Local Plan Strategic Objectives

Support the Strategic Transport objectives.

Under Health and Well-Being add a bullet: "develop networks of paths and lanes to encourage NV travel/walking/cycling."

Resident of West Wittering
Addressing facilities in the Witterings. 4 Banks have closed, Hardware shop closed, restaurant closed, Pub closed, Post Office closed, convenience store closed etc, etc. More housing appears to bring about retail closures.
Addressing environment. More housing brings about more commuting into Chichester and destroys landscape.
Addressing Strategic Infrastructure. Access to and from A27, mitigation was supposed to have been put in place by the time the housing completions were met under the adopted Local Plan, which has already been met, ref Jacobs Transport Study 2013. No work has yet been undertaken.
Addressing Sewage. In 2012 the spare capacity at the Sidlesham WTW was 914 dwellings. To date new builds, under construction and with Planning Consent is already nearing 850. Remaining capacity 64.
Addressing Flood Risk. NPPF requires a 'Fall Back' area to allow for homes to replace those at flood risk due to rising sea levels. This has been ignored.

Housing and Neighbourhood, 1st Objective:
The quality and appearance of our most recent development, East Beach Walk is, by some resident, `not fit for purpose'. Because of the high level of ground water, doors and windows do not fit. More important is the drainage issues. A few houses have damp floors and carpets. All future developments should have real mitigation against becoming boggy. Finally, the design of most new estates (EBW among others is boring red brick boxes with small windows. What has happened to modern architecture that is pleasing to look at and is designed for the particular location?

Strategic Infrastructure
The planned population increases on the East West Corridor will make the proposals for the present A27 only a short term solution. The only long-term answer to segregate through and local traffic.. If the proposed roundabout improvements are done, during the 2 or 3 years that this will take the traffic and the air pollution will be much worse and children may die. The only sensible option is to first build a Northern option, then sort out the exisitng road, knowing that there will then be 45% less traffic on it.

Cycle Routes & Public Transport
a) It is imperative that all potential cycle routes link up to make a commuter network. On the Manhood, these these have been identified and promoted by GLAM and MPP. Are the protocols in pplace to ensure that they can be given priority when future Planning Applications are lodged which might otherwise conflict.
b) Is there a way that CDC can work with the bus providers to ensure lower fares, especially for those aged under 25's.?

Water Resources a) Ensure Supplies by capturing rainfall that falls on the Downs and building reservoirs in the South Downs as opportunities arise. This will reduce coastal groundwater and can provide leisure facilities and enhance nature.
b) SUDS are only a partial answer to flooding. Small ponds in boggy places are more effective, better for wildlife and they enhance the environment generally. There should also be rain water capture and re-use of grey water from houses to use in toilets and water gardens, hopefully planted with copious trees and shrubs. This should be a requirement of planning permission.

Housing must be affordable & majority for local connection not just 2 yrs but if people are born in area / have a local connections. Second home embargos in villages. Make it financial unviable for people to buy houses to rent out. Cap the rents so they have to be affordable to local families. No studies on the environmental damage due to A27 and air/light pollution.Mass development not sustainable because of lack of infrastructure.No mention of the North. Unless this is addressed in future iterations of the plan , I will raise this with the examiner at the appropriate time.

What is the evidence that Strategic Sites will become more self-contained? (Para 3.11) In spite of all the new houses East Wittering and Bracklesham have seen the recent loss of 4 banks and a large pub. There are very few new employers.

What is the evidence for commercial and social activities to thrive? (Para 3.12)

What is the evidence that more dwellings will cause local industries to flourish? (Para 3.13)

The vision is full of communities flourishing and thriving as a result of new housing with no supporting evidence. This Local Plan Review should include an appraisal of the previous plan. We need to learn from the previous Local Plan before prescribing more of the same.

The objectives of the Strategic Infrastructure should be more explicit in identifying the conflict between local traffic and through traffic on the A27. It is not enough to attempt to mitigate congestion on the A27 through improvements. The objective should focus on ways to separate through traffic from local traffic without cutting the Manhood Peninsula off from the City.

