Policy DM25: Noise

I fail to see how it is possible to control noise disturbance on new developments on construction and the subsequent use where vehicle noise and general noise associated with modern living.

Department for Environment Food & Rural Affairs (DEFRA) states that Environmental Noise Directive (END) requires, on a five yearly cycle, the production of strategic noise maps, the preparation of Action Plans based on the results of the noise mapping, and consultation with the public on the contents of these Action Plans.
The Action Plans are designed to manage environmental noise and its effects, including noise reduction if necessary, and preservation of quiet areas.

7.150, DM25 point 2. What is deemed an "acceptable level" when there is no reference to industry standards or DoT Design Manual for Roads and Bridges (DMRB) in the Local Plan.

DM25 omits to state what mitigations will be put in place during construction periods when noise levels are likely to be in excess of "acceptable".

DM25 leaves out the development proposed for AL6 including a raised road in the vicinity of the internationally recognised and protected AONB. Mitigation will be difficult to introduce on a raised road without impeding the historic views of the Cathedral and South Downs from the harbour. This policy has a focus on Goodwood's noise polluting motor circuit and aerodrome.

DM25 leaves out any mention of financial compensation to residents/AONB or any actual noise assessments or noise maps for these areas prior to and after development.

Peter Brett's Appendix H states that there is a clear noise level increase for Bracklesham Lane far in access of what they conclude as "acceptable" - 3db!

This Policy ignores the need to protect Chichester Harbour AONB from developments which will cause noise affecting Wildlife Habitats/"quiet areas".

This Policy needs redrafting to include all of these factors.

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