areas for another 200+ houses within their local plan and SDNP should be promoting small scale house building within the Park in order to sustain local services such as schools and local services which will die if more families are not encouraged.

Why has the north of Chichester ,been removed from the plan...houses along the A259 amount to well over 2000 houses with the same environmental sensitivities and yet houses south of the SDNP to Chichester NONE. There is no justification for this as there is suitable land around Goodwood airfield and Rolls Royce that could be used and was originally included in the plan but again was removed for no justifiable reason. Why can large villages like Lavant and Boxgrove not have any housing allocation ? They are classed as local service hubs as they have shops and schools and yet are excluded. Unless this is adequately addressed in future iterations of the plan, I will raise this with the examiner at the appropriate time.

New housing need to be smaller less intrusive developments so that they don't overwhelm and swamp existing residential areas. They also need to be a majority of affordable housing for people with local connections. These local connections should actually mean people born in the city or whose parents have lived in the area for the majority of their lives. Local young adults don't stand a hope of buying or even renting in Chichester as the prices are so high compared to wages of most ordinary people.There should be a ban on second homes and but if they do slip though and are rented out, then rents should be capped to make it less attractive to landlords.

New developments should not include 'executive' 4 and 5 bedroomed houses. There are enough of these in Chichester and so developments should consist of 1, 2 and 3 bedroomed properties only with a few 4 bedroomed houses to satisfy housing association demand.

Why are brownfield sites like the one bordering Swanfield Drive / Portfield near Sainsburys not being used for housing if demand is so crucial. We do not need anymore out of town entertainment which is killing the town centre.It should be reclassified for housing , as it would have less impact, is within walking distance of services and already borders residential areas..

Unless these issues are adequately addressed in future iterations of the plan, I will raise it with examiner at the appropriate time.

SCHOOLS/SERVICE INFRASTRUCTURES

(including 4.85)

Although there is lip service paid to providing schools, it is all very vague. If you are building developments of 250 + then you are going to need school provision. Most schools in places like Bosham are already at full capacity from local children so expansion or new schools need to be built very early on in any development. The threshold should be very low , for example when the 50th house of 250 is built, that way the services will already be in place before the houses are occupied. Most primary schools within Chichester city and surrounding villages are now already at full capacity necessitating parents to have to travel in cars to get their children to less local schools. The schools like Parklands Primary that have been expanded recently to take two form entry have suffered from substandard design and building. Stairs out of action for months. Disabled toilet out of use and worst of all classrooms too hot in summer due to lack of air conditioning which meant children had to be sent home for several days. This particular issue has still not been addressed so will occur next year when the temperature rises.

Although the Free School has recently been completed( but because of its site requires most children to access by car at least some if not all of the way,) relieving pressures on primary and secondary school places, no provision has been made for future developments around the southern peninsula of Witterings/ Bracklesham etc which necessitates huge transport movement twice a day as there is no secondary school provision within a 6 mile radius.

Funding for such new schools are not funded by CDC and therefore these should have been properly costed and funded before they could be legitimately included in the Local Plan...again a fictitious wish list !!

No mention of where people are going to find other services such as doctors and dentist, many of which are already running at full or near full capacity.If there are no services available locally then people will be forced to travel. No mention of increased travel because of this and lack of local school places in the Local Plan.

Unless these issues are adequately addressed in future iterations of this plan, I will raise it with the examiner at the appropriate time.

AIR QUALITY

DM24/SP28 There is no acknowledgement of the fact that the air quality levels especially at Stockbridge Roundabout exceeds quite substantially acceptable levels set by the Government. Such an omission is significant and has a huge influence on future planned developments and unless it is adequately addressed in future iterations of the plan, I will raise this with examiner at the appropriate time

AL6.

Well where do I start on such an utter inaccurate piece of wilful destruction and vandalism. AL6 contradicts everything that the Local plan states .
It does not protect the biodiversity of the area...It DESTROYS it
It does not protect the historic views of the only Cathedral visible from the sea...It DESTROYS it.
It does not enhance the natural environment (S26)... It DESTROYS it
It does has an adverse impact on the openness of views in and around the coast. (S26)..It DESTROYS them.
It does not have regard to flood and erosion policy (S27)...It WILL increase the likelyhood of flooding and contamination of Chichester Harbour water.
It does not protect the area from light/air/noise pollution(DM23/24 etc)....it would DESTROY the dark skies policy and hugely increase air pollution.

