Policy H2 Strategic Locations/ Allocations 2021 - 2039

Chichester District Local Plan 2039 – Pre-Submission (Regulation 19) Consultation

1. Introductory Comments
Stagecoach South is the main commercial public transport operator across Chichester District. The Company has headquarters in the city, which is also the principal public transport hub for the District and it’s rather wider travel-to-work area encompassing much of the Arun District. Our services extend throughout and beyond the District boundaries, as far as Littlehampton, Midhurst, Havant and Portsmouth. The vast majority of services operate on a commercial basis – that is to say, sustained by passenger use and fare revenue, including concessionary reimbursement.

While the role of the railway is significant in much of the District, especially the east-west Coastway line, yet bus services account for more boardings locally than the railway, with Chichester depot services carrying over 3.5m passengers each year.

Unlike bus services in other parts of the country, the local network has recovered strongly after the pandemic with fare-paying passenger numbers over 95% of 2019 levels, albeit with concession patronage somewhat lower. This has helped secure not only a stable but growing bus network even during this period of rapidly rising operational costs, avoiding the need for the service contractions seen in other regions. Indeed, during the second quarter of 2023 Stagecoach will invest £5.5m in brand-new vehicles for high-profile coastal Service 700 – one of the largest vehicle investments for Stagecoach Group this year.

Our services are therefore critical to existing and future local connectivity. As the Plan acknowledges, mobility demands do not respect planning authority boundaries. The role of our services is especially high to settlements in the broad A27 corridor, within the District and beyond. This includes major settlements in Arun District such as Pagham and suburban Bognor Regis, where bus is the only mass public transport option. As the Council is well aware, there is an even higher level and rate of committed development envisaged in these locations in the Arun District Local Plan than in Chichester.

It is already evident to the planning authorities, West Sussex County Council and National Highways, as proprietor of the A27 Trunk Road, that accommodating growing mobility demands across Chichester District and especially around Chichester itself, is becoming increasingly challenging to the point of being seriously problematic.

Stagecoach has a particular interest in this Plan arising from:

• The already clear and highly deleterious impact of congestion affecting our operations and their reliability and attractiveness to the public. The effects of these on the approaches to Chichester, and around the A27 bypass are especially severe. If public transport is to retain its existing role – even before the needs of any meaningful growth both in Chichester and neighbouring authorities is considered, are considered – the Council and the Highways Authority need to arrive at clearly-defined measures to protect buses from chronic delay and the damaging impacts arising from the lack of bus network resilience and customer journey times.
• In connection with the above, the need to properly consider the predictable impacts of committed development in Arun District on the transport network and in particular the operation of bus services. The duty to cooperate on cross-border strategic matters is not limited merely to accommodating housing requirements.
• The fact that our entire business premises and operational base at Chichester is the subject of allocation for redevelopment within the Plan period. Specifically, this includes our Head Office, the Bus Station as the operational hub of the network and the key interchange for passenger journeys – including those that involve the railway – and the bus depot required to support the entire operation. Notwithstanding many years of discussions, there is as yet no agreed deliverable strategy to replace these facilities either in the Draft Plan or elsewhere.

Stagecoach broadly supports the vision and priorities of the draft plan. In most respects, Stagecoach supports strongly the spatial strategy and the identified site allocations that flow from it, and the evidence.
However, it has serious concerns about the soundness of the plan as proposed for submission, for important regards outlined in this response. These are made in the light of requirements set by the National Planning Policy Framework (NPPF), in particular at paragraphs 15 and 16; 35, 105-109 inclusive and having due regard to the need for allocations to satisfy 110-112 inclusive in due course as development permission is sought; and paragraph 174.

Paragraph 16c) of NPPF makes plain that strategic plans and policies should “be shaped by early, proportionate and effective engagement between plan-makers and communities, local organisations, businesses, infrastructure providers and operators and statutory consultees” (our emphasis). This makes plain that collaborative and ongoing involvement of public transport operators is both necessary, and separate and in addition to the engagement with statutory consultees. This has not taken place.

Para 1.25 of the draft plan states that “the council has engaged constructively, actively and on an ongoing basis with other local authorities and organisations to address key strategic matters.” Despite the requirements in NPPF and contrary to the statement made, Stagecoach has not been approached or involved in a meaningful, collaborative or ongoing way in the preparation of the Plan.

Our main concerns centre around the fact that the plan strategy is neither backed by sufficient transport evidence. Even more importantly, the plan relies on a wholly car-based transport mitigation strategy despite policy stating that this is not the case, and the track record of the existing Local Plan, based on a very similar strategy, that has failed to bring forward meaningful mitigations to date to prevent traffic conditions substantially worsening. There is no support in policy for the achievement of the Strategic Objectives in the Plan. Nor is there definition of any measures in the 2023 Transport Study to make provision for sustainable transport infrastructure or services – much less materially improve them.

Finally, to the extent that updated transport evidence has been provided in the form of the 2023 Chichester Transport Study, arising from updated traffic modelling, it does not support the contention that highways capacity constraints on and around the A27 justify not meeting the objectively-assessed development needs of the area, as the draft plan contends.


2. Vision and Strategic Objectives

2.1. Issues and Opportunities
Stagecoach Objects because the Plan:
• does not comply with the duty to cooperate
• is unsound as it does not conform to the National Planning Policy Framework
• is not effective
• is unsound because it is not based on relevant, proportionate and up to date evidence
Stagecoach recognises the important role of the West Sussex and Greater Brighton Strategic Planning Board which agreed a Local Strategic Statement (LSS2) in early 2016 to identify spatial planning issues across the wider area. This established strategic priorities and policies to guide longer term strategic growth in a coordinated and well considered matter. This institutional framework and the purpose of the LSS is a highly significant one and is at the heart of efforts to properly fulfil the statutory Duty to Co-operate, including with regard to strategic infrastructure issues, as NPPF requires.

Given the long period of time elapsed since the 2018 Reg 18 consultation and the already very clear constraints on strategic infrastructure capacity, it is of great concern to Stagecoach that the LSS2 has not been updated to reflect emerging issues in the intervening period. A review and update of the LSS2 has only just commenced. This includes a study of projected housing and employment needs, transport impact, infrastructure and spatial options to deliver the required development in the period after 2030. This Chichester District draft plan covers a period extending to 2039 – therefore well beyond 2030 and the nominal currency of LSS2.

However, infrastructure needs are pressing today. Stagecoach is presented with severe highway operational problems on a near-daily basis. During the winter of 2022-23 we have, for example, seen key road links impacted for many weeks by acute disruption arising from flood events. Unpredictable, but seemingly more-frequent, exogenous events expose a lack of resilience in the highway network around Chichester and its travel-to-work area. However, serious, chronic, unpredictable delay has been normalised over recent years, with peak-time congestion having quickly returned after the pandemic. The existing development strategy has failed to bring forward measures having any impact on this to date, and key commitments – notably at west of Chichester Phase 2 and at Tangmere – have yet to commence to further aggravate the issue.

We have no confidence in the transport mitigations proposed in the existing Local Plan and LSS2 being sufficiently effective, even if deliverable at all. Indeed, the existing adopted Local Plan does little more than make vague speculations about the sustainable transport measures that might be achievable. The draft local plan review is no different. It has no ambitions at all for sustainable modes and thus, makes no meaningful provision to meet them.

This is especially relevant in light of the fact that the approach to resolving issues on the A27 around Chichester that were anticipated in 2015-16 have fallen away. LSS2 is thus currently inadequate to act as a part of an up-to-date, proportionate, and relevant evidence base for the Plan.

