Sustainability Appraisal

The difference between Option 1 and 1A is said to be that option 1A reduces the scale of development on Manhood and redistributes it to Southbourne, Hunston and Tangmere.

However for some reason Chidham and Hambrook allocation reduces from 600 in Option 1 to 500 in Option 1A and there is no explanation or justification for this reduction.

The 600 unit allocation for Hambrook in Option 1 should have been carried forward in Option 1A as it has a railway station and the 700 bus route.

Then reduce 200 unit allocation for hunston to 100 as less sustainable

Overall - clarity needs to be provided as to why a larger development was deemed to be more sustainable in Hunston (see Section 4.1.1).

Hunston Sustainability Report:

1C - change to neutral - development would have a negative impact on biodiversity due to loss of green space habitat and proximity of proposed developments to Hunston Copse.

4B - change to negative (red) - as strategic development will increase congestion on B2145 and increase need to travel to Chichester City. Limited facilities in village therefore there will be increased commuter trips or trips for services (e.g doctor, pharmacy, schools)

6C -include increased traffic on already congested B2145

This SA appears to me, a general member of the Chichester community, a well researched & thought out document.
I support what it represents for the 2035 Local Plan.

Option 1A (Table 4) is the preferred choice for spatial distribution. The Manhood Peninsula is struggling to adjust to the hundreds of houses already built in the last five years. It is well known that the infrastructure is under severe strain. Commuting times have increased, especially in the winter. Waste water treatment and piping is at capacity. The primary schools are full and there are no secondary schools. The District Council assured residents at the last round of Local Plan consultation that there would be no more housing on the Manhood until roads and especially the A27 crossings were sorted out.

On page 60 it states that land for development at East Wittering (AL8) is likely to be Grade 3 land. This is doubtful. Only a strip of the coast is Grade 3. The proposed development sites appear to be on at least Grade 2 land.

The established needs for housing according to emerging neighbourhood plans is for more affordable housing and smaller single-floor units for the elderly. Both can be achieved with three storey blocks of flats within existing settlement areas. It is not necessary to take up large areas of good quality agricultural land. The loss of countyside is potentially damaging to the tourism, the economic main stay of the area.

Natural England welcomes the production of the Sustainability Appraisal of the Local Plan Review policies. We support the inclusion of objectives on biodiversity, water quality, use of resources, landscape and best and most versatile agricultural land. However, an omission is the lack of an objective on access to the countryside for people's health and wellbeing.

Nevertheless, we welcome the fact that the SA has been used to direct the preferred approach to Option 1 (650 dwellings per annum) and the spatial strategy to Option 1a (focus on existing settlement hubs, but limiting development on the Manhood Peninsula). Natural England agrees that these are, overall, the most sustainable options, whilst recognising that no option is without environmental impacts.

Furthermore, the SA is very useful in assessing the broad range of potential impacts that the plan policies may have, and hence should direct the Council in devising suitable mitigation measures.

The allocation of 500 homes in the Chidham and Hambrook area is excessive and is not supported by the Council's Sustainability Appraisal.

I object because:
1. The Local Plan promotes the joining of settlements between Chichester to Emsworth, which will adversely impact the special and unique character of these villages. This is in line with the Parish Council's response to Policy S2 Settlement Hierarchy.
2. The Local Plan Review has failed to make a proper distribution of housing in the Parish. The so-called comprehensive selection process undertaken by the planners in their Strategic Site Allocation exercise, and subsequently approval by the District Councillors, is woeful, as it is simply based upon developers' estimates, which have not followed the density benchmarks as per Policy DM3, and also have not been moderated for locations adjacent to sensitive locations. (as Parish Council's response to Policy S2 Settlement Hierarchy.)
3. The Infrastructure Delivery Plan -http://www.chichester.gov.uk/CHttpHandler.ashx?id=31025 (Pages 106-111 for our Parish) which supports the Local Plan is not fit for purpose. It does not adequately address the transportation, educational, medical and general amenities needs of the area that will take a long time to put in place, and not in time for a community which is expected to grow by over 50% in the plan period. This also includes the ongoing debacle about plans for the future of the A27, while in the meantime the A259 takes an ever increasing volume of local traffic. See Parish Council's response AL10/SA10 S23.
4. The Spatial Vision and Strategic Objectives (section 3.6 of the Local Plan) and the Sustainability Appraisal in relation to Chidham and Hambrook are contradictory. See Parish Council's response Policy S26/DM19 Natural Environment. If the latter prevails we will see the loss of key landscape views, the loss of high quality grade 1 and 2 farmland, a further deterioration in water quality, and further increased disruption to internally important migrating birds.

Whilst everyone in the parish fully acknowledges it has a responsibility to contribute to the need for more new housing in the District, there is no justification for the 500 homes slated for Chidham & Hambrook, a number which is excessive and not supported by any documentation.

Most importantly, it is also at odds with the standard method for assessing local housing need, based on the recently reduced ONS estimates of local housing requirements which, In September 2018, revised down its previous 2014 estimate of 210,000 new households per year to 159,000 per year in England, a huge reduction of 25%

It is also highly likely that there are reduced affordability ratios in the Chidham and Hambrook area compared to Bosham and Fishbourne which are closer to Chichester (this area is likely closer to the Havant figure of a 9.2 price to earnings ratio rather than the Chichester one of 13.5)

Adjustment factor equation to take account of affordability

There is also no account taken of the release of properties from landlords for sales in the area. As the affordability factor on new houses is 9.7, and existing houses 7.6, there should be a focused campaign on driving landlords to sell more houses already in the area, rather than building new ones.

