Policy NE16 Water Management and Water Quality

Chichester harbour must be protected and extra use of Apuldram WwTW avoided.

There should be a moratorium on any building in the area until there is a strategy for dealing with wastewater.

Southern Water calculates its capacity calculations based on dry water flows of water and not average yearly levels but even with this data which is arguably skewed in favour of development. Southern Water have confirmed there is not capacity for the number of dwellings proposed in policy A11

This issue then brings the proposed development of Policy A11 into direct conflict with other areas of the proposed local plan.

One of the objectives stated in the proposed plan is to:

“Protect and enhance the character of the area including the Chichester Harbour Area of Outstanding Natural Beauty (AONB), the coastline and the setting of the South Downs National Park;”

Allowing any development which will have an adverse impact on Chichester Harbour by exacerbating the sewage outflow levels cannot be deemed to be protecting or enhancing Chichester Harbour.

The harbour is designated as both an AONB and a site of special scientific interest. It is afforded the highest status of protection under the National Planning Policy Framework. The local plan itself suggests that the site at A11 is not suitable.

Developments should be refused until Southern Water has upgraded its treatment plants so that it has the capacity to treat additional sewage.

Development proposals should include an assessment of the extra sewage that would have to be treated by Southern Water given that it struggles to handle existing levels.

Remove policy A11 from the local plan.
Cut the number of houses allocated in the plan to from the 10,354 proposed to 2,699.

Chichester District Council are under a statutory duty to protect Chichester Harbour. The housing proposed in this plan will have an adverse effect on the quality of the water bodies. Southern Water are not able to cope with the level of wastewater generated in the district. For Policy A11 Southern Water have stated they do not have the capacity for the number of houses proposed. The water quality and wastewater part of this policy will not be complied with if these houses are built.

With respect to Wisborough Green Water Quality and Waste Water...
a) There will be adverse impact from additional sewage spilling into adjacent water bodies and groundwater.
b) Additional sewage spilling will adversely affect surface and ground water quality.
d) Significant wastewater infrastructure improvement is required to properly cope with the current load. As per this Policy, additional housing development must align with the infrastructure development.

A moratorium on house building until wastewater and A27 road infrastructure upgrades are guaranteed and carried out.