An update of a traffic model lies at the heart of a 2023 Chichester Transport Study. This talks no account of the existing role of non-car modes, nor can it do so. It is unable to properly evaluate the nature of problems or solutions that involve public transport, or for that matter, other sustainable modes.

Therefore, we consider that the combination of committed and additional development needs that must be accommodated over the whole plan period between 2022 and 2039, in both the Chichester and Arun Districts, require a “first principles” review. This must be based on a refreshed transport evidence baseline of no earlier than 2022 – given that the effects of COVID distort 2020-22 – and the transport infrastructure and service requirements to sustainably support those needs.

Key issues – including substantial changes with regards to transport issues and challenges, as well as potential solutions – thus do not form part of the evidence base that steers this plan. Given long term changes in travel patterns, and mode share that took place during COVID, as well as a local and national policy context that seeks to radically reduce and then eliminate transport-related carbon emissions, this is especially problematic.

The specific problems of congestion and network resilience that are evident on the A27 and the approaches to Chichester remain a set of especially difficult problems that disproportionately affect the efficiency, reliability and attractiveness of the bus network, that evidently demand larger-scale strategic responses involving multiple stakeholders, including bus operators.

Where the effects of development on the national Strategic Roads Network (SRN) are concerned, the approach of National Highways to addressing and responding to the mobility needs of development has now substantially changed following the promulgation of the DfT Written Ministerial Statement LTN01/22. This makes it clear that adding highways capacity is no longer the first or only strategy that should be pursued, but one subordinate this to maximising the potential of non-car modes and sustainable travel.

“Effective and ongoing collaboration” on transport matters has not led to solutions being agreed and published for public scrutiny as part of the plan evidence base. Whatever the approach to modelling and “highways improvements” that may be agreed or pending agreement with the County Highways Authority and National Highways, Stagecoach is neither participant or sighted. This is despite the clear requirements set out in NPPF Para 106 b) that “Planning policies should … be prepared with the active involvement of local highways authorities, other transport infrastructure providers and operators and neighbouring councils, so that strategies and investments for supporting sustainable transport and development patterns are aligned.” (our emphasis).

We therefore consider that the Council has failed to comply with the requirements of NPPF paragraph 25 and 26 that “relevant bodies” are involved in plan-making, especially with regard to addressing the needs for infrastructure. Public transport services and the infrastructure that supports its operation and use clearly fall within matters relevant to plan-making. This is explicit in NPPF Chapter 9 and indeed within the plan itself – for example reference to public transport and sustainable modes in the Vision for the plan.

It should be stressed that the Regulation 18 “Preferred Approach” consultation took place in December 2018 – over 4 years ago and prior to COVID, based on LSS2. The inordinate length of time that has elapsed between the Regulation 18 and Regulation 19 stages greatly challenges the LSS2 and other parts of the evidence base, especially as the pause straddles the COVID epidemic. That would include the transport modelling baseline, and key assumptions in any traffic modelling that took place prior to mid-2022, which is a point at which a reasonable “new normal” post-COVID might be considered to have become established. In that period, Arun District has also adopted its own Local Plan development strategy that accommodates an unprecedented quantum of development immediately east and south-east of the District Boundary – creating additional substantial transport impacts directly affecting the A27 and multiple major approaches to Chichester crossing it.



The established mechanism to fulfil the Duty to Co-operate has thus not operated effectively.
The Plan is not founded on a relevant, proportionate and up-to date evidence base and is thus inadequately justified.

2.2. Spatial Portrait
The spatial portrait is generally succinct and accurate. However, it makes no mention of road-based public transport, the role of the City as a public transport hub, or the range of bus services that provide local connectivity (Section 2.4 and 2.5). The complete concentration of post-16 education in the City itself as just one example of the peculiarities of transport demands in the area, is not highlighted, though this has a profound influence on peak time travel demands affecting the most congested parts of the highway network. Among other things, the role of bus services in supporting the educational system of the plan area is very great indeed.

The potential role of bus in addressing the already-severe transport problems of the plan area and beyond seems entirely overlooked. The spatial portrait is thus clearly inadequate and incomplete.

2.3. Strategic Objectives
Stagecoach Objects because the Plan:
• is unsound as it does not conform to the National Planning Policy Framework
• is not effective
• is unsound because it is not based on relevant proportionate and up to date evidence

Chapter 9 of NPPF and paragraphs 104 and 105 in particular require that plans should:
“Transport issues should be considered from the earliest stages of plan-making and development proposals, so that:
a) the potential impacts of development on transport networks can be addressed;
b) opportunities from existing or proposed transport infrastructure, and changing transport technology and usage, are realised – for example in relation to the scale, location or density of development that can be accommodated;
c) opportunities to promote walking, cycling and public transport use are identified and pursued;
d) the environmental impacts of traffic and transport infrastructure can be identified, assessed and taken into account – including appropriate opportunities for avoiding and mitigating any adverse effects, and for net environmental gains;…
…The planning system should actively manage patterns of growth in support of these objectives. Significant development should be focused on locations which are or can be made sustainable, through limiting the need to travel and offering a genuine choice of transport modes. This can help to reduce congestion and emissions, and improve air quality and public health…”

The Strategic Objectives do not conform with NPPF in these foundational requirements adequately, to transparently steer the plan strategy. They should therefore be amended to read:

“Plan to provide local infrastructure to support new development and seek opportunities to address existing identifiable infrastructure problems deficits, such as in particular those relating to the A27 and its junctions and wastewater treatment.”

Paragraph 2.36 states, in the context of the Climate Emergency and the National Trajectory to “Net Zero” that “The council will enable the delivery of infrastructure, jobs, accessible local services and housing for future generations while protecting, conserving and enhancing the historic and natural environment.”
Naturally, we support this intent.

However, there is no acknowledgement of the role current patterns of transport use contribute to carbon emissions, nor that substantial mode shift is necessary to address sustainably an acute lack of capacity on the local network and the SRN, especially around Chichester. This is especially concerning as the basic conceptual link is not made between the fact that the greatest such problems lie on the A27 corridor and around Chichester, while these are also at the same time present many of the most sustainable locations for development, and where the opportunities to secure much greater use of sustainable modes also exists.

Strategic Objective 7 “Strategic Infrastructure” includes the following statement:

“To work with infrastructure providers to ensure the timely delivery of key infrastructure to support delivery of new development. New development will be supported by sufficient provision of infrastructure to enable the sustainable delivery of the development strategy for the plan area. Key infrastructure to support the Local Plan will include improvements to transport, …

A sustainable and integrated transport system will be achieved through improvements to walking and cycling networks and links to accessible public transport. Highway improvements will be delivered to mitigate congestion, including measures to mitigate potential impacts on the A27 through a monitor and manage process.”
The latest transport evidence in the Chichester Transport Study makes no pretence to define much less to deliver a “sustainable or integrated” transport system. It is wholly devoted to sustaining current levels of car use across the District, to and through Chichester area.

It is no more than the lightest of touches to the approach taken to supporting the adopted Local Plan, an approach that is already almost 10 years beyond the date of its gestation but has yet to deliver any significant capacity improvement schemes, much less any measures that sustain even current levels of public transport journey times and reliability in the face of increasing congestion – much less any betterment.