For all the reasons given above the allocated number of houses it was stated should be significantly reduced by at least 50%, to 250 houses
Maximum

Finally, dealing with two specific local proposals by landowners:
1. Orchard Farm, Drift Lane - this campsite and caravan site has been offered for development. This single track road is already blocked by construction traffic for a single house currently being built. It is not conceivable that access for any construction traffic would be practicable to build any future house in Drift Lane.
2. Baileys fields - Pallant homes. Based on all of the considerations given above, this development is too large altogether at 500 homes.

Developer viability assessments

It is also notable that, when houses are built, developers do not make the most of the land that they own. Many housebuilders hide behind the viability assessment in not building a suitable number of affordable homes. The government has said that "this assessment should only be used when circumstances have made the council's requirements literally impossible." In all case developers trying to hide behind viability assessment should be made to publish their reasoning so that the local public can scrutinize it and, if the developers refuse to do this, their plans should also be refused.

4.4.2 and Table 3 4.6.4 , 4.7.3 Sustainability Appraisal 010

This Sustainability Appraisal is full of highly subjective notions which leads its impact assessments to be generally questionable ie on whether an option has a positive or negative impact on eg biodiversity.
In para 4.4.2 who were the "further discussions" with to cause scenario 1a to be added ?
Para 4.6.4. in trying to justify the allocation of 1250 dwellings to Southbourne, it talks of the "potential advantages" but does not mention the obvious disadvantages in almost doubling the population of this village. What provisions will the plan make eg to ensure that the Southbourne railway station is capable of handling possibly a doubling of passenger traffic.? The answer is that it can't because investment in the railway network is outside it's jurisdiction. I would only support an option that shares any new housing more evenly between settlements which is more likely to limit the obvious damage that is going to be caused to natural habitats by this Local Plan review.

What improvements or changes would you suggest?

As above.

003 Housing and Econ Devt

This document appears to rely for it's conclusion of new housing numbers on the unbridled continuation of economic growth levels through the Plan period to 2035[par a 1.17].I believe that this is an unsustainable model on which to plan the future for our children and grandchildren.
There is no attempt that I can see to apply some sort of sensitivity analysis to the single end figure of 609 dwellings per annum so that lower numbers could be chosen as a preferred option. There are many factors which could influence housing numbers over the long Plan period so it would seem sensible to start with lower numbers to try and reduce the inevitable negative impact on natural habitats that any increase in human numbers will cause.

What improvements or changes would you suggest? As stated above

5.5 in particular Strategic Wildlife Corridors Background Paper

Whilst supporting the concept of Wildlife Corridors in the Plan [why was this not done 20 years ago ?] I do object to the removal from the Plan Review of the Chidham/East of Nutbourne Wildlife Corridor. If the Southbourne Neighbourhood Plan Review [SNPR] wishes to give more priority to natural habitats then it can devise policies which avoid "the close proximity of...proposed development" cited in paragraph 5.5.
Glossary - Wildlife Corridors are not defined in the Glossary and should be included.

What improvements or changes would you suggest? As stated above.

All but especially sub-areas 82 and 83 Landscape Capacity Study - 007

Apart from it being a useful inventory of landscape types in Chichester District, this document appears to me a rather pointless exercise in Planning fudge. For example on page 496 in is saying that development could be accommodated etc etc at the same time as avoiding any "landscape or visual harm " This sort of language is found all over this document and givers too many opportunities for misunderstanding or misinterpretation.
It would have been helpful to have page numbers for the sub-areas. As it is the location of sections is prolonged.

What improvements or changes would you suggest?

Avoid attempts to give facile conclusions and recommendations.

Paras 5 and 7 various Natural Environment

Para 5.51 [Strategic Policies] suggests the Council will only object to development that causes "significant harm" to the function of the natural environment but there is no definition of this phrase
7.168 Is stating that "providing open space, sport and recreation is part of "protecting and enhancing the natural environment" This is not true as these are all man-made features designed for humans, not for nature.
Para 7.189 and others mention "priority habitats" but I can see nowhere in the Plan Review that identifies the 21 types of these habitats mapped in Sussex* either by list or on a map of the District.These important habitats are often overlooked when development applications are made [eg ref 16/03569/OUT] and this Plan is a good opportunity to draw the public's attention to those in their area.
Para 7.189 refers to a Map 5.1 but gives no easy reference to where this can be found ?
Note: *Sussex Biodiversity Record Centre records these as "Habitats of Principal Importance" - which designation is correct ?
Glossary issues: Priority Habitats are missing and should be included in the Glossary in the Plan Review.

The principal objection is to Policy AL10, with reference to the following policies: S1, S3, S26, S29, S30, D3, DM32 and the evidence of the Sustainable Appraisal and the current HELAA study.

Objection to Policy AL10: The allocation of housing for Hambrook, part of the Council's Local Plan preferred option, is disproportionate, and contrary to its policies and inconsistent with its evidence. The CDC preferred option housing allocation of 500 homes is not consistent with the sustainability evidence. CDC may have underestimated the land required in the parish to meet the Local Plan preferred option housing allocation. CDC has not fully considered the impact on local character of the parish, the landscape and wildlife corridors.