I am emailing as a member of the public who has been invited to make comments on the proposed new Chichester District Council Local Plan.
Firstly, I have been invited to comment on whether the plan is legally compliant. With this in mind, I would question whether it is. I am aware that there is legislation which is designed to protect Chichester Harbour, namely, I believe, the Chichester Harbour Conservancy Act 1971. This legislation gives the Harbour Conservancy a duty to conserve, maintain and improve the harbour. In the proposed local plan it states:
“4.120. In February 2018 the Chichester Harbour designated Site of Special Scientific Interest (SSSI) was downgraded from ‘Unfavourable – recovering’ to ‘Unfavourable – no change’. Further assessment during 2019/20 found that more than 3000ha of the intertidal parts of Chichester Harbour were now ‘Unfavourable – declining’. A specific policy is therefore required to address this issue. Nitrates finding their way into the Harbour (from a variety of sources) cause algal growth which is harmful to wildlife. Although the proportion of total nitrogen originating from new development is very small, it is important that this source is addressed whilst other measures, such as catchment management, are undertaken to reduce other inputs and recover wildlife.”
Concerning nitrate mitigation, I note that the South Downs National Park Authority (SDNPA) are not able to
guarantee any further land to offset nitrates and this will impact the number of houses which can be built in the
area. The SDNPA has made this clear in the letter they have submitted in consultation regarding Policy A11
(attached). There are, I believe, several proposed sites in the local plan which will need to be able to show they have nutrient neutrality and at present, they cannot do this. With this in mind, I suggest that it would be wrong to
propose the site referred to in Policy A11 and any other sites where this matter applies.
In addition to the issue of nitrates, there is also the issue of water pollution which is blighting the harbour. Building
over 10,000 new houses in the district is going to exacerbate both nitrate and wastewater pollution. A study by Chichester Clean Harbours Partnership (attached) shows that at five sites which were tested within Chichester Harbour, all failed tests for E.coli and Feral Streptococci levels which suggests water quality in the harbour is being impacted by the constant outflows of sewage which are happening across the thirteen outlets which Southern Water control and discharge directly into the harbour. Last year’s data shows that Southern Water spent over 19% of the year releasing untreated sewage into the Chichester Harbour waters. This is evidence that Southern Water is either unable or unwilling to cope with treating the wastewater generated by the housing in the district so to propose 10,000 further houses with no guaranteed upgrades to the wastewater treatment seems ludicrous and a dereliction of the statutory legislation designed to protect the harbour. For these reasons I would question whether the plan can be judged as legally compliant.
The second area I have been invited to consider is whether the proposed plan is ‘sound’. To this, I would suggest that there are so many contradictions between what the plan proposes and what is found in the National Planning Policy Framework (NPPF), other consultation documentation and the plan itself that I believe the plan cannot be found to be sound. As an example two examples referred to above:
Allowing building to go ahead on land without being able to guarantee nitrate offset brings the plan into conflict
with itself. (Policies NE12, NE13, NE19)
To allow building to go ahead which is guaranteed to increase sewage outflow into the harbour brings the plan into conflict with itself. (Policies NE12, NE13, NE16, NE17)
The focus of most of the plan seems to be on providing housing. However, the NPPF makes it clear that house
building needs to be sustainable and include infrastructure in order to meet the economic objective and that there is an environmental objective to be considered both of which I do not believe this plan is meeting.
The proposed local plan does not include any guaranteed upgrades to the strategic road network but does refer to
the fact that the congestion on the roads is a major concern for the residents of the Chichester District. (Proposed Local Plan Point 8.3) I am aware that the strategic road network is an issue outside of the Council’s control but again, to propose adding 10,000 plus housing to the area when they are aware of the serious congestion problem seems nonsensical, especially now in the light of the government removing mandatory house building targets.
The main issue the Chichester District seems to have is that within the boundary, there is a large percentage of land which is protected from development as SDNP and AONB land. What this plan seems to be doing is trying to cram 90% of the original government-proposed allocation of housing into 23% of the land in the district. It stands to
reason that this will have a detrimental impact on the road network. In addition, Chichester District Council are
aware that the major junctions on the A27 have been operating at capacity since the last local plan was written and in their transport assessment published in January 2023, they have made reference to the major junctions now all operating well over capacity (CDC Local Plan Transport Assessment 2039 Point 11.2.1) and have made reference to the fact that there has been no mitigation which was proposed in the previous local plan to most of the junctions (CDC Local Plan Transport Assessment 2039 Point 1.3.2). Therefore building more housing without guaranteed upgrades to the road network would seem both unfair to the residents and businesses who are already suffering the daily challenge of congestion and unethical in the light of the plan which contains several policies referring to minimising the climate crisis, reducing pollution and only allowing development which does not exacerbate congestion and road use. Once again this brings the plan into conflict with itself because the additional congestion is
going to impact both pollution in general and air pollution specifically (Policies NE20, NE22)
The NPPF suggests that there is a presumption in favour of sustainable development but I would argue that trying to fit too many houses into a small, already over-congested area, is not sustainable and does nothing to enhance the lives of people who already live in the area. Of the three objectives in the NPPF (economic, social and environmental) this plan only seems to address the social objective of providing more housing. It does not address the economic objective because of the strain building 10,000 further houses will create on already weak infrastructure. More importantly, it does nothing to address the environmental objective because it will increase pollution and exacerbate problems with the sewage network and the road network which already exist.
In conclusion, with reference to whether the plan is sound, I do not believe it can be judged as sound because, aside from contradicting itself and not fulfilling the objectives outlined in the NPPF as I have highlighted above, the plan is not taking into account local people’s wishes. There have been several action groups set up and demonstrations against further building in the area on the large-scale proposed here. Neighbourhood Plans have been completely disregarded and people in the area have genuine concerns about the impact of pollution on the harbour, the relentless building with no additional infrastructure and the detrimental impact of building on farmland and the implications for biodiversity and agricultural security as well as coalescence of our villages and strain on already overburdened resources such as doctors, schools and village shops.
I can speak concerning Policy A11 because this directly affects where I live but I will also try to highlight below other policies where I know the proposed sites conflict with what is in the neighbourhood plan and conflict with
statements in the local plan.
Our neighbourhood plan has been ignored and the site proposed was the site deemed least suitable for
development and conflicts with the statements in the local plan in the following ways:
1) The site is greenfield land and there is brownfield land available capable of being used for smaller-scale
development (Burns Shipyard). This would appear to be the case with most of the proposed sites being
greenfield land. (Policies A6, A10, A11, A12 A13 and A14). The NPPF states that where possible preference
should be given to using brownfield land for development before allowing development on Greenfield or
agricultural land.
2) The site is wholly outside of the Bosham settlement boundary which in the plan would define this as the
countryside. The local plan states in Chapter 3, that development in the countryside should be ‘restricted’ to
what is essential and meets the proposed needs as defined by policy NE10. The site chosen does not meet the criteria set in policy NE10 and proposing the site, therefore, puts it into contradiction with the plan.
3) The site proposed for Policy A11 is grade 1 and 2 productive agricultural land. The local plan states that it will seek to protect the best and most versatile agricultural land from large-scale, inappropriate or unsustainable non-agricultural development proposals that are not in accordance with the Development Plan. (Local Plan Point 4.8) However for the sites A1, A12 and A14 this does not seem to be the case. In the case of some of the land proposed from Policy A14, I believe the land has been compulsorily purchased from farmers. A large majority of the land proposed for development in the local plan is viable and productive agricultural land.
4) The site’s overflow wastewater discharges from the Bosham outlet into the Bosham channel. This outlet has
been the most compromised in 2022 and has discharged for the largest amount of hours out of all 13 outlets
that discharge into Chichester Harbour.
5) The site proposed for Policy A11 has no proposed primary school provision. The local village school is at
capacity and is unable to be expanded on its current site because there is no land available. Instead, the children from this proposed development will be expected to go to school outside of the village and this will inevitably lead to more cars on the roads as the proposed schools with places are not accessible by public transport or within walking/cycling distance. Again, this is a theme common to Policy A12.
6) The site proposed in Policy A11 suggests that the land is likely to suffer from groundwater and surface runoff
flooding. The likelihood of flooding is greatest along the western boundary of the site which abuts the existing
development of Brooks Lane. Brooks Lane already suffers periods of flooding. The NPPF says that new
development should not increase the likelihood of flooding at existing developments.
7) The vehicle access to the A259 is via one vehicle access point only, which is likely to exacerbate air pollution at peak times with cars idling to access the A259.
8) The proposed additions to the village will be a fourth community hall, which there is no desire or need for and
no end-user has been identified to maintain, allotments which were specifically proposed at the initial consultation and rejected as the least popular choice of an additional community facility and a mini football
pitch which has been hastily added and squeezed onto the site of inadequate size and with inadequate parking
provision to make it a usable asset.
For all of these reasons, I believe that the proposed local plan cannot be judged to be sound. There were several
hundred objections to Policy A11 and I believe there would be true for most of the sites proposed. Our local
neighbourhood plans have not been taken into account when producing this plan and this is against what is stated in the NPPF which suggests that Neighbourhood Plans give communities the power to develop a shared vision for their area. (NPPF Point 29)
The last area I have been invited to consider is if the proposed local plan meets the duty to co-operate. In this
respect, I feel that the duty to co-operate seems to have been viewed as more a ‘duty to consult’ Whilst there has
arguably been consultation between appropriate bodies and other local authorities, I do not believe the plan
reflects the advice that has been given. Again, coming back to Policy A11 as an example the SDNPA, Chichester Harbour Conservancy, Southern Water and National Highways have all raised reservations about the proposed scale of development and the impact it will have on the Bosham area and local infrastructure. However, the reservations have not been heeded and the proposed development is still much the same as it was at the outset. Again, local plans have been ignored and local voices have not been heard. Whilst I am aware that the duty to co-operate is not a duty to agree, if every aspect of a consultation is ignored, I would argue this can hardly equate to co-operation.
In conclusion, I understand the importance of having a local plan and I understand the constraints that Chichester District Council is under due to the available land infrastructure constraints it faces which are largely outside of its control. However, because of the above, and that they have now been given the freedom to deviate from mandatory government house building targets, I would ask you to pay scrutiny to the number of houses in the proposed plan and recommend to Chichester District Council that they need to go back and rewrite the plan to reduce house building to a sustainable level of 23.5% of the government proposed allocation to reflect the percentage of land which is available in the district for development. I also recommend that there be a moratorium on further development in the district until the issues of water pollution by nitrates and sewage can be addressed and until there are the mitigation measures proposed in the transport assessment to allow for further house building.