Of the six key junctions on the A27 around Chichester, recognised to require significant mitigation given they are saturated for extended periods, five accommodate regular bus services - indeed frequent ones at least every 20 minutes in several cases. The sixth at Oving Road, relates directly to a key corridor where bus services are needed to support strategic growth currently being delivered at Shopwhyke, as well as substantial further growth West of Tangmere (proposed allocation A14) and “East of Chichester” (A8), south of Shopwhyke Road.

As stated at p12 of the Study Summary “The modelling shows that all the junctions on the A27 Chichester bypass are well over capacity, even before adding in the Local Plan development and with the exception of Portfield Roundabout are actually shown to be over capacity in the base model year (2014) in one or both peaks”. This much has indeed been evident for years from delay and periodic even more severe disruption arising to Stagecoach services from the lack of network resilience.

The reassignment of through and local traffic through Chichester to avoid the A27 bypass is an especially serious issue for bus services that penetrate the city. This is leading to consequential saturation of a range of junctions used by buses. Rising delay and unpredictable running times are at the root of our decision to sever the long-established Portsmouth to Littlehampton service in 2023, which will in future no longer run across Chichester, but terminate to provide additional dwell time to mitigate the impacts of congestion.

While this congestion affects all road users including businesses and freight traffic, the effect on scheduled bus services is greatly higher, as such services cannot reassign route to ‘beat the queue’. Traffic congestion often encourages greater car use for this reason, in tandem that people are happier to sit for extended periods in their own vehicle on a seamless door-to-door journey than wait at the roadside for a delayed bus making slower progress in lengthy queues.

As the Study admits at para. 1.3.2 “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.”

In other words, in the 8 years since the current Local Plan was adopted in 2015, there has been minimal progress is delivering the traffic mitigations. There is no clarity at all when any such mitigations will be brought forward. It is hardly surprising then, that traffic conditions have deteriorated. The “predict and provide” transport strategy supporting the current plan has failed.

Despite this, the Draft Local Plan Review proposed to “double down” on exactly this strategy. It represents, like the rest of the evidence base, a “rolling forward” of the current car-based strategy by 9 years, with the lightest of touches to attempt to accommodate car trip demands from a relatively modest additional development quantum.

Nevertheless, the Study requires a global 5% reduction in trip demands arising from unspecified “credible” (paragraph 4.1.2) sustainable transport and travel planning measures. It is unclear why use of non-car modes will see disproportionate growth when no measures are in place to make them more attractive. This 5% increase in use translates to a doubling in the modal share of bus services. There is no evidence nationally, anywhere, that simple ignorance of alternatives to the car is the main barrier to uptake.

The outputs of the 2023 Chichester Area Traffic (SATURN) model are set out at Table 5.1 (am peak) and 5.2 (pm peak) without mitigation. These betray just how seriously compromised the whole network around Chichester is, and will be in future, even with implementation of a mitigation partake to increase traffic capacity that is understood to cost between £92m and £164m – and which the Study and the draft plan acknowledge cannot be delivered through developer funding sources alone. Unspecified external funding presumably from HM Treasury through DfT is required.

Even if this provided and the schemes are delivered, Tables 8.1 and 8.2 indicate these will provide minimal relief. The final columns suggest key junctions, including Portfield, Fishbourne Road and Cathedral Way East will remain at well over 100% ratio of flow to capacity (90% is considered the point at which saturation is approached, with the onset of increasing delay above that figure). RFCs in tables 8.1 and 8.2 are some of the highest we have ever seen in a local transport evidence base for a post-mitigation scenario. While the serious potential risk of reassignment across Chichester City is greatly reduced, which is important and welcome given its impact on bus services, Tables 8.1 and 8.2 show the extent of post-mitigation saturation is also egregious, covering a very large number of key links and junctions.

On every measure and criterion, then, including cost deliverability and effectiveness, the revised Transport Strategy falls well short of evidence to suggest the transport impacts of the plan can be properly addressed by this means.

Despite the repeated statements about sustainable modes throughout the draft plan and Chichester Transport Study, only 2 paragraphs at Section 6.2 within the Study are devoted to public transport:

“6.2.7 The funds generated from the parking management schemes, local/nation funding schemes and developer contributions could also be utilised to fund potential public transport enhancements within the city centre including an expansion of the bus priority lane system within Chichester City Centre. This could reduce reliance on the car in the longer term towards sustainable public transport. A park and ride scheme could be incorporated within a bus priority lane network in the future depending on the uptake and successfulness of early bus priority trials.

6.2.8 Chichester City centre has a constrained existing public highway network. Therefore, any proposed dedicated public transport or light transit corridors that could be implemented would be at the expense of existing highway. This could be managed through a time-based system where certain routes are restricted to public transport only during specific times. E.g., peak hours.”

There is some very high-level consideration of Park and Ride following this section. None can be considered a serious practical evaluation of consolidating car-borne trips onto bus services, including existing ones, for example local mobility hubs, more frequent bus corridors, delivery of specific bus priorities.

None of the discussion of alternatives to “predicting and providing” for unconstrained traffic growth is rooted in a deliverable evidence base, or proper evaluation of options and specific projects.

To take just one aspect of the few specifics that can be picked out, a workplace parking levy is hypothesised. This would apply only to “offices”, in Chichester city centre (para 6.2.3), without consideration given as to how this could be practically achieved or even that a meaningful amount of office based employment would qualify. Much less is any consideration given to how far focusing a strategy only on office-based workers would actually deliver a particularly significant effect, apart from to create a strong incentive to relocate offices out of the city centre to places out of reach by public transport.

Looking at the Chichester Transport Study 2023 and the draft plan together, there is insufficient evidence that the traffic capacity increase proposed in the 2023 Transport Study is any more affordable or technically deliverable, or likely to be sufficiently effective, than those in the past strategy. The evidence more strongly points to the fact that no highways improvements are identifiable or economically deliverable to meet even short term increases in demand for car-borne mobility on most of the network around Chichester.

There are no published strategies or schemes clearly supporting the contention that the objective of improving sustainable modes is technically achievable or deliverable either. The plan makes generalised assertions that such strategies will be devised and implemented only after serious problems emerge from a shortfall in the car-borne transport strategy.

The reference to “monitor and manage” is undefined and unsubstantiated. There are no outcomes stated, no mechanisms specified and no timescales for action.

Our experience today is that network conditions have reached unacceptable and prejudicial levels of severe unpredictable delay. The saturation of the network is already evident well outside the traditional peaks on key sections of highway and at key junctions. External shocks such as the effects of severe weather are becoming more common, leading to delays so extreme as to justify the description of “gridlock”. The plan does not identify a strategy to effectively address this, in particular by consolidating passenger car trips onto more efficient public transport vehicles. This is unacceptable to Stagecoach.

2.4. Local Plan Vision
Stagecoach Objects because the Plan:
• is not effective
• is unsound because it is not based on relevant proportionate and up to date evidence

Stagecoach supports the broad approach in Plan Vision and in particular that by 2039, the Plan will support and enable greater use of sustainable modes. However, there is no link made between reducing the use of private cars, and the need for a step change in the use of sustainable modes. Without a published transport evidence base it is impossible to establish a suitable sustainable transport strategy to support both carbon reduction and alleviation of the problems arising from acute congestion. Even on a very crude basis, to achieve a meaning mode shift on key approaches to the A27 Chichester Bypass will require more than 20% of existing peak car-borne journeys to transfer to other modes. A 10 percentage point transfer to bus (about half this shift) would imply more than doubling peak hour bus passenger boardings.