CDCF should like to respectfully comment and respond to the current Local Plan Consultation being held by Chichester District Council.
For a start, the consultation papers and documents provided for consideration are without doubt, a 'massive' piece of work. The Chapters and text form a highly technical and complex piece of work covering the whole of the Chichester District. It is as if the district has been 'rolled out' flat or to put it another way, 'no stone has been left unturned'. The Planning Policy Team at CDC must be congratulated for their thoroughness and attention to detail.
With this in mind, it would be presumptuous of CDCF to 'drill down' into the document and request small changes here and there. CDCF have the interests of cyclists and cycling at heart and this response wishes to adopt a more 'broad brush' approach.
Without wishing to state the obvious, different cyclists have different needs and preferences. For some people, cycling is a way to travel from home to work whereas for others, it is a whole family leisure activity. Some cyclists travelling to work require a flat surface and a direct route (on or off road) to achieve a good speed and comfortable cadence. A cyclist on an off road leisure route, wishes to enjoy the safety, peace and fresh air away from vehicular traffic.
One size does not fit all and the Local Plan must reflect these differences. CDCF note that the Local Plan Vision for 2035 includes a reference to residents 'pursuing a healthy lifestyle with good access to leisure facilities and open spaces' and to 'move around safely and conveniently with opportunities to choose alternatives to car travel'. Under the heading of Objectives for the Local Plan (3.19) the document lists the need to 'achieve a sustainable and integrated transport system through improved cycle ways and links to public transport'. CDCF would endorse these statements.
CDCF note that the Local Plan sets out those areas within the Chichester District where new housing would be most suitable and appropriate. According to the Local Plan, the East/West corridor from Tangmere to Southbourne is the most favoured location for the majority of these new dwellings, circa 10,056 with a further 1933 new dwellings being built on the Manhood Peninsular.
CDCF have very recently been working on a cycle project known as CHEMROUTE. This is an abbreviation that describes our aspirations for a decent and useable cycle route between Chichester and Emsworth. In addition to following the A259 corridor, this vital section of cycle route forms part of the National Cycle Network Route 2 ie Dover to St Austell. NCN2 passes through West Sussex and into Hampshire and we
2.
have a duty and responsibility to ensure that our section is clearly marked, engineered and designed to national standards. Our work on this project has taken us to meet with representatives of the Parish Councils along the route and it has been encouraging to see the unanimous support for NCN2. The Parish Councils are writing this support into their own Local Plans and the hope is that, when certain sites become the subject of a planning application for new housing, contributions will be sought through the Community Infrastructure Levy process to require developers to finance this important cycle route. CDCF are pleased to see that CDC's Local Plan sets out a commitment to improve the highway infrastructure for cyclists and pedestrians. In simple terms, if the residents of each new household along the A259 corridor ran two cars, this would result in an additional 20,000 cars using the A27 and A259. The traffic jam would be spectacular! Sustainable transport, such as cycling, buses and trains are the only solution and for the former, a decent cycle route must be put in place to encourage the population to leave their cars at home.
One of the frustrations of our current planning process is that planning officers can only make a determination on the development site. In other words, the area of land inside the red boundary line that extends around the whole site. Many developers put in place cycle paths within a new housing area but very often, these paths reach the 'red line' and stop. In other words, these paths do not link in with existing cycle paths or long term plans for a cycle route. The A259 corridor is already seeing and will see in the future, new development sites being identified and it makes sense to require developers to finance cycle infrastructure improvements to encourage their 'new residents' to cycle or walk.
The same argument may be applied to the Manhood Peninsular only here; the current road networks are even more difficult. It is encouraging to see that Policy 18 acknowledges that there is a need to 'improve the infrastructure to support sustainable modes of transport, especially cycle ways, bridleways and footpaths'. In recent months, the Selsey Community Forum has been planning for a Selsey Greenway path to link Selsey with Chichester. It is well known that the B2145 is not a good place to be on a pedal cycle and at the time of writing this response, the first stage of the Greenway ie Selsey to Pagham Nature Reserve is nearing completion. There are advanced plans to progress the pathway further north towards Hunston and Chichester. Further west, the Salterns Way is a considerable community asset and is well used by walkers and cyclists alike.
It is worth noting that the Local Plan points out that CDC are updating their Cycling, Walking and Infrastructure Plan and under Green Infrastructure (DM32) the text reads, 'planning permission will be granted where it can be demonstrated that the following criteria have been addressed: the proposals do not lead to the dissection of the linear network of cycle ways, PROW, bridleways and ecological corridors'.
3.
Therefore, developers will have to incorporate measures to avoid harm and mitigate effects.
It must also be pointed out that the National Planning Policy Framework that came into force in July 2018 (para 98) directs that, 'planning policies and decisions should protect and enhance public rights of way and access, including taking opportunities to provide better facilities for users, for example by adding links to existing rights of way networks including National Trails'.
CDCF note that the Chichester District forming part of the South Downs National Park will not become the focus for any major new housing developments. The Centurion Way follows the old railway line that was once operated by the London and South Coast Railway Company. To date the Centurion Way extends from Chichester to West Dean and a planning application is currently under consideration to extend the path to the top of Cocking Hill where the South Downs Way crosses over the A286. The ultimate aim is to extend the Centurion Way to Midhurst. CDCF have recently established a Centurion Way User Group to protect the route from unreasonable changes and to offer light maintenance along the route.
In summary, Highways England have a published a Cycling Strategy, West Sussex County Council have a Walking and Cycling Strategy, Chichester District Council have a Cycling, Walking and Infrastructure Planning Policy. For any of these 'policies' and in particular, this Local Plan, to make any sense whatsoever, CDCF must urge the relevant authorities to put their words into actions. When our communities can actually see real change happening, then and only then, shall we feel satisfied and confident in the knowledge that our thoughts and comments have been applied to everyday, real life situations. CDCF should like to wish the CDC Planning Policy Team well with this project and the eventual publication of the final Local Plan.