A quote from the 'Sustainability Appraisal for the Chichester Local Plan Review - Preferred Approach' referring to the proposal for Chidham & Hambrook:
"The scale of the development will completely alter the existing development.
There would be significant impact to the existing historic village"

1 Sustainability Appraisal - the evidence and decision making
The Local Plan review has failed to make a proper distribution of housing in the district. In particular its evidence and decision making process for arriving at its allocation of housing to Hambrook is flawed.

The distribution strategy.
How carefully has the Council arrived at the housing allocation for Hambrook? When comparing Hambrook with other nearby parishes the number of houses CDC estimated that could be accommodated in Hambrook on its HELAA study preferred sites is not consistent with the study evidence. Meeting the allocation may require the parish to propose development of previously rejected sites.

The Council considered alternative numbers for housing in the parish
In comparing different housing allocation scenarios, the Council looked at different numbers of houses for the various parishes. In many cases these varied significantly.
eg
Southbourne Min 250 Max 1250
East Wittering Min 0 Max 750
Selsey Min 0 Max 750
Fishbourne Min 250 Max 1000
Bosham Min 250 Max 700
Hunston Min 0 Max 1000

Hambrook Min 500 Max 750

Unlike other parishes, it did not consider scenarios requiring fewer than 500 houses in Hambrook, setting it apart from these other parishes.

Sustainability - the evidence
In considering the proposed parish allocation, the evidence of the Council's Sustainability Assessment says
"The scale of the development will completely alter the existing development.
There would be significant impact to the existing historic village"

This is a substantial change of policy from the previous Local Plan where 25 homes was the indicative housing number for Hambrook. This policy change came very much out of the blue. In fact Chidham & Hambrook accommodated 130 homes under the previous local plan despite the Local Plan indicative number, mainly because the delayed Local Plan allowed developers unfettered rights to develop (before the Local Plan and NP were adopted).
How suitable is Hambrook?
The distance to the nearest town centre (Emsworth or Chichester) is further for Hambrook residents than for other nearby parishes.

Of 31 categories of sustainability,
Hambrook is judged inferior for development compared with Fishbourne (for example) in 7 categories

The categories where Hambrook is less suitable for development than Fishbourne are
"Does the option..."
reduce levels of water pollution?
reduce the need to travel?
improve networks for cyclists and pedestrians?
meet local housing needs?
provide access to services and facilities?
ensure that economic opportunities are accessible to all?
avoid the loss of the Best and Most Versatile agricultural land?

and superior in only one category -
Does the option require new waste water treatment capacity? (It is not clear how this distinction has been made. On the face of it the judgement could well be neutral.)

In the Council's preferred option:
Fishbourne is asked to supply 250 homes, compared to Hambrook which is asked to supply 500.

2 Other sustainability issues -

Landscape. Policy S26 refers

The views of the Downs from the area of the Bus stop on the A259 near Broad Rd looking northeast past Flat Farm have been omitted from the Landscape Capacity Study 2018, East West Corridor, Fig 84 (p507)


The views of the Downs from the area of the Bus stop on the A259 near Broad Rd looking northeast

However the area is judged to have Medium/Low capacity for Landscape change. The view northwards from between Broad Road and towards Drift lane towards the South Downs makes a considerable contribution to the local landscape, but in the HELAA study this is land considered to be suitable for development.
Wildlife Corridor Policy S29, S30, DM 32 refer
Located between the SDNP and the Chidham peninsula and Chichester Harbour, the wildlife corridor through Hambrook linking important Green Infrastrucure, is of special sensitivity.
A variety of species commute or forage between the harbour area and the SDNP including mammals, both deer, and bats of which 10 or more species have been recorded. Badgers, while not normally found on the peninsula, have been seen. Smaller species like Hedgehogs, stoats, weasel, moles, and small prey species, and slowworms, toads and frogs use the corridors to extend their access to foraging habitat. Birds including tawny and barn owls, grey heron and migrant species such as Fieldfare and Redwing use these corridors. Development in Hambrook should be constrained by proximity to the wildlife corridor identified by CDC.
Furthermore there is an important wildlife corridor on the west side of Hambrook, running north south, following the Ham stream.
By comparison, the Wildlife corridor in Fishbourne is away from the development area.


3 The Capacity of Preferred Sites The current HELAA study and Policy DM3 refer

CDC may have underestimated the land required to meet the parish housing allocation.
The proposed allocation of 500 houses is linked to the HELAA study which shows preferred sites in the parish of 15 hectares with a capacity for 565 houses.
However this capacity calculation is based on developer estimates.

The Local Plan Preferred Option policy DM3 indicates a density benchmark of 35 houses/hectare but with exceptions eg
"locations adjacent to sensitive locations (i.e. nationally designated areas of landscape, historic environment or nature conservation protection) where a lower density may be appropriate."

A lower density is appropriate in Chidham & Hambrook because of its semi-rural character, the existing low density nature of development in the parish, the desire to provide green space and landscape views, the perceived need for Bungalows for the ageing population, and the proximity of the Chichester Harbour AONB.
The CDC benchmarks mentioned in the HELAA study (a 'living document') which identifies available sites are:
housing densities (30/ha) and developable areas (80%)
This would mean the preferred sites identified would be adequate for 360 houses. That is, the preferred sites identified by the Council are inadequate to provide the parish allocation of houses.
It is not clear how much land the Council anticipate will be required to meet the allocation of 500 homes, or how, or on what basis this figure was finalised.