The Vision is nothing more than an aspiration, that needs to more definitively aim at key outcomes, for the plan to be effective. The Vision should thus be altered to read:
“Get about easily, safely and conveniently with less reliance on private cars –making the greatest possible use of the rail and enhanced bus network, and with more opportunities for active travel including walking and cycling; to materially reduce dependence on private car use.”

Underpinning the Plan’s spatial strategy, the Vision section goes into more specific detail about key localities in the Plan area.

Regarding Chichester, Paragraph 2.39 states: “The emphasis will be upon consolidating and enhancing the role of Chichester city as the plan area’s main centre, whilst also developing the role of key settlements to its east and west. The focus will be upon creating communities with good access to a range of employment opportunities and affordable housing for young people and families to balance the ageing population.”

This is clearly the appropriate focus for meeting the District’s development needs in a sustainable manner. The city and key settlements to the east and west, are those places already able to make use of relevant public transport services, both rail and bus. Especially within and near the City, walking and cycling can credibly present highly relevant choices. This emphasis clear can be expected to address the requirements of sustainable development set out in NPPF and their local application set out in the Plans Strategic Objectives.

However, this needs a robust transport strategy, to avoid a further concentration of development and its traffic impacts occurring on or near some of the most chronically congested parts of the highway network. To date, the absence of intervention has strangled the bus network through further marked deterioration in traffic conditions. This by consequence increases the risk of bus delay or cancellation, lengthens journey time and reduces customer confidence in bus as an attractive alternative mode of travel.

In April 2023, Stagecoach is making significant timetables changes to improve operational resilience in and around Chichester. The biggest such change is the severance of the Portsmouth to Littlehampton section of service 700, at Chichester, with buses operating independently to the east and to the west and ending cross-city links. This is planned to reduce the probability of delay but at the cost of additional vehicle resource (circa £200,000 per annum) which could be better spent providing new or enhanced services. We anticipate a small loss of custom as a direct consequence of the change, but have little choice other than to take negative action so as to fulfil our statutory punctuality obligations.

If the Strategic Objectives of the Plan and its Vision are to be achieved, in the way required by NPPF paragraphs 104-105, a properly-evidenced transport mitigation strategy needs to create the conditions where bus journeys are more reliable than car journeys and thus mobility demand switches as far as can be realistically achieved away from car use, to bus use and other more sustainable modes.

Beyond Chichester, the Plan Vision focuses on key localities beyond to the east and west.

To the west of Chichester a focus on growth at Southbourne is justified at paragraph 2.43: “…the aim is to take advantage of the village’s good transport links and existing facilities to deliver significant new residential-led development within the broad location for development which will further enhance local facilities and offer opportunities to reinforce and supplement existing public transport, including bus routes.”

We agree this is a very significant opportunity. However, if the requirements of NPPF paragraphs 104-105 are to be met, this demands that effective bus priority is delivered on the A259 corridor, especially eastbound at Fishbourne and westbound approaching Emsworth. Without such measures, the growth committed and planned will serve only to further undermine bus journey time and decrease punctuality on the existing 700 service, entirely contrary to the aims of the Vision.

The emphasis on the A259 corridor served by Stagecoach 700 west of Chichester is reinforced at paragraph 2.45 stating that “Between Chichester and Southbourne, the Plan provides for more moderate levels of growth within the parishes of Fishbourne, Bosham and Chidham & Hambrook, … with opportunities to support and expand existing facilities and for increased use of public transport options”. We strongly support the principle, but the Plan must follow through with specific public transport priority measures that facilitate rather than prejudice such an outcome.
East of Chichester the focus is at Tangmere, where the existing allocation for about 1000 dwellings is being uplifted by 300. Paragraph 2.44 justifies this among other things recognising the scope for “…improved and additional bus services and cycleways will provide better connections to Chichester city and east to Barnham and the ‘Five Villages’ area in Arun District.” We unequivocally endorse this conclusion. Realising a “game-changing” level of bus service quality, reliability and frequency east of the city, also serving committed and planned development north and south of Oving Road at Shopwhyke, is equally essential, given that all SRN links and junctions are approaching equal saturation.

The National Bus Strategy has given new focus on partnership with West Sussex County Council to discuss and deliver a significant new bus service between Chichester, Shopwhyke, Tangmere, Eastergate and Barnham, supporting committed development and acting as an initial phase of what ought to be a more ambitious longer-term strategy to support growth beyond 2025 in both Chichester and Arun Districts. For these improved bus services to be both deliverable and effective, robust bus prioritisation is unavoidable. No such measures are proposed in the Plan or its evidence base and we therefore suggest inclusion of plans to facilitate safe and efficient bus operation between Tangmere and Nyton/Eastergate, ideally avoiding the need to join A27 through-traffic entirely.

We welcome the clear recognition that these localities identified for growth, benefit from existing relevant public transport services. The Vision also sets an expectation that bus services in particular should be “enhanced” and “reinforced”.

We entirely agree that these opportunities exist, across the broad strategy and strategic allocation proposed by the draft Local Plan. Securing them will be crucial to achieving national and local policy objectives, including the Strategic Objectives. However, to our continuing very great dismay, the Plan goes no further to defining how this will be achieved. As such the Vision is not demonstrable achievable or deliverable.

Accordingly the Plan cannot be considered effective, in the sense of NPPF.

Remedying this, demands specific measures to protect bus services from congestion in the following corridors:

• A259 East of Emsworth
• A259 Fishbourne
• A 259 Via Ravenna/Cathedral Way
• A286 Stockbridge Road north and south of A27
• B2145 Whyke Road/Hunston Road
• A259 Bognor Road, east and west of A27 and extending to the District Boundary
• B2144 Oving Road/Shopwhyke Road east and west of the A27
• A 285 Westhampnett Road/Portfield Way/Stane Street, potentially involving a mode filter at the west end of Stane Street

These must be defined to a sufficient level of detail to assess their effectiveness and deliverability, including costs.

This would then allow West Sussex County Council and Local Transport and Highways Authority, ourselves as the principal bus operator, and where appropriate other organisations that would be directly tasked with delivering the mitigation package, to agree service levels and standards necessary to deliver specified outcomes, including journey times, frequencies, capacity and hours of operation on the network, and also in respect of the strategic allocations and Strategic Locations for Growth.

The agreed mitigations strategy should be set out in an up-to-date Infrastructure Delivery Plan backed by clear funding commitments, including a funding strategy to justify necessary developer contributions.

Where necessary to support evidence of effectiveness and deliverability, clear statements of support, which might include Statements of Common Ground between the LPA, LTA, National Highways and Stagecoach, could be provided.


3. Spatial Strategy
Stagecoach Supports
Stagecoach well recognises the constraints outlined in the explanatory narrative at the start of Chapter 3.
In particular we strongly endorse that strategy in that it reflects that the best opportunities to meet housing and employment development requirements sustainably clearly exist in and close to Chichester and on the key east-west movement corridor where – subject to effective measures being delivered to make these modes more attractive, efficient and relevant – sustainable modes can credibly provide for a much higher proportion of movement demands, mitigating most effectively the potential traffic impacts of development.
We agree that the Manhood Peninsula suffers serious environmental constraints, but, added to these, public transport and other sustainable modes cannot provide such attractive alternatives, and significant further development risks merely reinforcing already high levels of car use, aggravated by the carbon impacts of the distances involved – something the plan does very little to evaluate, and makes no reference to.