Add 'The uncertainty of these constraints, the reduced efficiency of SUDS in such low-lying areas and the current concerns about Chichester Harbour make it unlikely that there would be much further sustainable
Development.'

Add 'The uncertainty of these constraints, the reduced efficiency of SUDS in such low-lying areas and the current concerns about Chichester Harbour make it unlikely that there would be much further sustainable
Development.'

A moratorium on house building in the district until there are guarantees for suitable infrastructure upgrades to the A27 junctions and wastewater treatment.

I have read the plan, all of it, and the biggest thought that comes into my mind is that there appears to be very little promised...
What appears to be guaranteed/promised
Ten thousand odd dwellings squeezed into approximately 20% of the available land space.
What is not guaranteed/promised
No new roads or traffic congestion mitigation. The roads around Chichester and the surrounding areas are at capacity already and have been for some time, (Transport assessment Jan 2023) with the exception of the Covid lockdown period. My business involves engineers driving to visit customers in and around this area are a considerable amount of the working day is wasted in traffic congestion. At not an inconsiderable cost. For example, one of my engineers lives in Bognor Regis and what was a 35-minute journey to work - in Bosham - now takes 60 minutes. 60 minutes. More frequent flooding and closures of roads exacerbate this and the new Free school sited on Hunston Road, has compounded the misery. Of course, these delays that everyone experiences only compound the pollution issue as well. This can only get worse with the additional promised housing in the area. Working in and around the area will be chaos.
No new sewage infrastructure is guaranteed for the foreseeable future.
Chichester Harbour and the streets of Bosham are regularly filled with sewage that overflows whenever there is rain. According to Southern Waters’ own Beach Boy App data, there are regular non-stop discharges of Sewage into Chichester Harbour. There is nothing in the plan to stop this and Southern Water themselves say that they don't have the capacity to deal with the wastewater at present, let alone with another Ten Thousand houses built in the medium term. All the E.Cioli levels in the Harbour are already above acceptable levels as advised by the Environment Agency. Table enclosed - figures supplied by the Clean Harbour Partnership.
Attached is the document that explains this testing
No doctor surgeries
None planned
No new schools for the majority of these new housing developments
So despite the positive language of the Plan, there are no plans to provide any new schools for that area, except for the Tangmere proposed development. So in the absence of such plans, I have to ask where in the area are. I don't know about the availability of school places around the area except for Bosham and Chidham where there are none.
General observations
There don’t appear to be many proposed developments for this housing on Brownfield sites. All the major developments in the area appear to be on Grade 1 and 2 agricultural land. Some of which, i.e. Highgrove Farm, which is outside the settlement boundary, appears against National Planning Policy Guidance and local opinion.
So in conclusion, this Plan appears to be solely a cash-generating exercise by Chichester District Council, with income derived from Section 106/CIL levies and forecasted Council Tax receipts, which gives no apparent regard, or only Lip Service, to the quality of life and areas of natural beauty for the existing residents and proposed new residents. It is not a really well thought out plan, not joined up at all with the needs and requirements of the local and separate Utilities and Government agencies such as Transport.
I am not against new housing generally. I'm sure there is a need for future generations and increased population in the County, But this cannot be allowed without all the other facilities that should come along with new housing. This Plan does not plan for that. If there is no funding available to upgrade these facilities, then I can’t see how it is sensible to allow more new housing on this scale.
Yours sincerely Roger Weymouth
Dear all (Sent local councillors, responses removed)
I’ve looked at some possible “road improvements” notably one just outside Tesco which looks like there will be a possibility of multiway lights and a new junction but removing an existing one coming onto the roundabout from the industrial site. Just makes me wonder how much busier this junction will be if they feel the need to re-do the junction. I cannot see how a traffic light system will
improve anything and this strikes me as a case of trying to polish a turd. There will just be too much traffic because of ill-thought-out planning and too many new houses but minus the traffic network improvements required. I also read somewhere that a model or
something shows that if there are no improvements to this area, it will result in a 29-minute wait time at the Tesco roundabout for traffic coming from Bosham way at AM and PM peak times. 29 minutes! Are the planners trying to destroy the quality of life around these parts?
I do not hold much hope for real improvements to the road network, if, after any housing gets the go-ahead in this plan. I quote a paragraph from the Chichester District Council Duty to Co-operate Statement (May 2014). Item 3.10 it states “ The Highways Agency is confident that the works on the A27 Chichester Bypass required to support development set out in the Local Plan can be delivered.
The Stantec Chichester District Council Local Plan Transport Assessment (Jan 2023) states:
• "The adopted Chichester Local Plan (LP) 2014-2029, included a set of mitigation measures at the 6 principal
junctions along the A27 corridor. Although there have been works at the Portfield Roundabout in this timeline, no other mitigation schemes have been completed along the A27 corridor, as such the mitigation schemes defined in this report will also be required to consider the development from this plan period."
So it seems that all this was promised back then and then shelved and the road network is now pretty much unusable on a daily basis, despite the promises of the Highways Agency. So we have a situation where we all try and bypass the Bypass
I would have thought that any new developments, roadworks etc are meant to be progress, or progressive. Not regressive to the local community and those of us who work in the area.
Perhaps there needs to be a moratorium on all new housing in the district until guaranteed measures are in place to improve the road network. This is not guaranteed in the plan. (Point 8.5)

Reduce the water usage to 100l per person per day.
The requirements for developers in the catchment of Thornham Waste Water TW should be set out here without having to refer to the Position Statement ( as for Appulram). Why have the two catchments been treated differently.

Waste water and water quality should be separated into two distinct policies. Both PW and SW have targets of 100l usage a day per person. Why is CDC not following the same? There is no certainty that Thornham can deliver infrastructure improvements to increase capacity in the near future . This is a serious problem which requires a rethink of the number of houses expected to connect. There will be significant consequences if the allocated numbers are approved and connections are not possible.

Bosham Parish Council contends that the plan is not sound as regards policy NE16 because adequate SAFE water supplies will not exist and the provision of water supplies will be detrimental to water the quality.
There is no evidence in the LPlan to show how lower water usage will be encouraged
There is no evidence of upgrades to waste water infrastructure which the IDP categorises as a critical issue.

"A drainage impact assessment MUST DEMONSTRATE TO THE SATISFACTION OF THE LOCAL PLANNING AUTHORITY that the development complies with the principles set out in the latest Thornham Position Statement".