If this allocation stands, preferred sites (15Ha) will be inadequate. A further 6 Ha of sites, rejected in the HELAA study, may have to be developed. So the impact on Chidham and Hambrook will be greater than envisaged in the Local Plan preferred option.

4 Conclusion
The allocation of 500 homes for Hambrook is excessive, and is not supported by the Council's Sustainability Appraisal. The low provision of amenities, the proximity of the AONB and Wildlife Corridors, limits the development capacity of the land. The HELAA report suggests there is land suitable for development, but the report appears to have misjudged the suitability and capacity of the preferred sites. We are confronted with choosing not just all the preferred sites but in addition, some unsuitable sites and unsuitable housing densities to provide for the houses required by the plan.

From experience we know that housing development comes at the front end of the plan development period, making absorption of these numbers especially problematic. Equally we know that promised amenities frequently do not materialise as envisaged, if at all.
If we build 500 homes in Hambrook, the number of homes in the village since 2010 will have effectively doubled, reducing the openness of the landscape increasing congestion of local roads and schools, and putting pressure on biodiversity and the green spaces that we do have, with little benefit for residents.

"The scale of the development will completely alter the existing development. There would be significant impact to the existing historic village"

Submission in support of policy S30
Biodiversity is essential to the AONB, and the SDNP. Without it they are diminished, as are we. The enjoyment of wildlife is an important part of the life of many residents, and on many levels vital to our wellbeing.
Biodiversity requires suitable habitat, either of a suitable size, or connected to other areas of habitat by a corridor of suitable width that allows wildlife to move from one area to another either to forage or to breed. With the continuous pressure on land, corridors are vital. Habitat that is cut off, and too small by itself to support the natural diversity of life will die. If it is connected to another patch of habitat allowing movement between the two, the habitat may be large enough to support the natural diversity and genetic diversity which is vital to species survival.
Similarly corridors between the SDNP and the Harbour AONB are similarly important for creatures that need to move further as part of their natural cycle of life or in order to forage or breed.

The combination of distant views, landscape, wildlife and biodiversity, habitat, and corridors is vital to our mental and physical wellbeing. It is also vital to the economy of the region. It is why people come to live here. It is why visitors come.

Chichester District is home to a wide variety of wildlife and habitats. To maintain healthy and vibrant wildlife, we need robust corridors so species can utilise them to travel between their habitats.
A particular example is the rare bats that we are blessed with. They need established corridors to move from roosts to foraging areas. Roosts and foraging areas change with the seasons. Bats flying in the dark need established navigational corridors such as hedgerows. They need darkness. If these corridors are disrupted by development we will lose our rare bats. A corridor can be broken by grubbing up part of a hedgerow, or by the proximity of bright lights, or by reducing its width.

Policy S30 must be supported. It is vital that it is enforced robustly. It is not adequate to assume that we need only worry about the identified corridors. There are more corridors than have been identified so far, and every development should be designed to allow it to act as a corridor, as far as possible.

I urge the planners to ensure the proposed Wildlife Corridors are given the due protection, and importance they deserve, and proper consideration to strengthening the policy by identifying additional corridors.

Characteristics of the Plan Area: a spatial portrait
The term East-West Corridor used with in regard to west of the City of Chichester is ill defined and the use of this term implies the focus of policy is on transport and through movement to the detriment of a more balanced focus on local settlement, existing residential, local countryside and amenity issues.
There is a lack of vision, clarity and coherence of planning policy towards the Bourne Villages, their
character and the surrounding countryside that lies between the South Downs AONB and Chichester
Harbour AONB

Policy S2 Settlement Hierarchy
Object
Chidham & Hambrook, among the other Bourne villages, is characterised as a 'service village' with no definition or explanation of what this means. This term does not reflect the special and unique character of any of these areas, it designates them as no more than utilitarian dormitory communities.
"The largest level of growth is expected in the service villages and settlement hubs, able to accommodate higher levels of growth without adversely impacting the character of the settlement". An increase in growth of housing stock by 55% will undoubtedly negatively impact Chidham & Hambrook.

Policy S3 development Strategy
We believe the rationale for how the number of 500 dwellings for Chidham & Hambrook was arrived at to be wanting and the supplementary evidence to be inconsistent and contradictory. Figures in the 2018 HELAA report suggest that there is available land from achievable sites for 565 new dwellings. This is a completely unrealistic expectation. If these are assessed against the suggested CDC figure of 30- 35 per hectare and 80% developable this gives a total of 360 - 420. The figures seem to be almost entirely based on projections put forward by promoters. Consequently, we were told to put a call out for additional sites. Several of those that have come forward are on sites previously rejected by CDC on the grounds of impact on the AONB, significant access constraints, adverse impact on the landscape and detachment from the settlement boundary.
The Sustainability Appraisal sets out to select numbers in the Potential Distribution Strategies. Assuming a figure of 650 pa, across Chichester District, the predicted numbers for Chidham & Hambrook stay within a narrow range of 500-750, whereas other Parishes fluctuate widely eg Fishbourne 250-1000, Hunston 0-1000.Unlike other parishes, it did not consider a figure of less than 500 for Hambrook.
The Strategic Development Location Assessments seek to assess each district against sustainability criteria. Chidham & Hambrook has been scored with 11 negative and 7 neutral with only 12 positive.
We agree with your judgements with the following additions:
1a in addition to the bat population North of Priors Leaze Lane the Ham Brook is home to water voles.
4b This is a significant constraint. Without adequate public transport and no local facilities or services this will put considerable strain on both the A259 and A27 at both Emsworth and Fishbourne.
5a There is considerable risk of surface water flooding on a number of identified sites.
6a This should be a negative score. To speculate that Southern Rail might increase the service is no justification for assuming a shift to sustainable transport. The hourly service east and west is not adequate for commuters.
9 This should be a negative. There are no local shops apart from a very small and poorly stocked Post Office, which has erratic opening hours, and a charity shop. This doesn't constitute some shops. There are no medical facilities, sports facilities or recreation ground.
10a-12b There are extremely limited employment opportunities in Chidham & Hambrook so difficult to see how any of these would apply.
13a The Local Plan diminishes our rural economy by taking farmland and nurseries for development
13b We have high quality Grade 1 and Grade 2 agricultural land .
We believe these judgements demonstrate that Chidham & Hambrook is less suitable for large scale housing numbers than other areas.