We endorse the conclusion in paragraph 3.24 that significant development in the part of the District north of the National Park is inappropriate. The rationale is principally on landscape and visual character. This exposes a fundamentally biased approach to plan making that has consistently underplays transport accessibility and carbon issues. In fact, the lack of local services and the extended distances that need to be travelled to fully participate in society in this area, with no realistic prospect of public transport offering relevant choices, ought to rule such a strategy out of play on a far less aesthetic and interpretational basis.

3.1. Policy S1 Spatial Development Strategy
Stagecoach Supports
The Spatial Strategy flows clearly and logically from the Spatial Portrait, and the opportunities and constraints identifiable across the Plan area. It represents a logical and justified continuation of the existing Local Plan strategy. In particular the spatial strategy maximises the potential for sustainable modes to contribute to meeting a much higher proportion of all the District’s mobility and accessibility needs.

3.2. Policy S2 Settlement Hierarchy
Stagecoach Supports
The settlement hierarchy clearly reflects the service endowment and potential self-containment of the settlements in the District. In particular, the second tier of settlement hubs includes secondary schools, which are major peak trip generating uses. Service villages, in the main, also benefit from bus services running at least hourly, which can be expected to provide for a degree of mobility for the higher number of trip purposes that cannot be satisfied by walking or cycling within the immediate locality. Thus, a level of development to meet local needs in this tier is relatively sustainable.

There is a quite broad range of settlements in this category. We have concerns that, north of the National Park, the Service Villages have no realistic public transport choice. These include Plaistow/Ifold, Kirdford, Loxwood, and Wisborough Green. Such as exists is typically a 1/bus per day off-peak shoppers service offering up to 90 minutes in Horsham or Guildford and as such any development here even to meet local needs requires each adult to own a car. This contrasts strongly with Service Villages to the south of the National Park, which are greatly more sustainable.


4. Climate Change and the Natural Environment
Stagecoach Objects because the Plan:
• is unsound as it does not conform to the National Planning Policy Framework
• is not effective
• is unsound because it is not based on relevant proportionate and up to date evidence

This section of the plan is extensive and wide ranging, as should be expected.
However, remarkably, there is no acknowledgement whatever of the role of transport in mitigating climate change or its effects, not of the importance of sustainable movement and access being facilitated across the plan area in addressing anthropogenic impacts on the natural world at a more local level.

This exposes very clearly a troubling level of indifference to transport matters in the production of the Plan, which, while nationally quite common, is neither appropriate nor acceptable. The mitigation of transport impacts is not merely a matter speaking to the social and economic aspects of sustainable development. It is crucial to address the causes and effects of climate change that arise from transport, and personal mobility.

This is now well understood and at the centre of national policy, including the National Decarbonisation Strategy for Transport (July 2021) which at Section 5 commits the government to aligning land use planning and transport strategy much more tightly and effectively to mitigate the carbon emissions associated with the current dependence on cars, and the mode mix; but also to reduce travel distances, both increasing the potential relevance and effectiveness of all sustainable modes, and reducing average journey lengths for residual motorised journeys of all kinds.

National statistics show that well over a third of all domestic carbon emissions arise from land-based transport and of these, the vast majority arise from trips of over 10km – outside the range of large scale use of cycling. In fact, the potential of the plan to materially support carbon emissions reduction from within the plan area lies more in the realm of transport than any other policy theme – including emissions mitigation from buildings, which is in any event an aspatial matter and covered by nationally-binding building regulations. By 2025 something like 40% of all the emissions within the plan-area will be transport related.

There is no evidence supplied to support the plan that addresses the transport carbon impacts of the spatial development strategy in a clear manner.

There is no evidence supplied that sets out the effects of potential worsening of congestion on air quality within the plan area, arising entirely from the excess of passenger car movement demands over available and credibly deliverable highway capacity. This is despite the evidence set out and acknowledged in the explanatory memorandum at paragraph 4.130:
“4.130. The council’s Air Quality Action Plan and the West Sussex Transport Plan 2022-2036 both refer to the air quality issues faced by Chichester. There is currently one Air Quality Management Area (AQMA) in the plan area, located at St Pancras, Chichester. AQMAs are designated where air quality exceeds, or is likely to exceed, national air quality standards and objectives. Development within or impacting these areas, or that likely to cause the declaration of any further AQMAs, will be subject to an air quality assessment by the applicant.”

This is a retroactive approach – it is not “planning”, based on evidence.
We are well aware that air quality issues in and of themselves can render allocated sites to be undeliverable: a good example is in the Vale of White Horse, Oxfordshire, where strategic allocations on the A338 and A420 corridors have been held up for years by air quality issues at Marcham and Frilford, in large measure because agreed transport interventions were considered inadequate or undeliverable a very short time after the Plan was examined and adopted.

There is no evidence that shows how the development strategy can effectively mitigate these impacts as well as the further potential impacts that arise from the development strategy. This is exasperating, as there is clear evidence that could be drawn upon to show that that very substantial opportunities exist to:
• Speed buses up and make them more reliable by the delivery of bus priority on most of the key main corridors. Most of these even today operate relatively frequently
• Improve service frequencies and extend hours of operation.
• Secure significant background mode shift to bus as a result, damping pressure on key links and junctions, by consolidating demands on direct more reliable and more frequent bus services.
The spatial development strategy as submitted is in fact, likely to well conform to such additional evidence.

The allocations require substantial additional transport related work and evidence to demonstrate that the opportunities for sustainable transport have been identified and taken up as required by NPPF paragraphs 104-105.

With regards to specific policy, Policy NE22 should be modified to read:
“Development proposals will be permitted where it can be demonstrated that all the following criteria have been addressed:
1. Development is located and designed to minimise traffic generation and congestion
through access to by maximising the relevance and attractiveness of sustainable transport modes, including maximising provision of specific demonstrably effective measures to make pedestrian and cycle and public transport routes and networks more direct, more safe, faster and more reliable;…”


5. Housing

5.1. Policy H1 Meeting Housing Needs
Stagecoach Objects because the Plan:
• is unsound as it does not conform to the National Planning Policy Framework
• is not effective
• is unsound because it is not based on relevant proportionate and up to date evidence

The presumption of the planning system is that local planning authorities should seek to meet their objectively assessed development requirements in full. These needs are assessed by a defined Standard Methodology set out in Planning Practice Guidance and elsewhere, that has explicit regard to ensuring that the economic and social effects associated with housing are properly provided for, to avoid exacerbating serious problems that arise from inadequate housing supply.

As a significant local service provider and employer, Stagecoach is concerned that existing issues with housing availability and affordable housing supply are not exacerbated. This has a direct bearing on staff recruitment and retention. It also has an indirect bearing on our cost base.

The existing problems with housing affordability have developed over many decades of undersupply. It should be emphasised that the significant boost to the supply of housing that has been sought by governments over the last 15 years, has only begun to take effect relatively recently in this District. Tackling the problem will require years of consistent attention.

Stagecoach notes that the Council is no longer proposing to meet its identified housing needs in full. Rather than 638/annum the Council is allocating a total that implies an annual delivery rate of 535/annum.

While a number of matters evidently present challenges to the Council in identifying a sustainable development strategy. Paragraph 5.2 indicates that “constraints, particularly the capacity of the A27 has led to the council planning for a housing requirement below the need derived from the standard method…” The blame for being unable to meet housing requirements is thus laid squarely at the door of transport infrastructure and systems.