“Residential development within the catchment of the Thornham Wastewater Treatment Works, a drainage impact assessment should show that the development complies with the principles set out in the latest Thornham Position Statement"
There is a line in the TPS which states: "There is at present no certainty of a deliverable solution for the Thornham catchment and any solution will take time to deliver."
Why is development being proposed in Southbourne when there is no guarantee that appropriate waste water treatment can be provided at the right time?

No further development until the necessary infrastructure improvements are delivered.

Apuldram WwTW is already currently inadequate per CDC's own admission. Southern Gateway Strategic Allocation AL5 drains to Apuldram WwTW. There are environmental constraints which restrict its capacity to accommodate any further development. Concern about permitting more homes before upgrades to infrastructure are complete. Clear these are necessary for housing growth whilst maintaining and improving water quality of receiving waters. Recent flooding illustrates urgency of upgrades. Southern Water's plans are optimistic and we have concerns this will actually be delivered within 10 years. Across the district the lack of sewage provision is set to worsen until the substantial improvements are delivered.

Two separate policies for water supply and wastewater.
Amend the status of water companies and amend the Water Act.
A more robust policy.

Water supply and wastewater should be dealt with as two separate polices. There is nothing in this policy to prevent applications being approved when connection to WWT is not possible. There should be NO new development in the Thornham Catchment until such time as upgrades to the system have been completed, proposals for which have not been finalised. To do so risks further storm overflows which have been polluting the Harbour for months and completely unsatisfactory solutions such as tankering of waste material from new developments because Southern Water will have issued a letter confirming connection to their network to the developer even though they know that their wastewater treatment plant did not have this capacity. We have requested both the DLUP who have passed on the request to DEFRA that Southern Water and indeed all water utilities are made statutory consultees on all sizeable planning applications. This is essential and needs to be done urgently. Add this bit to the bit on have you told us about this before?

A reduction in the housing allocation numbers to a much more sustainable level

The current waste water treatment system is inadequate and unable to deal with combined household and surface water discharges at the present time. This is only going to be exacerbated by the proposed level of development, particularly in an area with high groundwater infiltration levels.
In 2022, the storm discharges from waste water treatment works into Chichester Harbour totalled:
Chichester (Apuldram) – 87.33 hours (3.64 days)
Bosham – 791.54 hours (32.98 days)
Thornham – 585.02 hours (24.38 days)

In addition, data has also been supplied since 2020 for 5 CSO’s that discharge into the Harbour. The most significant of these in 2022 was Priors Leaze, Nutbourne, which discharged for a total of 8.03 days. It should be noted that the harbour also receives storm discharges via Budds Farm in Langstone and the Lavant WWTW.
It is very hard to foresee how Southern Water, given the current regulatory framework, will be in a position to provide the necessary infrastructure to accommodate the development levels proposed. Recent permitted developments in the district rely on removal of waste by tanker, to avoid back-flowing sewage.
Likewise in a region of water scarcity, which will only worsen in the future with climate change, the proposed level of development is utterly unsustainable. The water-recycling proposals at the Havant Thicket reservoir site are deeply unpopular with the local community.

Under Water Supply insert additional wording " outside the Sussex North Water Resource Zone" so the text reads: "Development proposals outside the Sussex North Water Resource Zone will be permitted that demonstrate";

Under Water Efficiency correct "Southern Water's Supply Zone North" to " Southern Water's Water Resource Zone Sussex North".

Southern Water’s comments relate to the headed parts of this policy as follows, and we have suggested changes for the Water Supply and Water Efficiency sections of this policy, whilst we support the Water Quality and Wastewater section. We have uploaded this document to the consultation portal due to the limited space allowed for representations.

Water Supply

Southern Water supplies water to the north of Chichester District, to settlements within the Sussex North WRZ. Water resource planning is managed at regional scales by water companies through the production of Water Resources Management Plans (WRMPs) which are updated every 5 years. These plans set out how water companies will achieve secure water supplies for customers, whilst protecting the environment. New development sites allocated through local plans are taken into account as part of this process.

Moreover, it would not be necessary to include developments within the Sussex North WRZ in the requirements of criteria (a) and (b) of Policy NE16, as these will automatically be met where the development has complied with the requirements of Policy NE17.

Suggested amendment;

Development proposals outside the Sussex North Water Resource Zone will be permitted that demonstrate;

a) […]


Water Efficiency

Regarding criterion (b) of this policy’s Water Efficiency section, we would request a correction to the reference to our water resource zone, for consistency and accuracy, as follows;

‘… development in Southern Water’s Water Resource Supply Zone Sussex North..’

Water Quality and Wastewater

Southern Water supports this policy, in particular criteria (c) and (d) which relate to surface water and new infrastructure provision.

WGPC supports this policy intent Support but is unaware of provisions that prevent homeowners subsequently changing installed fittings or any definitive plans for rainwater capture and use within individual homes.

We need to see your answers to the above questions before we can suggest any changes.

Can you please confirm what evidence Chichester District Council expect to see from a developer to discharge this policy. i.e. how will developers comply with securing a water supply before occupation. It would be beneficial to understand what the Environment Agency's position on this is as well.
We are disappointed that only 110l per person is being promoted within this policy rather than 100l per person. It would be beneficial to understand why Chichester District Council are choosing these figures.

WGPC supports this policy intent but had concerns relating to water supply and wastewater treatment as detailed in its submission for Policy H3.
In terms of wastewater, severe problems are already being experienced and additional housing has the potential to exacerbate these issues.
WGPC is concerned that Southern Water is not taking these concerns seriously, and capacity figures are based upon dry weather.

It is suggested that capacity will be taken up on a first come first served basis, as opposed to prioritising the strategic allocations, this should be amended to ensure strategic planned schemes are given priority.

The Thornham position statement, referenced in Draft Policy NE16 requires new development proposals within the area served by Thornham WwTW to demonstrate that, taking account of both the latest DWF based headroom information and the needs of extant planning permissions yet to be built/completed, sufficient headroom exists to serve the development, or alternatively that no net increase in flows to Thornham WWTW will result from the development. Alarmingly, it is suggested that capacity will be taken up on a first come first served basis, as opposed to prioritising the strategic allocations.

There should be an allowance for schemes to demonstrate through their own Ww mitigation strategy and drainage impact assessment that they can operate within the capacity of existing wastewater treatment infrastructure.