Policy S12 Infrastructure Provision
Infrastructure Delivery Plan
This gives us no confidence that the development of 500 homes in Chidham & Hambrook will give us the infrastructure we need at the time it is required.
Despite the rapid growth in housing numbers over the last five years there has been little infrastructure development. We have no medical centre, local convenience store, employment opportunities, early years or child care provision ,sports or recreational facilities.
Transport: there is no mention of any upgrades to any of the roads or junctions serving the Parish to alleviate congestion and to improve safety. There is no mention of cycling routes and walking provision to provide safe routes. This will be exacerbated by the 1,110+ homes proposed in the Southbourne Parish which will have a coalescent impact on Chidham & Hambrook, particularly Priors Lease Lane and Broad Road.
Education: the suggestion here is that Chidham & Hambrook will be contributing funding to a new school in Southbourne rather than a replacement school in Policy AL10. This represents yet another contradiction. It is unclear where or at which development Early Years and Child Care places would be accommodated.
Health: The nearest provision would be Southbourne

Policy S8 Employment
Object
7.1 Part Two Development Management states " place housing in locations which are accessible by public transport to jobs, shopping, leisure, education and health facilities."
There are limited employment opportunities in Chidham & Hambrook and it appears there is no demand for commercial premises in the area. Industrial units built by Taylor Wimpey on the Lion Park development were not taken up and consequently converted to housing. In the last few years three employment opportunities have closed down to be replaced by housing - two garages which sold, serviced and repaired vehicles, one of which sold petrol and a small stock of essentials, and a plant nursery. This will put an added pressure on traffic as more people drive to their areas of employment west or east using the A259. Public transport is limited and expensive.





Policy S23 Transport /DM8
Object
In Chidham & Hambrook the vast majority (80%) of the proposed new dwellings would be built off Broad Road and some sited on the adjoining Main Road, the A259. There is no provision for the road infrastructure impact of 2250 new homes along this road between Southbourne and Fishbourne. And this will impact the travel survey.
Currently Broad Road has significant safety issues for pedestrians, drivers and cyclists. There is limited visibility due to lack of off-road parking facilities for current residents which has resulted in a number of near accidents. Where it meets the A 259 there is a staggered junction with Cot Lane which, even at present, is difficult to negotiate. The combination of new housing leading to increased traffic in Broad Road and the potential significant volume of increased traffic coming from the 1100+ new dwellings in Southbourne will make this junction dangerous and untenable.
To the North of the Parish there will be increased traffic on the Common Road to Funtington and then the B2178 as a route into the city. Opportunities for any access to housing developments without using Broad Road or Main Road are extremely limited. All other roads in the Parish are essentially lanes, mostly restricted to single lane traffic and could not be used as access to developments.
Pedestrian access in Broad Road is very poor with footways in places too narrow to accommodate buggies, wheel chairs or motorised disabled scooters. As a consequence residents are heavily reliant on cars.

The added volume of traffic will cause significant congestion and decreased air quality. Accessing the A27 at Fishbourne will be further exacerbated by the lack of plans to introduce an additional junction and slip roads onto the A27 between Emsworth and Fishbourne, and for no right turns from the Stockbridge and Whyke roundabouts. The only suggested mitigation is to create a hamburger junction. The increased commuter traffic combined with beach traffic in good weather, will cause gridlock at this roundabout at every junction.
We object to the proposal to build a link road to Birdham which would go straight through a flood plain and a site of environmental significance and would have a negative impact on the views from the coast to the City and SDNP.
Public transport is limited to one bus service along the A259 and an hourly train in either direction from Nutbourne station. The bus is very expensive and the vast majority of passengers are those with bus passes. There is no bus service south to north. The train frequency is too limited as a viable alternative to car travel. We would like to see a more robust policy focussing on public transport links.

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 and be coordinated with WSCC with the goal of introducing high quality and separated cycle links between the villages along the A259 and Chichester.

CDC together with WSCC Highways should undertake to provide specialist advice to those Parish Councils chosen to implement proposed strategic housing allocations through Neighbourhood Plans along the A259 in order to assess the impacts of the scale of such allocations on the local highway network. Such advice should be provided in order to aid site selection prior to any master planning of the subsequent development proposal and to help find solutions to potential traffic problems





Policy S6 Affordable Housing
Support
There is a disproportionate number of detached and 4 bed houses currently in our housing stock. We would like to see a commitment for Social Housing in addition to Affordable Housing, which many local people cannot afford to rent or buy. This means many young people leave the area. There is too much flexibility given to developers here in delivering the housing need for the area. They must deliver their "affordable" requirement if sufficient housing to meet local needs is to be provided.