This conclusion in no way follows from the evidence in the Chichester Transport Study. This, rather, makes the statement that when a higher annualised quantum of 700 dwellings per annum was tested, in the majority of cases the traffic capacity improvement package would perform little differently. To quote the Study:

“5.6.3 The network performance outputs analysed comprising V/C%, Delays (seconds) and Queues (PCU’s) suggest that generally the proposed SRN mitigation identified for the Core Scenario, can accommodate in the most part, additional increase in development to 700dpa.”

Whether the rest of the local road network is similarly protects is moot.

Irrespective of these results, even if the contention made in the draft plan were true, unlike many other constraints, this is amenable to a suitable effective strategy to address the constraints identified being collaboratively conceived. This is what NPPF expects, as set out in paragraphs 104-106.

Where the A27 is concerned, as part of the SRN, National Highways is now working to a substantially revised approach than that in force at the time to current Local Plan was prepared, or LSS2, or reflected in the Chichester Transport Study. This is set out in DfT WMS 01/22. This document is the policy of the Secretary of State for Transport in relation to the SRN which should be read in conjunction with the National Planning Policy Framework (NPPF). It replaces the policies in the Department for Transport Circular 02/2013 of the same title.

It makes plain that to accommodate additional demands arising from development, National Highways (NHC) expects to meet the requirements of its statutory license in a substantially different manner. With respect to development NHC LTN 01/22 continues to address the tensions between national policy for the environment and carbon mitigation, the ongoing need to substantially boost the supply of housing as well as maintain national economic competitiveness and protect the safety of the public. However, in future, the approach will be to seek first to maximise the impact of demand management measures (reducing the need to travel), and then to accommodate residual additional demands first though maximising the use of sustainable modes, rather than accommodating assumptions about current levels of car dependency and use.

LTN 01/22 much more closely and explicitly aligns with the language of NPPF Chapter 9 paragraphs 104-106. Paragraph 12 states: “New development should be facilitating a reduction in the need to travel by private car and focused on locations that are or can be made sustainable…. Developments in the right places and served by the right sustainable infrastructure delivered alongside or ahead of occupancy must be a key consideration when planning for growth in all local authority areas.” (our emphasis).

It continues at paragraph 13: “where developments are located, how they are designed and how well delivery and public transport services are integrated has a huge impact on people’s mode of travel for short journeys. The company will therefore expect strategic policy-making authorities and community groups responsible for preparing local and neighbourhood plans to only promote development at locations that are or can be made sustainable [footnote 8] and where opportunities to maximise walking, wheeling, cycling, public transport and shared travel have been identified.” (again, our emphasis)

Stagecoach readily confirms that the draft Plan development strategy conforms well to the first limb of this expectation, in terms of the location of development.

Stagecoach considers that the plan and its evidence base conforms poorly to the second in that the specific opportunities to maximise walking, cycling wheeling and public transport are not clearly identified, and defined, and proven to be effective and deliverable.

The current mitigation strategy for the A27 Chichester area, supporting the adopted Local Plan and for which proportionate developer contributions have and continue to be sought, reflects now-superseded DfT Circular 02/2013. As a direct result, it failed completely to identify any significant effective bus priority measures, despite the fact that frequent services already exist on the key corridor concerned, and that one bus journey can remove, fully seated between 72 and 80 single occupancy car journeys from congested links and across key junctions on the A27. Rather, it sought to implement targeted measures to increase the throughflow of general traffic.

We recognise the realisation that this approach, which was already reliant on some tenuous logic, is simply not technically viable, especially where further development needs are anticipated.

National Highways will form now pursue an approach with the planning system that “includes moving away from transport planning based on predicting future demand to provide capacity (‘predict and provide’) to planning that sets an outcome communities want to achieve and provides the transport solutions to deliver those outcomes (vision-led approaches including ‘vision and validate,’ ‘decide and provide’ or ‘monitor and manage’). The company will support local authorities in achieving this aim through its engagement with their plan-making and decision-taking stages.” (paragraph 15).

Paragraph 23 is at the fulcrum of assessing and defining transport mitigations to accommodate growth on and near the SRN “Capacity enhancements such as modifications to existing junctions or road widening to facilitate development should be determined on a case-by-case basis. The general principle should be accepted where proposals would include measures to improve community connectivity and public transport accessibility, and this will be weighed against any negative safety, traffic flow, environmental and deliverability considerations, impacts on the permeability and attractiveness of local walking, wheeling and cycling routes, and alternative options to manage down the traffic impact of planned development or improve the local road network as a first preference.” (our emphasis).

However, no material work has been done that seeks to identify if a bold robustly conceived and suitable judiciously-prepared strategy that seeks to consolidate flows on already densely travelled corridor onto improved bus services, driving mode shift through insulating these services preferentially from already serious queuing. This would be likely to have very substantial impacts on all the key junctions on the A27, and potentially, on the A27 itself. The need for an integrated approach between Shoreham and Emsworth within West Sussex paying particular regard to development requirements in both Arun and Chichester Districts naturally lies at the heart of this, and we would expect to be picked up by the LSS3 Review among other things.

However, the locus of the problems and its causes and effects are obviously well enough known to start work on defining solutions within the plan area today. We would expect that this work will be essential if National Highways are to support the Plan, especially now given the terms of Circular 01/2022.

Such work could and should start from a “policy off” position: in other words that the Plan should fully accommodate its needs unless it can be proved that a mitigation strategy for the A27 that is compliant with DfT WMS 01/2022 cannot credibly accommodate resulting capacity demands without unacceptable impacts on the safety and efficient operation of the SRN.

This evidence does not exist. In fact the Chichester Transport Strategy 2023, on which the Council solely relies as its transport evidence base, indicates the opposite at para 5.6.3. This is the case before meaningful measures to secure damping of traffic demands through mode reassignment are even considered.

The exception to this is Portfield and Oving Road, which are among the most problematic areas after mitigation even at the Council’s chosen 535 dwelling/annum scenario (para 5.6.4.-5). The costly capacity mitigation simply cannot deliver enough benefit. It is admitted that WSCC has indicated that it would prefer a solution that places greater reliance on sustainable modes damping car-borne demand. This is entirely the strategy required by NHC to follow LTN 01/22, of course. Despite the fact that “predict and provide has “run out of road” no attempt has been made to examine what such a solution set credibly could looks like. This is unsatisfactory and deeply troubling.

At paragraph 5.4 the draft plan points back again at the West Sussex and Greater Brighton Strategic Planning Board and the future work that has been commissioned, but has barely begun, to update the Local Strategic Statement. This work is to inform the preparation of plans that have horizons beyond the end date of the current LSS in 2030 and properly to meet the Duty to Cooperate. As we said in our response to section 1 of the Plan we fully endorse the conclusion that this is the right mechanism to look at these issues. However, the mechanism has not been effectively applied to the production of this plan. Therefore, the specific evidence that capacity on the A27 in and of itself supports accommodating a lower housing requirement does not exist.

The Plan thus does not conform to NPPF, is not adequately justified and is not effective.

The Plan does not properly meet the statutory Duty to Cooperate.

We will return to this matter in specific representations to Section 7 of the draft plan.

5.2. Policy H2 Strategic Locations/Allocations 2021-2039
Stagecoach Supports
Policy H1 makes plain that the plan, as far as it identifies locations for development has done so in locations that conform with its spatial strategy. All of the strategic allocations to a greater or lesser extend offer clear opportunities to make use of sustainable modes, by virtue of their location. That is not to say that the opportunities to take up these opportunities, and maximise the role of sustainable modes, has been identified, defined and translated properly into the rest of the plan policy suite or Infrastructure Delivery Plan.