Draft Policy NE16 requires any development outside of Chichester, Fishbourne and Stockbridge to not drain into Apuldram (Chichester) Wastewater Treatment Works, a position which would hold to ransom any strategic sites within the Apuldram WwTW catchment, until a time at which Southern Water make the necessary capacity improvements.
As there is no certainty of the timescale for a deliverable solution for the Thornham catchment, we recommend that the policy wording acknowledges the need for a fallback scenario should the lack of WwTW upgrades not be forthcoming and to recognise the impact this may have on the District’s overall housing trajectory.

Addition at the end of the section entitled 'Water Quality and Wastewater' - “Development shall connect to public mains sewer as the first option, and if that is not possible, provide justification for this and why a different option is needed.”

We can support the policy requirement that new residential proposals must demonstrate that a maximum water consumption of 110 litres per person per day.

The District lies within a serious water stressed area (as classified in 2021). The Government’s Written Ministerial Statement dated 1 July 2021 (HCWS140) highlighted the need for water efficient homes and announced the publication during 2022 of a roadmap towards greater water efficiency in new developments, including exploration of revised building regulations. Water efficiency is important not only from a water resource perspective, but also because of the link with water quality and disposal of foul water. There are real benefits in keeping down the capital cost of new water supply and waste water infrastructure, maintaining ecosystems and protecting landscapes. Reducing the amount of water entering waste water treatment works is also a key way of helping to mitigate issues around the capacity of the works and the receiving environment. Water efficiency standards can also help deliver objectives set out in River Basin Management Plans.

We are pleased that our comments at the Regulation 18 consultation regarding wastewater have been incorporated into this policy. The section entitled ‘Water Quality and Wastewater’ could be slightly improved by adding wording to reflect that development should connect to public mains sewer as a first option to ensure that the situation of lots of small private treatment plants does not crop up. We suggest additional wording to the end of the section to say “Development shall connect to public mains sewer as the first option, and if that is not possible, provide justification for this and why a different option is needed.” Connection to mains is preferable as it is more likely that systems will be maintained and improved over time. This also accords with the Planning Practice Guidance for Water supply, wastewater and water quality.

The policy references the Apuldram Position Statement, which we reviewed in July 2022 and concluded that it was still applicable and should continue to restrict development connecting to the Apuldram (Chichester) Wastewater Treatment Works (WwTW) to manage impacts on the Chichester Harbour from the increased use of storm overflow as a result of groundwater infiltration issues. The Thornham Position Statement is also referenced, albeit the issue here is related to infrastructure capacity.

We will raise that Lavant WwTW also has similar groundwater infiltration issues to Apuldram WwTW and as such may not have capacity for further connections in the future. Groundwater infiltration issues are difficult to improve upon and this is a continuing challenge for Southern Water.

Whilst Tangmere WwTW has been upgraded, further upgrades may be necessary in the future to accommodate more development.

We are currently working with the Local Authority and Southern Water to produce a Statement of Common Ground for Wastewater to provide more detail around the wastewater issues in the district. We understand that the Local Authority keep informed about capacity and discuss such matters with appropriate partners.

Reword to say development proposals will “minimise harm” rather than have “no adverse impact”.

Please refer to submitted representations document.

This seems a sensible stance. My only comment is the Council seems to be defining what constitutes a major development in the policy wording. Are you sure that's what you want to do?

Amend policy under water quality and wastewater to ensure the policy is effective in accordance with NPPG Paragraph: 019 Reference ID: 34-019-20140306

Bullet point

d) development is phased to align with the delivery and operation of new and improved wastewater infrastructure where this is required.

See attached representation.

See attachment.

A policy written in the final submission to assemble a consortium of stakeholders to conduct a full survey as to the condition of Pagham Harbour. The scope would cover impacts on marine and land-based environments from chemical, micro plastic and sewage contamination of the harbour and it's immediate coastline. Stakeholders would include Natural England, Environment Agency, CDC, Southern Water and the R.S.P.B. It is highly likely that Pagham Harbour is traveling a parallel downward path as Chichester Harbour in terms of condition but no stakeholders are paying this anything like the attention it deserves.

Manhope is a local interest group and represents more than 500 residents and users of the Western part of the
Manhood Peninsula (WMP); the part of the district at greatest risk from climate, travel and infrastructure challenges.

Our sole purpose is to protect the unique character of the Western Manhood Peninsula by opposing inappropriate and unsustainable large building developments before the necessary infrastructure is actually in place.

We are not sufficiently aux fait with the policies to be able to use the clause by clause “speech bubble” approach to comment. Therefore, our response is by way of email as suggested by our MP, Gillian Keegan in her letter to residents in February this year.

We understand that only three topics are open for comment in respect of the proposed Local Plan submission.

1. Is the submission legally compliant?
2. Is the submission 'sound'?
3. Does the submission comply with the Duty to Cooperate?

We are not qualified to comment on either 1. or 2. so these comments will address the question of whether the proposed submission is sound.

Chichester District Council has, quite rightly in our opinion, placed no demands for further large developments in the WMP apart from windfall sites. In our opinion even these should NOT be approved until the caveats shown in our Conclusion are implemented.
The following subjects have been well aired so we will not dwell on them in great detail but will summarise them as follows.

Transport.

The transport network serving the CDC area is already unable to cope at peak times and groaning at most other times. The A27 frequently gets headline recognition and from a strategic national point of view rightly so. The various arguments are again well rehearsed elsewhere especially from other local interest groups such as MPAG, SOSCA and the Harbour Trust and we support their submissions in this respect.

It is sufficient for us to say that if it was recognised that mitigating measures were required to cater for the huge increase in developments then it follows that the absence of such mitigation should halt completely such development. That is just pure logic.

Everyone who lives, works, uses or visits the WMP knows that having left behind the A27 they have not left behind the traffic problems. The obverse has become the “new norm” with the most minor hold up, such as refuse lorry, slow moving device or minor road works causing substantial delays and queues sometimes up to eighty vehicles long

The system whereby WSCC highways review the impact of planning applications is dysfunctional.

This is evidenced by WSCC highways department being unable to provide accurate feedback to the LPA as to the ACCUMULATIVE impact of very large developments.
The modelling simply does not allow it and there is no scope for actual local experience or common sense. In not one case of over twenty applications for ten or more houses have they even flagged a cautionary note about this accumulative impact.