Broadly support.
Consider in Health & Well-Being including reference to children, not just "the older population" - children who get out and about independently in their communities become healthy adults who value the same freedoms and interaction with the spaces and people around them and are a good "indicator species" for healthy, cohesive, properly-planned communities.
Consider similar for people who have disabilities - the world around all of us needs to welcome all, not just our "dwellings", "leisure facilities and linked green spaces".

Natural England broadly supports the strategic objectives. However, we would urge the Council to be more ambitious in the greenhouse gas emissions objective, and amend 'minimise the net increase' to 'reduce greenhouse emissions'. Chichester District is at particular risk from the effects of climate change, in terms of sea level rise and cost of flood management infrastructure, but also loss of intertidal habitats (and the species that rely on them) that residents and visitors value.

Under the economic objectives, we suggest that the fourth point might be strengthened/enhanced with the addition of reference to cultural uses alongside those already included. Cultural uses are compatible within this context, and would help ensure consistency throughout the document and help underpin delivery of the vision.

Objectives should include support for the WSCC/CDC preferred scheme for a new A27 Chichester Bypass to the north of the City.
These objectives are all well and good but the plan doesn't say how most of them are achieved e.g. "Encourage healthy and active lifestyles......".

The strategic objectives housing makes no mention of renewable energy and up to date digital infrastructure that should be built into any new development both for housing and employment space.

The Strategic infrastructure makes no mention of the mitigated Northern route. We must resist tinkering to the A27 that can be considered as community consensus and prevents us from getting our true requirement which is a strategic mitigated Northern Route. You are obliged to look at short, medium and long term solutions where they impact the strategic road network. The proposal in this plan is only short term and therefore does not provide a deliverable solution for the strategic A27 and is a waste of valuable infrastructure money locally. It is also in direct conflict with the works proposed but not undertaken in the current adopted plan. You are obliged to meet those requirements before then considering new development impacts. Unless this is adequately addressed in future iterations of the plan I will wish to raise this with the examiner at the appropriate juncture.

strategic objectives housing makes no mention of renewable energy and up to date digital infrastructure that should be built into any new development both for housing and employment space.

strategic objectives housing makes no mention of renewable energy and upto date digital infrastructure that should be built into any new development both for housing and employment space.
Strategic infrastructure makes no mention of the mitigated Northern route. We must resist tinkering to the A27 that can be considered as community concensus and prevents us from getting our true requirement which is a strategic mitigated Northern Route. You are obliged to look at short, medium and long term solutions where they impact the strategic road network. The proposal in this plan is only short term and therefore does not provide a deliverable solution for the strategic A27 and is a waste of valuable infrastructure money locally. It is also in direct conflict with the works proposed but not undertaken in the current adopted plan. You are obliged to meet those requirements before then considering new development impacts. Unless this is adequately addressed in future iterations of the plan I will wish to raise this with the examiner at the appropriate juncture.

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.

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.

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.

I have a number of issues with the PLAN.
The old plan has not expired yet a more aggressive plan is being introduced.
Few people have commented.
A mail shot to all residents should be implemented outlining the individual aspects
The A27 Junction alterations appear to be a "southern route" by stealth.
The Appuldram link road in particular is of serious concern what with its proximity to the Harbour.
No provisions for education have been met on previous big builds how can we be assured that planning for education will in fact be carried out.
The intensity of build projects appear to have exceeded the current plan targets, why impose a greater plan ahead of requirement.
A stronger opposition to building the large scale developments should be implemented.
Of the new build how many will be for Chichester residents. If outside families move into the borough their children's requirements will only exasperate the future housing requirements.
What properties are for current residents and will a rule apply to prevent outside occupation.

My main concern is that the PLAN is too big and complex for many to fully understand and longer should be taken to fully explain the implications.

See reps

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

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

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

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

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

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

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

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

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

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

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

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

In addition, paragraph 189 of the Framework states;

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

See attachment

See attachment

See attachment

See attachment

See attachment