Policy DM 2 Housing Mix
Support
As above we have a high number of 4+ bed and detached homes. Young, low income and single households are being priced out of their neighbourhoods.

Policy DM3 Housing Density
Support
Specialist housing and housing for the elderly will require a lower density as it will be single story. It is essential that there are robust measures that will enable high quality homes to be built to enable elderly people to remain in their community should they need to move into adapted housing more appropriate to their needs. Similarly, life long homes for those with a disability who need specialist housing.

Policy S26 / DM19 Natural Environment
Object
The Spatial Vision and Strategic Objectives 3.6 states that any development west of the city will
" conserve and enhance the local distinctiveness, character and cohesion of existing settlements".
The Sustainability Appraisal states, in relation to Chidham and Hambrook " The scale of the development will completely alter the existing development and there will be significant impact to the existing historic village" These two statements are contradictory .
The magnitude of an additional 500 homes {growth of 55%) will patently alter the local distinctiveness and character of Chidham & Hambrook and risk coalescence with Southbourne. The landscape is characterised by extensive arable land with some nurseries and pasture. Hedges, bushes, orchards and groups of trees contribute to the landscape, as do streams which pass through the Parish. The South Downs National Park is to the North and the AONB of Chichester Harbour to the South.
The CDC Landscape Capability Study reinforces the detrimental effect development will have on the landscape and character in all areas within the Parish
Nutbourne East - Ham Brook Mosaic
Potential development is said to impact on:
valued views, visual corridor for views from Nutbourne Channel towards the SDNP, separation of Southbourne, Hambrook, Nutbourne East, the rural landscape setting, existing pattern of low density settlement.
It will also contribute to the loss of:
Pasture, arable fields, hedgerows, trees, woodland (ancient and semi natural) copses. The area is constrained by its remaining rural character.
Nutbourne West-Nutbourne East Coastal Plain
Potential development will impact on:
valued views, characteristics views to the harbour and the SDNP, views from the AONB and nearby peninsulas: wider separation between Nutbourne West and Nutbourne East, the rural landscape setting,of the AONB, the existing pattern of low density settlement, the well treed landscape setting.
It will also contribute to the loss of:
Pasture, arable fields, hedgerows, trees, woodland copses, characteristic landscape field patterns. The area is constrained by its rural and treed character which contributes to the open setting and character of the AONB.
Upper Chidham Coastal Plain
Potential development will impact on:
Valued views- to the harbour, hills of the SDNP, Bosham Church, setting of Nutbourne Channel and Bosham Harbour, setting of listed buildings, strong rural and tranquil character, views from the SDNP.
Contribute to the loss of:
Arable and paddock fields, hedgerows, trees, tree belts, patches of coastal grassland and wetland, characteristic landscape field patterns.
The area is constrained by its rural and tranquil character, the visually sensitive open large scale fields, its contribution to the open, rural setting of the settlements of Chidham, Nutbourne East and West and their wider separation and its contribution to the wider AONB landscape, including the setting of Nutbourne Channel and Bosham.
Nutbourne East North - Eastern Coastal Plain
Potential development will impact on:
Valued views, rural character, separation between Hambrook and Nutbourne East, semi enclosed and more open character,
Contribute to the loss of: pasture and arable fields, hedgerows, trees, and characteristic field patterns
Nutbourne East Nurseries
Potential development will impact on:
Valued views, characteristic views to the Harbour and SDNP, rural character, separation between Bosham and Nutbourne East, semi enclosed and more open character, the pockets of orchards and small copses.
Contribute to the loss of: pasture and arable fields, hedgerows, trees, and characteristic field patterns

There are clearly significant constraints on the landscape and character if large scale development were to take place in Chidham & Hambrook. The principles in the AONB Management Plan must be rigorously applied to any new developments.

Policy S29, S30, DM 32 Wildlife Corridor
Support
We welcome a specific Policy on wild life corridors located between the SDNP, the Chidham peninsula and Chichester Harbour. The Chidham / East Nutbourne wild life corridor linking important Green Infrastructure, is of special sensitivity.
A variety of species commute or forage between the harbour area and the SDNP including mammals, both deer and bats, of which 10 or more species have been recorded. Badgers, while not normally found on the peninsula, have been seen. Smaller species like Hedgehogs, stoats, weasel, moles, and small prey species, including tawny and barn owls, grey heron and migrant species such as Fieldfare and Redwing use these corridors .
The Ham Brook follows a natural environmental course from the AONB to the SDNP. This natural water course is home to water voles (seen by CDC Wildlife Officer and local environmental volunteers as recently
as January 2019) and the land north of Priors Leaze Lane is a Barn Owl Habitat.There is ancient woodland either side of the railway line next to the trout farm and this is a dormouse habitat too. Development in this area should be constrained by proximity to the wildlife corridor identified by CDC.