For example many - actually most - accidents are not reported so the West Sussex Accident Location Map so this source often used by planners and developers to demonstrate how safe our local roads are, is dangerously misleading. Many life changing injuries have been sustained and known about by local people in the WMP but virtually none of these appear in “formal records”

Flooding.

Because of the low lying and vulnerable southern part of the district the findings and implications of the CDC Level 1 Interim Strategic Flood Risk Assessment (December 2022) need to be fully understood by parishes, councillors and local residents before comments of any real value can be made. We asked five elected or formally appointed local representatives and not one felt they had a full grasp of the SFRA’s implications and only one had a fair understanding.

We do know that the risk of significant flooding has increased. We also know that even before the SFRA was published the West Sussex County Council Lead Local Flood Authority gave a thumbs down to two of the large applications B 21/01830/OUT in Birdham and EWB22/02214/FULEIA.

CDC have recognised that the Manhood Peninsula has specific challenges including flood risk hence the zero requirement for housing in the WMP. In this respect we think the submission is probably just sound enough and hope that this approach filters through to decisions for applications yet to be determined.

However, to be certain of real soundness the work needs to be completed BEFORE implementation. Please see our notes under “Conclusion” Sewage.

There can be no doubt that this subject must impact whether the submission is sound or not. The arguments are complex and lengthy but two basic simple facts remain.

1. The main sewage plant for the Manhood Peninsula is Southern Waters Siddlesham WWTW. This plant is a couple of metres AOD and yet planners, the EA and developers argue as to whether four or five meters is an appropriate floor level on new developments. Hardly a sound approach when the treatment works will have been inundated well before even a three metre threshold will have been reached. One example of these discussions can be seen at E 22/03125/OUT for 100 houses

2. Southern Water have a policy of deploying large road tankers when heavy rain is forecast to standby local sewage points as there is a high risk of the system being overwhelmed. Frequently the drivers have to stay in their cabs all night.

Yet Southern Water are obliged to advise the LPA that they can deal with the additional load from huge new developments. Neither CDC nor the Inspector can solve the sewerage infrastructure issues but the above facts raise serious doubt as to the soundness of the submission. Please see our further notes under
“Conclusion”

Conclusion.

Manhope recognise the real imperative of having a local plan in place and is appalled that the system has resulted in a colossal amount of work for the LPA and yet still a disastrous delay in getting this in place let alone full and proper consultation with parishes and local people. Further delay in the submission of the local plan is therefore wholly unacceptable so our uncomfortable is that the submission, whilst barely sound, is as sound as it can be and should go forward BUT with some very clear caveats. Our suggestion for these are shown below.

A. No new developments of ten or more dwellings shall be commenced until suitable mitigating road improvements to the A27 are in place.

B. No new developments of five or more dwellings shall be approved by the LPA until the following reports, work and maps have been completed and due consultation has taken place with residents & parishes, (in line with the latest government approach to restoring local democracy).
a. Environment Agency flood maps based on the Interim SFRA (December 2022) have been completed.
b. Sewage infrastructure work as yet unknown in Southern Waters upcoming Asset Management Period to be in place before any development of 5 or more dwellings are approved.
c. Full and proper engagement with NHS as to practical limits on health demands as a result of new housing developments especially on the Manhood Peninsula. NHS’s advice was ignored by CDC and a planning inspector for a 70 house development (WW/20/02491/OUT) so they have not responded to further consultation requests. Vis EWB 22/02235/OUT and EWB 22/02214. This cannot be allowed to happen again.

C. Insert a policy in the submission that CDC planning reserve the right to apply their discretion in planning decisions when consultees provide advice that is contrary to public and parish experience. Ie Where formally submitted local and Parish advise given in their written response to planning applications is not aligned to other consultees then take the Parishes advice. To avoid using this discretion is not consistent with exercising a duty of care.

D. A policy written in the final submission to assemble a consortium of stakeholders to conduct a full survey as to the condition of Pagham Harbour. The scope would cover impacts on marine and land-based environments from chemical, micro plastic and sewage contamination of the harbour and it's immediate coastline. Stakeholders would include Natural England, Environment Agency, CDC, Southern Water and the R.S.P.B. It is highly likely that Pagham Harbour is traveling a parallel downward path as Chichester Harbour in terms of condition but no stakeholders are paying this anything like the attention it deserves.

Thank you for consulting Horsham District Council on the Chichester Proposed Submission Local Plan 2021-2039. We are grateful for the opportunity to be able to comment on your emerging plan. Overall, we consider that the plan has positively sought to balance the provision of future needs with other wider objectives in a manner that contributes to achieving sustainable development. I would also take the opportunity to reaffirm Horsham District Council’s (HDC’s) commitment to continued dialogue under the Duty to Cooperate and joint working between our two councils. We have a number of comments on the Proposed Submission Chichester Local Plan 2021 to 2039 to make on individual policies which we have set out below:

Policy S1 Spatial Development Strategy

We support this policy in principle, but consider it is not justified as stands. We note the spatial distribution in the plan period is split into three areas: East – West Corridor, the Manhood Peninsula, and North Plan area (which is the only part of Chichester district which directly adjoins Horsham district). HDC acknowledges Chichester District Council’s position that it is not able to meet its entire identified local housing need of 638 dwellings per annum, given the constraints associated with the required upgrades to the strategic road network in order to facilitate growth, potential environmental constraints and wider infrastructure restrictions. It is understood that National Highways requires a cap on growth due to the limited capacity of the A27. The proposed housing supply target is therefore 575 dwellings per annum.

HDC acknowledges and welcomes that significant effort has been put into identifying development capacity in a way that reflects the principle of positive planning. Nevertheless, the NPPF and PPG set a high bar for ‘leaving no stone unturned’ in respect of meeting development needs. We support that planned growth is directed to sustainable locations where access to local services and access to transport links are easier to access than remote rural areas. It is acknowledged Chichester City is the most populous settlement in the district as well as being most sustainable. We support that growth and future development should be focussed in the East-West Corridor, and in particular in or close to the City, first and foremost. We also acknowledge wider infrastructure deficiencies will need to be addressed in strategic locations before they can accommodate more growth.

We support your continued dialogue with National Highways to support improvements to the strategic road network and note a Statement of Common Ground (SoCG) will be published and updated as part of a continuous dialogue with National Highways. The SoCG is important as part of the justification for a lower housing supply figure and should transparently demonstrate why the constraints on the A27 will not allow higher growth in the East West corridor, in order to evidence that maximum housing needs have been achieved in the City and East West Corridor. This evidence is needed for HDC to inform its own DtC position with Chichester District Council (CDC).