I could continue. AL6 should be removed completely. The Plan itself states that no proper study has been done into the impact of AL6 and so that very admission should have been enough to exclude it from the plan.How can you include a destructive option like this without doing any sort of environmental study or impact study first. Unprofessional and disgraceful AL6 comes within 100 metres of Chichester Harbour which has AONB status which holds the same protection as the SDNP but does not have the same 5km exclusion that the SDNP has been given....strange that !! Unfortunately Chichester Harbour does not have a landed Estate as its neighbour !!

AL6 is on a category 3 Floodplain , which under Governments own rational means that it should not be developed for housing or industry at all because of the unacceptable flood risk and only then developed if ALL other less risky sites have been developed first and only then for suitable light use. Land to the south of the SDNP has been removed due to it being under risk of flooding and yet it is mainly classed as Flood zone 2 , a lesser risk. So why was it removed for this reason and AL6 left in place ?
INCONSISTENCY and BIAS. REMOVE AL6.

Under CDC own data, a link road would need to be elevated to 4 metres in order to be safe from flooding.How on earth are you going to mitigate a road that high which is on a flat topography with historic views of Chichester and the Cathedral ? .This would then contravene Government policy on pollution and housing , as the toxic fumes from the road would reach higher into the air.REMOVE AL6.

This link road and Options 2/3 were hugely unpopular in the 2016 Highways England Democratic Consultation and were emphatically rejected by the vast majority of Chichester residents as they knew it would be short term and ineffectual and that along with the no right turns at junctions would hugely hinder the movement of local traffic. CDC were seen to accept that and Cllr Dignum said that "any Highways improvement should mitigate congestion on the A27". Clearly this scheme would not and so why is the link road included. If you want an unbiased complete Plan then surely the mitigated Northern route should have been included in this plan as the criteria are the same...no funding and no HE acceptance, or exclude both proposals. Again double standards to the detriment of the south.No roads should have been included as they do not come under CDC remit or funding and the protection under Para 3 AL6 is unachievable. Total betrayal under Cllr Dignum leadership.REMOVE AL6

In order to instigate a link road , junction upgrades are also mentioned...(but not funded by CDC and no consultation evidence with HE in the Local Plan S23 and PBA report) Each junction is estimated to take a minimum of 3 yrs to complete, that's 15 years of gridlock, air pollution and misery. Seriously. Chichester city and tourist industry would be destroyed. REMOVE AL6

There is no mention of only a 100 metre border with the Chichester Harbour AONB and yet frequent reference is made to the SDNP 1km border. Double standards and inconsistency again.REMOVE AL6

There is no mention that the land earmarked in AL6 is floodplain 3 category. Frequent reference to SDNP/Goodwood being in Flood zone 2 and a small amount in Flood plain 3. Again double standards and inconsistency. REMOVE AL6

No mention to the destruction of the views and yet time and again SDNP/Goodwood views of the Cathedral are mentioned and pushed. The views from SDNP/Goodwood are far less prominent and actually are invisible because of the topography of the land in many places. Not the case for views in AL6 where uninterrupted views of the Cathedral can be seen from the coast in almost any position looking north. Double standards and inconsistency again.REMOVE AL6

No amount of mitigation could protect Chichester Harbours unique ecology. It has status as an AONB, SPA,SAC,SSSI and is a Ramsar site. There is no detail of how a successful buffer zone would be applied.There appears to be no room for a proper successful wildlife buffer zone, with proposed building up to 100 meters of the harbour.There would be significant adverse ecological damage done, from light, noise and especially air pollution,which already breaches Government and EU safe levels. There is no mention of waste water management and the capacity for any further waste water to be processed at Apuldram Water Treatment plant is not an option as it has reached capacity so the risk of polluted water entering Chichester Harbour is incredibly high and an unacceptable risk.(Policy S18) REMOVE AL6

There are other much more suitable areas already identified around Goodwood Airfield and Rolls Royce which meet the criteria set out in the plan for housing and light industrial employment and already have suitable infrastructure but have been unjustifiably removed. These should be reinstated and AL6 REMOVED.

Any development of AL6 would necessitate movement by car due to its proximity to the A27 .This is against CDC Local plan policy of encouraging any new developments to either be well served with public transport or sustainable transport ie cycling and walking. The position of this site will not meet this criteria. REMOVE AL6.

There is no mention of the fact that this site is part of the River Lavant floodplain. Those of us who remember the 1990's , remember the hugely damaging flooding that affected Chichester partly because the water courses and natural drainage had been allowed to deteriorate. AL6 covers a significant part of the River Lavant natural drainage basin. It would be insane to build on this land. It could well result in renewed flooding in the city centre as we get wetter winters and the rain water has no where to go.REMOVE AL6.