As our remaining representations make clear, we support the locations thus far identified as being those that offer the best opportunities to reduce the need to travel, reduce travel distances, and create high quality attractive sustainable travel choices, for both existing residents as well as new ones.

However, the transport impacts of the allocation will individually and cumulatively likely to lead to increasingly severe impacts on the transport network, and on bus services.

Perversely, because these opportunities are not properly identified and secured through the plan and its supporting transport strategy, the opportunities presented by the allocations to secure a substantially more sustainable and lower carbon pattern of movement will not only risk being squandered but may aggravate the wider problems.

5.3. Policy H3 Non-strategic Parish Housing Requirements
Stagecoach Supports
The approach is consistent with the plan’s spatial strategy. It generally avoids a dispersal of development to locations likely to be highly car dependent. There is a clear focus on meeting housing needs in the far north-east of the District at the largest and most sustainable settlements, such as Loxwood, Kirdford and Wisborough Green. However, it must be pointed out that public transport availability in this area, provided by the County Council through services it procures, is minimal. These settlements in practice require each adult and child of secondary school age to have access to motorised transport to fully participate in society. This might justify significant measures to secure a boost in the frequency of bus services between Guildford and Billingshurst, passing through these settlements.

Otherwise, existing commitments in the plan area already make provision to meet for local needs. To the degree that there is an unmet local requirement for affordable housing of a small scale – for example to support the rural economy – this could be met through neighbourhood plans or through Rural Exception Sites.


6. Place-making, Health and Wellbeing

6.1. Policy P1 Design principles
Stagecoach Objects because the Plan:
• is unsound as it does not conform to the National Planning Policy Framework
• is not effective

NPPF requires that proposals should consider transport issues from the earliest possible stage. Designing to properly facilitate safe and efficient access, focusing first on sustainable modes, should be at the heart of development design. Too often it is still an afterthought, notwithstanding this.
Policy P1 must include an additional statement to be compliant and effective with NPPF paragraph 104-105 and 112 a):
“Development will be designed to make access and movement using walking, cycling and public transport the natural first choice, and demonstrate through the Design and Access Statement how such modes are afforded the most direct, safe, reliable and efficient routes within to and from the proposals, especially when compared with car use.”

6.2. Policy P4 Layout and Access
Stagecoach Objects because the Plan:
• is unsound as it does not conform to the National Planning Policy Framework
• is not effective

A number of proposals in the plan involve large-scale development. It is essential that where appropriate buses can access and circulate efficiently through development at a suitably early stage. There is no acknowledgement of this anywhere in the policy, contrary to NPPF paragraph 112.

Large-scale development which buses cannot access in an efficient or timely manner, or at all, strongly contributes to high levels of car-dependency. Evidence for this is referred to among other places, in DfT Circular 01/2022. To be compliant with NPPF and properly pursue its strategic Objectives, Policy P4 needs to be modified to address this point:
“1. Provide safe, direct and attractive conditions for inclusive access, egress and active travel between all locations and providing as good direct high quality links to integrated public transport, and where appropriate efficient access and circulation to bus services, unimpeded by excessive parking, at a suitably early point in the development phasing;


7. Transport and Accessibility
Stagecoach Objects because the Plan:
• does not comply with the duty to cooperate
• is unsound as it does not conform to the National Planning Policy Framework
• is not effective
• is unsound because it is not based on relevant proportionate and up to date evidence

The issues related to transport are fundamental to the soundness of the Plan. In particular, the constraints presented by the capacity on the A27 around Chichester and its key junctions, are the paramount reasons why the Council does not consider it can meet its objectively-assessed development needs in full. Thus, the transport issues and potential solutions available and what these mean for the ability of development needs to be accommodated, are matters that go to the heart of the soundness of the Plan.

Paragraph 8.3 sets out the approach taken to date succinctly:
“Increasing the capacity of the road network is key to supporting growth in the Local Plan. However, there is also a need to reduce demand for road transport to achieve net zero in greenhouse gas emissions by 2050 as highlighted in the council’s Climate Emergency Action Plan and Strategic Objective 1. In aiming to achieve the ambitions of the action plan, all development is expected to demonstrate how it will support four key objectives to create an integrated transport network which will alleviate pressure on the road network, improve highway safety, encourage sustainable travel behaviours and help reduce transport related impact on air quality, by:


1. Avoiding or reducing the need to travel by car;
2. Enabling access to sustainable means of travel, including public transport, walking and cycling;
3. Managing travel demand; and
4. Mitigating the impacts of travel by car.”

However, this approach is unambitious and “lightweight” as it assumes, as does the existing Chichester Transport Strategy on which the current adopted plan relies, that the focus of investment should be, wholly, in highways capacity improvement.

Sustainable modes explicitly are expected to play a greater role to “alleviate pressure” on the local road network, as part of this strategy. To emphasise: to avoid exacerbating congestion, the strategy will have to both remove a significant proportion of existing demands from the network on multiple key approaches to Chichester; and then ensure that travel demands from committed and further new development allocated in the plan does not simply replace these journeys, or, worse, create even greater demands.

This will demand very significant behaviour change. Only by making sustainable modes substantially more attractive, both absolutely, and relative to the same journey made by car, can this be expected to occur. However, the explanatory memorandum as well as the wider policy suite and IDP, well expresses a fundamental unwillingness to taking specific, defined measures to achieve this reduction in car use and material promotion of sustainable modes. It makes plain that sustainable modes, including bus services, will offer a lesser role to which “access will be provided”.

Such a vague and weakly defined mechanism will have no effect, at all, on current behaviour and car dependency if the relevance of those choices as a credible alternative to car use, is not substantially boosted. This includes a 5% reduction in trip demand assumed by the Traffic Model at the heart of the Chichester Transport Study 2023.

For this reason. the transport strategy behind the current adopted plan is demonstrably ineffective, as the updated model makes plain. It has not yet been delivered and is yet unclear when or (in the absence of committed funding) even if it can be. It is ineffective to “roll forward” this strategy to support a higher level of planned growth.

We note that a scheme for addressing congestion on the A27 at Chichester has been included in Roads Investment Period 3 (2025-2030) – well within the horizon of this Plan. However, recent history provides compelling evidence that off-line improvement to the north is not politically supported and arguably even technically or economically deliverable. It is not funded, nor at this stage can it be hypothesised if an economically deliverable scheme is achievable sufficient to warrant the necessary investment.

An on-line improvement of the A27, including junction improvements, is likely to favour longer distance east-west though movements, which are of greater significance to the national economy, at the expense of local movements crossing the SRN- a conundrum that largely sums up the dilemma that is faced by NHC and the County as Highways and Transport Authority. It is one that is played out in many places, but rarely is the tension so stark as at Chichester.

Every local route crossing the A27 at grade around Chichester accommodates a regular bus service - or shortly will do (Oving Road area is expected to follow in 2023, though bus services are likely to not use the modified crossroads but to use the left-in-left-out facilities provided as part of the Shopwhyke Lakes development). The impact of these issues on the entire bus operation are serious and increasingly severe.

By the same token, boosting the relevance and reliability of each of these services substantially consolidating as much demand as possible onto a much smaller number of vehicles, is clearly a strategy that ought to support the effective capacity of each of these junctions being greatly augmented, at the same time as reducing equally substantially, the energy- and carbon intensity of mobility in the plan area. Addressing the A27 should not be considered some kind of “zero-sum” game.