Chichester District is planning below the standard methodology housing target and has therefore asked HDC if it can accommodate some of Chichester’s unmet housing need. HDC has confirmed that we are not in a position to accommodate Chichester’s unmet development needs because of our own water neutrality constraint. Furthermore, the primary housing market for Horsham District is the Northern West Sussex HMA, whose development needs are substantially driven by the Gatwick sub-region, and it is this HMA that would be prioritised with respect to meeting unmet development needs.

As a partner in the Sussex North Water Neutrality grouping also impacted by this constraint, CDC jointly owns the relevant evidence, and our two authorities share an ongoing commitment to work on this as our Duty to Cooperate dialogue continues. As ever, the latest position with regards to Water Neutrality and the impact on the delivery of housing and other development needs can be set out in a Statement of Common Ground (SoCG) between our two Councils.




Policy NE16 Water Management and Water Quality

We support this policy which is clear in its encouragement of efficient use of water as part of good management framework.

Policy NE17 Water Neutrality

Water neutrality is a significant issue affecting both our districts. Horsham District Council supports this policy which is derived from the joint work undertaken by Chichester District Council, Horsham District Council and Crawley Borough Council. We look forward to continued working with CDC on the development of the implementation scheme, in order to deliver the JBA Water Neutrality Assessment study. This will ensure all new development is in conformity with the Habitat Regulations and can demonstrate water neutrality.

Policy H1 Meeting Housing Needs

As outlined earlier in this response, we acknowledge that land supply in Chichester is constrained, and that CDC meeting the full housing requirement within its administrative boundary during the plan period up to 2039 would be challenging. Horsham District is not however in a position to accommodate any of Chichester District’s unmet housing need because of water neutrality and, looking forward, the need to prioritise meeting unmet needs within our primary housing market: the Northern West Sussex HMA.

Policy H2 Strategic Locations/Allocations 2021 -2039

A significant proportion of CDC’s housing supply will be delivered through strategic allocations. Loxwood (220 dwellings) is identified as a strategic allocation and will come forward through the local plan process, with some allocations anticipated to be delivered through local neighbourhood plans. Given the challenges that face Neighbourhood Planning groups in the preparation and delivery of Neighbourhood Plans, (which can potentially delay the delivery of these allocations), we support the identification of strategic sites in the Local Plan, programmed for delivery earlier in the plan period.

As the delivery of strategic allocations requires significant infrastructure planning, including cross-boundary issues relating to the road network, education, healthcare and community facilities, Horsham District Council welcomes continued dialogue with the relevant stakeholders, to ensure development at strategic locations such as Loxwood are delivered in a timely manner and adhere to sustainable development principles. We have some specific concerns relating to strategic allocation policy A15: Loxwood which we have set out under that policy.

Policy H11 Meeting Gypsies, Travellers and Travelling Showpeople’s Need.

We note your position and your requirement to provide a number of pitches and plots for the travelling community during plan period. We support your policy position for intensification of existing pitches. Horsham District can’t at this point in time accommodate any of CDC’s unmet Gypsy, Traveller and Travelling Show people requirement as we are required to first address our own shortfall, and our evidence demonstrates that this alone will be challenging.

We have a body of evidence to support our position and we will continue to share our evidence with you as our Duty to Cooperate dialogue continues over the coming months. As ever, the latest position regarding Gypsy, Traveller and Travelling Showpeople will be set out in the Duty to Cooperate Statement of Common Ground between our two Councils.

Policy A15 Loxwood

We support this policy as it will contribute to meeting Chichester District’s unmet housing need, but consider it is not justified as stands and that its effectiveness could be improved. The five villages in the north of the Plan area (Kirdford, Wisborough Green, Loxwood, Ifold and Plaistow) are classified as Service Villages in the emerging Chichester Local Plan. They provide a reasonable range of basic facilities (e.g. primary school, convenience store and post office) to meet the everyday needs of local residents, or are villages that provide fewer of these facilities but that have reasonable access to them in nearby settlements. Loxwood is the strategic site identified to accommodate 220 dwellings over the plan period.

The nearby settlement of Billingshurst, in Horsham District, is considered to be the nearest main settlement to the villages identified above. Given the limited facilities available / or to be provided as part of the Loxwood allocation, it is considered that new residents are likely to be reliant at least some key facilities in Billingshurst, potentially including the GP surgery, the railway station (and rail user car park), The Weald secondary school and sixth form, the library and the retail and community facilities, including the leisure centre. Within Horsham District, there are potential proposals for strategic scale extensions to Billingshurst / new settlements relatively close to Billingshurst. Whilst no decisions have been made with respect to our local plan, housing growth delivered through our own local plan will create potential impacts on existing infrastructure which is already under significant pressure. We therefore require clear evidence that potential cumulative impacts on settlements in HDC have been considered as part of the proposed allocations. We would ask that CDC works collaboratively with HDC and other stakeholders to ensure future pressures on infrastructure in Horsham District is appropriately addressed. Consequently, we seek further clarification in Policy A15: Loxwood to emphasise the importance of collaborative working between stakeholders to mitigate against the potential cumulative impact of development.

I do hope these comments are helpful. I would like to emphasise that they are made in anticipation of further constructive dialogue between our authorities, and with an expectation that matters on which we have flagged concern can be readily addressed, and quite possibly eliminated through our Duty to Cooperate discussions. Should you require any further detail or information in regard to this response please don’t hesitate to contact a member of my Strategic Planning team.

See attachment.

Executive Summary

The Local Plan as written lacks ambition and vision, and will be detrimental to the landscape within which the district lies. It is a plan borne out of a need to produce a legal document which will satisfy the regulatory authorities. In terms of Urban Planning it fails “To meet the needs of the present without compromising the ability of future generations to meet their own needs” (NPPF).

The development that will consequentially arise from the deployment of such a made Local Plan is not sustainable. It will adversely affect the Character, Amenity and Safety of the built environment, throughout our district.

In particular, the Local Plan is inadequate for the needs of the people in the district both at present and in the future because –

1. It has been written in advance of the District having a properly formed and agreed Climate Emergency Action Plan. It is inconceivable that such a key document will not shape our Local Plan. It is this Action Plan that is needed first in order to provide the long-term strategic view as to how and what the District will look like in the future; this, in turn, will help form and shape the policies outlined in any prospective, Local Plan. The Plan as proposed is moribund, as a result of “cart before the horse” thinking.