AL10/SA10 Chidham & Hambrook
Object
In 2014 at the last iteration of the Neighbourhood Plan there were 850 households in the Parish of Chidham and Hambrook. By the time the new Local Plan is published there will have been an increase in the number of properties in the region of 150 to a total of 1003 in the Parish, an 18% increase. The previous Local Plan had set a target increase of 25 houses. Whilst absorbing this number of properties there have been no changes to the infrastructure and services in the area to support the additional population apart from a charity shop and expansion of the Primary School which is now at capacity and has been for the last year. The new Local Plan requires us to accept a further minimum of 500 properties. This will increase our local housing stock by 50% and will undoubtedly increase the population area by a greater percentage given the age demographic of the area.
6.68 states that" opportunities to relocate and expand the school to two form entry will be sought.". We note that there are similar plans for a relocated and expanded school in Bosham with a site allocated for that purpose, in addition to a new school in Southbourne. Discussions with WSCC have made it clear they would not support the creation of two new schools in such close proximity. It is therefore nonsensical to suggest these two schools could be realised. WSCC data does not support it. Their calculations for schools are based on 210 Primary children for 1000 homes so patently 750 homes would not meet support for two 2 form entry schools. However, the current school is at capacity and cannot on its current site be expanded. If a school project is not forwarded in Chidham & Hambrook the additional children coming from 500 homes would need to travel to Bosham or Southbourne to attend school, along with children from 1100+ homes proposed in Southbourne. There needs to be some clarity and certainty on which of these proposed schools can be achieved and how they would be funded. We find it extraordinary that there is no policy statement on Education.


The Parish Council fully acknowledges that it has a responsibility to contribute to the need for more new housing in the District. However, in view of the above, and having carefully scrutinised the evidence, we believe that 500 homes for Chidham & Hambrook is excessive and is not supported by the documentation. The low provision of amenities, the absence of planned sustainable transport, the proximity of the AONB, the sensitive nature of the landscape and the density of housing proposed, limits the development capacity of the land.
For the reasons given we would like this number significantly reduced by at least 50% in line with Bosham and Fishbourne.

Hunston Parish Council is writing to object to the Chichester Local Plan Review 2035 Preferred Approach - December 2018 with the following issues:

Housing Allocation:

Policy AL11 states that:

Land will be allocated for development in the Hunston Neighbourhood Plan for a minimum of 200 dwellings, including any amendments to the settlement boundary.

We would strongly suggest that the wording above should be changed for "a minimum of 200 dwellings" to "a maximum of 200 dwellings". Failing that, to change the wording to: "about 200 dwellings".

We do this on the grounds that there is uncertainty about the identified sites and their capacity to deliver 200 dwellings is not proven. There are issues concerning flood risk and threats to Ancient Woodland (Hunston Copse). Additionally, Section 4.121 The Manhood Peninsula of the Local Plan states that:

Environmental designations cover, or impact on, most of the Peninsula, including the Chichester and Pagham Harbours SAC/SPA/Ramsar sites, the Chichester Harbour AONB and the Medmerry realignment

Whilst we understand that the continuing lack of resolution to the problem of the A27 is not within CDC's control. We believe that the likelihood of increased air pollution caused by the cars associated with 200 new dwellings, when they reach the roundabout north of Hunston where the B2166 and B2145 meet and then onto the A27 must be taken into account.


The Planning Process:

1. The Housing Economic Needs Availability Assessment (HELAA) published in August 2018, allocated 176 houses to Hunston and 375 to Mundham. In October, CDC planners announce that 200 houses will be allocated to Hunston and 50 to Mundham. This reversal of the HELAA, with no rationale given is unacceptable.

2. The Sustainability Appraisal of the Site Allocation: DPD January 2018 states that there "are multiple options for Hunston - for a relatively small amount of housing to meet a local housing need". The local housing need is 22, with 14 in Bands A - C.

3. The CDC Landscape Capacity Study November 2018 identifies at section CH30 that sub-area CH30 is medium capacity but it is recommended that only a small amount of development may be accommodated around the existing settlement and provided it is informed by further landscape and visual impact assessment and sensitively integrated into the landscape. Once again what has changed? The development on land proposed by the Church Commissioners is not a small development.

Housing:

1. Hunston is a semi-rural village, increasing its size by 35% would change its identity to a dormitory for Chichester.

2. The suggested sites are currently arable land, used both for grazing cattle and crop production. UKs environmental footprint is already 2.4 times it's land area. We can only produce enough food for about 60% of our population.

https://www.gov.uk/government/publications/food-statistics-pocketbook-2017/food-statistics-in-your-pocket-2017-global-and-uk-supply

3. Using green field sites is not only detrimental to the village, it is also detrimental to the county and the country.

4. The size of this development on CDC's preferred sites would result in creep towards joining Hunston to Mundham and then Hunston to Chichester. This is social engineering, which will overcrowd the already overcrowded area.

Traffic:

1. The problem of the A27 remains unresolved at present. Currently it is increasingly grid-locked and access from the B2145 becomes more and more difficult.

2. Building 250 houses in Selsey, 200 houses in Hunston and 400 houses in Pagham will result in around 1700 more cars using the B2166 from Pagham and the B2145 from Selsey.

3. At present, the B2145 is the fourth busiest B-road in the UK. How can planners contemplate adding 900 cars to the B2145 and 800 cars to the B2166, all meeting at the roundabout north of Hunston?

4. The population of the Manhood Peninsula doubles in the summer, the current road infrastructure cannot cope, building more houses will result in permanent traffic jams and increased pollution

5. Local Plan P.130 states that the following should be considered: "Providing adequate mitigation for potential off-site traffic impacts upon the B2145". As CDC seem to have no effective engagement with Highways, and no recognition of the traffic pressures on Hunston, this seems like wishful thinking.

