Appendix E - Monitoring Framework

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

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

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

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

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

Spatial Strategy

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

Strategic Policies

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

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

Strategic Site Allocations

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

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

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

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

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

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

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

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

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

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

Policy AL11 'Hunston' allocation is not site specific.

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

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

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

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

Development Management

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

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

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

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

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

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

Appendix 'E' Monitoring Framework

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

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

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

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

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

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

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

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

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

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

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

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


REP2: OBJECTION TO PARAGRAPH 6.56

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

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

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

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

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

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

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


REP3: OBJECTION TO CRITERION 3 OF AL7

Policies AL9 and AL10 both include criterion 3 which state:

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

However, criterion 3 of AL7 states:

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

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

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


REP4: OBJECTION TO POLICY AL7

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

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

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

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


REP5: OBJECTION TO POLICY AL7

Policy AL9 and AL10 include a criterion which states:

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

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

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


REP6: OBJECTION TO POLICY AL7

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

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

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

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


REP7: OBJECTION TO POLICY DM18 FLOOD RISK AND WATER MANAGEMENT

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


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

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



REP9 - OBJECTION TO POLICY DM34 - OPEN SPACE

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

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



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


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

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

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


REP 11 - OBJECTION TO AL7 - DENSITY AND NUMER

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

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

OTHER

We support the creation of an integrated and sustainable transport plan for the District, or at the very least for the area west of Chichester. This plan should draw upon the ongoing work of the ChEmRoute group's investigations and proposals for the National Cycle Route 2 (NCN2) and be co-ordinated with WSCC with the goal of introducing high quality and separated cycle links between the villages along the A259 and Chichester. The route or routes may include a fast but safe link along the A259 aimed primarily at cyclists including commuters as well as a slower, more meandering and leisurely route north of the A259 (and perhaps the railway). To make these cycle routes sustainable they will need connections and feeder routes from new and existing developments. In developing a more ambitious and safer scheme for cyclists care must also be taken to ensure that pedestrian routes are protected too. The vision must be to ensure that both cycle and pedestrian traffic is encouraged and supported and not brought into competition with each other.

See attachment

See attachment

See attachment