The plan is totally inconsistent as to numbers in the development. How can we possibly comment on a plan that in one place states there would be 100 houses and industrial units in AL6 and yet elsewhere it says 200 + homes and industrial units. Ridiculous inconsistency and very unprofessional. REMOVE AL6.

Unless all these issues are adequately addressed in future iterations of the plan, I will raise these with the examiner at the appropriate time.

In summary, The CDC Local Plan in its form at present should be rejected and rewritten with the inconsistency and bias removed. Any development site should only be include when a proper and realistic viability study has been commissioned by independent consultants who will have been given a complete and unbiased brief (unlike the PBA study which is incomplete ,short term and does not reach the brief that was supposedly set). This is hugely important to the Chichester area and its residents. We want and deserve a fair ,complete and transparent plan and this version is not.

CDC along with WSCC should go to central Government and insist that until proper funding is put in places to sort the transport/A27 and services (Schools etc) infrastructure out then although the Plan can be written, no housing will be built until funding has been secured and work started on this vital infrastructure. We cannot sustain this level of development without serious investment on infrastructure and the addressing of dangerous pollution levels because of the lack of it.

Until this Plan has been fairly and properly amended so it provides a properly informed, fair and complete document it should not be adopted and should then be rewritten and only then reissued for full public consultation again. Unless this is adequately addressed in future iterations, I will raise it with the examiner at the appropriate time.

Chichester District Council
Local Plan consultation 2018/19

Comments by
Anthony Tuffin

1. There is no simple and intuitive way to comment online. A cynic could be forgiven for suspecting that the web designer had been instructed to make it difficult for the public to comment. So, I am commenting by e-mail.

2. Summary:
2.1 Selsey is not a hub.
2.2 Opportunities have been missed for development north of Chichester.
2.3 Manhood cannot cope with more development until a new A27 has been built north of Chichester.

3. 6.79 describes Selsey as 'settlement hub', but goes on to state that "it is located at the southern end of the Manhood Peninsula (Selsey Bill)" and 6.81 states, "The B2145 is the only road connecting the town to the north" As there is sea to the east, south and west of Selsey and only one road to the north in and out of the town, it is not a hub. Indeed, it is at the circumference end of just one spoke.

According to the Oxford English Dictionary, "hub" means;
* The central part of a wheel, rotating on or with the axle, and from which the spokes radiate.
* The effective centre of an activity, region, or network.
* A central airport or other transport facility from which many services operate.

I.e., "centre" or "central" is the key part of the meaning, but Selsey is neither a centre nor central.

4. The Council should not import housing need that the South Downs National Park (SDNP) refuses.

5. The Chichester District cannot accommodate future housing or employment space until the A27 uncertainty is ended. The local population rejected Highways England's last proposal.

6. Para 3.4 omits development opportunities north of the city. Including these would help us reduce the pressure to the south where there is a lack of appropriate space because of the flood plain.

7. Para 3.7 states, "The relationship between the National Park and significant natural areas to the south, especially Chichester Harbour Area of Outstanding Natural Beauty, will be carefully managed by maintaining and enhancing the countryside between settlements." How, then, can you justify the proposal at Apuldram, which would remove the only view of a cathedral from the sea in the country and long-distance views of the downs?

8. Para 3.19 Strategic infrastructure excludes the Mitigated Northern Route. Tweaking the existing A27 lacks local community consensus and would prevent us from getting a long-term solution; i.e., a strategic northern route.

9. Policy S4 Why is there no housing planned for the area between the city and the SDNP to relieve the pressure south of the city?

10. Para 4.84 "Some funding for the A27 junctions package of improvements has already been secured from planning permissions granted to date." The population of Chichester have asked for a new strategic route for the A27 endorsed by both CDC and West Sussex County Council (WSCC) in a democratic process.
We should not spend money to improve a road that is Highways England's responsibility.
It is Highways England's responsibility to provide a suitable trunk road for the south coast and it is the Government's responsibility to fund it.
CDC cannot accept housing allocation for the Manhood Peninsula surrounded by the sea and the congested A27 until the congestion is relieved.
11. DM24 air pollution. There seem no recommendations for the reduction in air pollution. As the prevailing wind is from the south-west, the best long-term solution would be to site the A27 north of the city.

End.

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.

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

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.

See attachment

See attachment

See attachment

Proposed plans for the A27 and AL6 will further deteriorate Air Quality.
Stockbridge already EXCEEDS the recommended air quality levels.
The Council should be looking at REDUCING the pollution levels rather than increasing them to the detriment of the local population.