6. Chichester Free School has created serious traffic problems in the afternoons, when children are being collected. Adding 1700 cars will mean traffic becoming increasingly delayed along the A27 as well as the B2166 and B2145

Air Pollution:

1. This increase in traffic and housing will result in increased air pollution, damaging people's health and breaking environmental guidelines

Infrastructure:

1. Parts of Hunston are already in a Flood Risk Area. The water table is high and 200 more houses will only increase the flooding risk.

2. There are no indications that the current sewage, drainage and water utilities will be able to cope with this development

Services - Schools:

1. Currently Mundham, Sidlesham and Chichester Free School are full at entry level. The Free School has a county wide catchment, so there is no guarantee of places for any children from the new housing proposal. As a result, children will need to be driven to schools further away, resulting in yet more traffic problems

Medical Services:

2. There are two GP surgeries on the Manhood Peninsula, one in Selsey and one in Witterings. All residents in Hunston use GP surgeries in Chichester. Where will 200 new families register?

Sustainability

The Chichester Local Plan Review - Sustainability Appraisal - October 2018 lists the following: http://www.chichester.gov.uk/CHttpHandler.ashx?id=30955

1A Does the option prevent biodiversity loss and habit fragmentation?
Within the zone of influence for Pagham and Chichester Harbour. Close to the Canal and Hunston Copse SNCIs. Potential impact on components of ecological networks.

3A Does the option reduce air pollution from industrial processes and transport?
Added congestion on the A27 likely to have negative impact on air quality

3D Does the option require new Waste Water Treatment capacity?
Negative impact until WWTW is upgraded or new capacity is found

5A Does the option reduce the risks of coastal, fluvial surface water and groundwater flooding?
Sites to the South East of Hunston likely to increase flood risk and other potential sites located close to flood-zones

6C Does the option reduce congestion?
Likely to add to congestion on A27

7A Does the option encourage sustainable land management practices to conserve landscapes?
Local impact is likely to be significant

7B Does the option ensure protection of traditional urban forms?
Negative impact on village form.

7C Does the option ensure conservation and enhancement of the historic environment, heritage assets and their settings?
Potential negative impact on the Archaeological Priority Area

13B Does the option avoid the loss of the Best and Most Versatile agricultural land?
Potential loss of Grade 2 agricultural land. However, some options for developing Grade 3 land.

It would appear that the Local Plan proposal for 200 houses is completely ignoring all of the above.

Environment: Ancient Woodland:

1. The Local Plan on P.130 states that the following should be considered: "Protecting existing views and particularly those of Chichester Cathedral spire and Hunston Copse"

2. Current residents of Southover Way and Meadow Close will lose their existing views of Hunston Copse with the proposed new housing.

3. The proposed 15 metre margin to protect Hunston Copse is woefully inadequate

Environment: Wildlife

1. Hunston Copse and surrounding fields support a wide range of wildlife from water voles, adders, grass snakes and slow worms to hares, deer, foxes. People move to Hunston for green spaces, not to have them taken away.

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Full detailed submission for the Local Plan and supporting evidence is attached.

The representations attached to this submission reflect a high level summary of the detailed submission and do not contain the full level of detail received.

High level comments received:

a. The transport study conducted by Peter Brett Associates (PBA) is not fit for purpose and needs to be rewritten. The scope set for PBA is far too constraining and counters the democratic process agreed by the council to seek alternative routes.

b. Many of the documents are inconsistent and in their current form smack of inconsistency and bias. Reasons for excluding some strategic sites are not consistently used for other sites.

c. Many of the evidence documents are not present or are not complete for this consultation. These will need to be re consulted when they are complete.

d. CDC should not be accepting the unmet housing need from the South Downs National Park (SDNP). They should also be going back to government to insist that until certainty is provided on the A27 this area can not accommodate future housing and or employment space.

e. The proposed link road was resoundly rejected last time it was proposed by Highways England. CDC need to respect the voices that rejected what is option 2 by stealth. Particularly as the PBA report states that the building of the link road will offer other "strategic options". This will not be tolerated locally.

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Site AL7 : I object to the sole inclusion of High Grove Farm for the proposed allocation of 250 additional houses in Bosham Parish.
The Bosham Neighbourhood Plan clearly states that residents would prefer housing to be sited over a number of sites and to avoid development if at all possible to the East or West. CDC's own sustainability assessment on the sites in Bosham demonstrated that the French Gardens site could take some of the housing allocated to the parish. As the site is in direct view of the SDNP and AONB the density should be kept to a minimum especially given the needs for balancing ponds, a school, allotments, play areas and so on. Therefore the housing should be split between High Grove and French Gardens Site which would help alleviate many of the constraints that are currently identified at High Grove site such as flooding, setting, density, traffic and so on. The French Gardens site was the site most favoured by residents outside of the AONB during the Neighbourhood Plan site allocation consultation (and that was for 150 houses).
I would also like to add that the whole French Gardens site is still available as defined in the 2016 SHLAA despite it not being included in the recent HELAA in its entirety if more housing was required or if the Policy direction changed in Favour of more EW corridor housing.
The French Gardens site is the only site adjacent to a railway station in the District and therefore has the lowest transport impact. It is therefore supported by Policy 1 in favour of sustainability. The fact that the owners would like to build Zero Carbon housing has not been included in the sustainability assessment. A small allocation would be well screened by existing vegetation and it also has existing access and a footpath to the village.