2. The Local Plan as written does not adequately address how infrastructure, transport and services are going to be materially and strategically improved to meet the predicted growth and shift to a significantly ageing population. There is presently insufficient capacity to supply services and to have adequate people and environmentally friendly connectivity, as a direct result of decades of neglect towards investing in infrastructure and services to meet the needs of the District’s population. We are led to believe that developers through increased levies in order to gain permission to build will fulfil this need, but all that this will result in is an uncoordinated, dysfunctional mess completely lacking in any future-proof master planning approach. We contend that this will do nothing for the quality of life of Chichester District residents and it will create a vacuum whereby few if indeed any can be held accountable or indeed found liable for shortcomings in the future.

3. The Local Plan as written does not state how it will go about addressing the need to create affordable homes. The District Council’s record on this matter since the last made plan has been inadequate and now the creation of affordable homes has become urgent as political/economic/social factors drive an ever increasing rate of change within the District.

4. Flood risks assessments used in forming the Plan are out of date (last completed in 2018) and any decision to allocate sites is contrary to Environment Agency policy. Additionally, since March 2021 Natural England established a position in relationship to ‘Hold the Line’ vs. ‘Managed Retreat’ in environmentally sensitive areas, of which the Chichester Harbour AONB is a significant example. CDC have failed to set out an appropriate policy within the proposed Local Plan that addresses this requirement.

5. The A27 needs significant investment in order to yield significant benefits for those travelling through the East-West corridor; this is unfunded. Essential improvements to the A27 are key to the success of any Local Plan particularly as the city’s ambitions are to expand significantly in the next two decades. But any ambitions will fall flat if the A27 is not improved before such plans are implemented.. The A259 is an increasingly dangerous so-called ‘resilient road’ with a significant increase in accidents and fatalities in recent years. In 2011, the BBC named the road as the “most crash prone A road” in the UK. There is nothing in the Local Plan that addresses this issue. There is no capacity within the strategic road network serving our district to accommodate the increase in housing planned, and the Local Plan does not guarantee it.

6. There is insufficient wastewater treatment capacity in the District to support the current houses let alone more. The tankering of wastewater from recent developments that Southern Water has not been able to connect to their network and in recent months the required emergency use of tankers to pump out overflowing sewers within our City/District reflects the gross weakness of short-termism dominated thinking at its worst and is an indictment of how broken our water system is. The provision of wastewater treatment is absolutely critical and essential to the well-being of all our residents and the long-term safety of our built environment. The abdication by those in authority, whether that be nationally, regionally or locally, is causing serious harm to the people to whom those in power owe a duty of care and their lack of urgency in dealing properly with this issue is seriously jeopardizing the environment in which we and all wildlife co-exist.

7. Settlement Boundaries should be left to the determination of Parish Councils to make and nobody else. The proposed policy outlined in the Local Plan to allow development on plots of land adjacent to existing settlement boundaries is ill-conceived and will lead to coalescence which is in contradiction of Policy NE3.

8. All the sites allocated in the Strategic Area Based Policies appear to be in the majority of cases Greenfield Sites. The plan makes little, if any reference to the development of Brownfield sites. In fact, there is not a Policy that relates to this source of land within the Local Plan as proposed. Whilst in the 2021 HELAA Report sites identified as being suitable for development in the District as being Brownfield sites were predicted to yield over 4000 new dwellings. Why would our Local Plan not seek to develop these sites ahead of Greenfield sites?

9. The Local Plan does not define the minimum size that a wildlife corridor should be in width. What does close proximity to a wildlife corridor mean? How can you have a policy (NE 4) that suggests you can have development within a wildlife corridor? These exceptions need to have clear measures and accountability for providing evidence of no adverse impact on the wildlife corridor where a development is proposed. Our view is quite clear. Wildlife and indeed nature in the UK is under serious and in the case of far too many species, potentially terminal threat. Natural England has suggested that a Wildlife Corridor should not be less than 100metres wide. The proposed Wildlife Corridors agreed to by CDC must be enlarged and fully protected from any development. This is essential and urgent for those Wildlife Corridors which allow wildlife to achieve essential connectivity between the Chichester Harbour AONB and the South Downs National Park.

10. Biodiversity Policy NE5 - This is an absolute nonsense. If biodiversity is going to be harmed there should be no ability to mitigate or for developers to be able to buy their way out of this situation. This mindset is exactly why we are seeing a significant decline in biodiversity in the District which should be a rich in biodiversity area and why the World Economic Forum Report (2023) cites the UK as one of the worst countries in the world for destroying its biodiversity.

11. In many cases as set out in the Policies the strategic requirements lack being SMART in nature – particularly the M Measurable. These need to be explicit and clear: “you get what you measure”.

12. 65% of the perimeter of the District of Chichester south of the SDNP is coastal in nature. The remainder being land-facing. Policy NE11 does not sufficiently address the impact of building property in close proximity to the area surrounding the harbour, something acknowledged by the Harbour Conservancy in a published report in 2018 reflecting upon how surrounding the harbour with housing was detrimental to it long-term health. And here we are 5 years on and all of the organizations that CDC are saying that they are working in collaboration with, to remedy the decline in the harbour’s condition, are failing to implement the actions necessary in a reasonable timescale. CDC are following when they should be actually taking the lead on the issue. Being followers rather than leaders makes it easy to abdicate responsibility. There must be full and transparent accountability.

13. The very significant space constraints for the plan area must be taken into account. The standard methodology need no longer apply where there are exceptional circumstances and we are certain that our District should be treated as a special case because of the developable land area is severely reduced by the South Downs National Park (SDNP) to the north and the unique marine AONB of Chichester Harbour to the south. A target of 535dpa is way too high. This number should be reduced to reflect the fact that only 30% of the area can be developed and much of that is rural/semi-rural land which provides essential connectivity for wildlife via a number of wildlife corridors running between the SDNP and the AONB. Excessive housebuilding will do irretrievable damage to the environment and lead to a significant deterioration in quality of life for all who reside within the East / West corridor.

14. Many of the sites identified in the Strategic & Area Based Policies could result in Grade 1 ^ 2 farmland being built upon. The UK is not self-sufficient in our food security. It is short-sighted to expect the world to return to what we have come to expect. Our good quality agricultural land should not all be covered with non-environmentally friendly designed homes.

Remove point d from policy.

See attached representation.