Furthermore, the approach of National Highways in its dealings with development and the planning system now reflect a substantial change in Government Policy set out in DfT Circular 01/2022, which we separately cover in these representations, that entirely aligns with an approach that seeks to appropriately invest in more active and rational management of scarce highways capacity, on both the SRN and local roads.

For environmental, economic and social reasons – including public health, the issues presented by the A27 and its interface with local roads around Chichester stands out, nationally, as an example of where the approach taken to accommodating and mitigating development impacts needs to make a clear break with previous “predict and provide” approaches to meet forecast unconstrained car use as LTN 02/2022 makes clear as a principle. Policy in the West Sussex LTP to 2036 itself makes plain that “shared mobility” – including bus services – must play a much greater role in this area.

The existing Chichester Area Transport Strategy is focused on justifying capital contributions from committed development to fund highways capacity improvement – with nothing included to make bus services more attractive, or importantly more reliable. Indeed this “cars first” approach is so costly, that there is already accepted by WSCC to be insufficient land value remaining to be captured to put into substantial improvements for public transport. That much is very evident, and transparent, from paragraph 8.12 and 8.14, where south of Chichester “This (one) package of works (of several improvements needed) would be between £57.23 and £82.79 million to deliver in full and would not be capable of being funded by development contributions alone.” This assumes the scheme is otherwise deliverable, which on the evidence in the public domain for some time, has be considered challengeable.

The draft Local Plan and a modestly updated infrastructure package that flows from the 2023 Chichester Transport Study, pursues exactly the same approach.

This strategy is also even more ineffective having regard to the roll forward of the Plan to 2039. It cannot deliver the key Strategic Objectives of the Plan; and in particular this is explicitly recognised by the Council in the failure of the draft Plan to accommodate the OAN in full.

It is also obsolete, as it does not align, from first principles, with national policy (including the National Decarbonisation Strategy for Transport) and DfT Circular 01/22; nor the Council’s own declared Climate Emergency.

As a result, draft Policies T1 and T2 are both unsound, as we will separately explain.

Owing to the lack of evidence about the implications of this for adjoining authorities – especially Adur District – in the absence of the review of the Local Strategic Statement – this has implications for fulfilling the Statutory Duty to Co-operate.

The absence of any meaningfully comprehensive refresh of the transport evidence base means that there are no meaningful schemes of any kind, defined in the plan or its IDP, to indicate either what level of growth can be accommodated, by delivering a change in travel behaviour. This would be aimed to secure a sufficient effective increase in junction throughput (measured in terms of person trips as opposed to passenger car unit movements (PCUs). Such evidence would propose measure to achieve that outcome and assess the efficacy and costs of such improvements, across all modes.

Paragraphs 8.10-8.13 inclusive indicate that the Council “has moved away from ‘predict and provide’” and invites the reader to conclude this has translated into a programme of interventions that can be funded to deliver specific, credibly predictable outcomes. Such a programme should be clear in paragraph 8.11. and the IDP. There is no such clarity and this conclusion would be false.

It would also be evident in the language of the Chichester Transport Study 2023 and its refreshed proposals. Only the most token of lip service is paid to the matter. It is a plainly car-focused, predict and provide methodology to support a “predict and provide” strategy. In fact, it is a brazenly car-focused approach, to the exclusion of all else.

The statements in the Plan regarding any other approach, read properly, offer nothing more than a vague commitment to look post-adoption, and implementation, at unspecified measures, based on problems that may arise in future that will be decided by a committee: the Traffic and Infrastructure Management Group (TIMG). This does not yet exist and is obviously an attempt to posit a mechanism that retroactively will cover for the lack of serious multi-party engagement to address the existing and future issues. Such a group should, in our view, also include the public transport operators, not least if the requirements of NPPF Para 106c) are to be satisfied, and the strategy and measures to be adopted are material to supporting the Local Plan, as of course the purpose of the TIMG has as its core raison d’etre.

The approach proposed by the draft plan is plainly ineffective and unsound in justifying the draft Plan.

It is more widely unacceptable to Stagecoach. The issues are severe today and well-known, already serving to jeopardise the delivery of buses relied on by existing residents, much less attract new ones.

We also consider that HM Planning Inspectorate are likely to be quite resistant to accepting this aspect of the plan’s transport strategy, nor will it be appropriate for the Council, West Sussex County Council, or National Highways, to define such measures after the submission of the Plan during the Examination process. The Examination in Public of a local plan has no purpose to improve plans, or remedy deficiencies clearly evident prior to submission.

The examination of the West of England Joint Strategic Plan in 2019, and the Uttlesford Local Plan in 2021, among several others, demonstrates especially clearly that the Planning System and the Examination process is not amenable to post-hoc retrofitting of transport evidence and strategies to support a development strategy.

7.1. Transport Evidence Base
Stagecoach Objects because the Plan:
• does not comply with the duty to cooperate
• is unsound as it does not conform to the National Planning Policy Framework
• is not effective
• is unsound because it is not based on relevant proportionate and up to date evidence

Most of Stagecoach’s serious concerns about the soundness of the plan arise from the fact that it has been prepared in advance of any up-to-date transport evidence and suitably robust transport mitigation strategy being advanced to support it. In essence, the Council has rolled forward the existing plan by 9 years, adding some additional sources of hosing supply, while still relying implicitly on a transport evidence base that was prepared 10 years ago.

This led to the formulation at that time of what can only be described as an attempt to develop an effective car-based mitigation strategy, creating capacity for general traffic added to accommodate unconstrained additional demands on an already over-taxed highways network – the Chichester Area Transport Strategy. Despite language in support of sustainable modes, no deliverable measures were identified to support either the extension of the bus network to serve allocated sites, and much less to create a vital improvement to the quality and reliability of public transport services. This approach reflected the approach set out in DfT Ministerial Circular 02/2013 “Development and the Strategic Highways Network”, applicable since the A27, which is the focus of the most severe difficulties, forms part of the national Strategic Roads Network.

This approach has proven ineffective even before substantial elements of housing land supply in the current plan come forward – in particular West of Chichester and West of Tangmere.

In addition, Circular 02/2013 has now been replaced by a new Ministerial Statement of 23/12/2022, DfT Circular 01/2022.

On both counts the transport evidence base and strategy needs to be properly revisited and established to provide effective mitigation for the plan, including current commitments that are being rolled forward.

The language of the current Ministerial Circular 01/2022 offers a highly condensed synoptic view of the proper approach to addressing transport matters in the planning system notwithstanding that it is directly concerned with the Strategic Roads Network. Videlicet:

“31. The NPPF expects local plans and spatial development strategies to be underpinned by a clear and transparent evidence base which informs the authority’s preferred approach to land use and strategic transport options, and the formulation of policies and allocations that will be subject to public consultation. The company will expect this process to explore all options to reduce a reliance on the SRN for local journeys including a reduction in the need to travel and integrating land use considerations with the need to maximise opportunities for walking, wheeling, cycling, public transport and shared travel.

32. The Transport Decarbonisation Plan indicates that carbon emissions from car and van use is the largest component of the United Kingdom’s total transport emissions. While action is being taken to decarbonise transport such that all new cars and vans will be fully zero emission at the tailpipe from 2035, the proposed location of growth in current plan periods and whether new developments would be genuinely sustainable remain important factors in demonstrating that a local authority area is on a pathway to net zero by 2050 and therefore compliant with the requirements of the Climate Change Act 2008.

33. Alongside this, the local authority should identify the key issues within their study area regarding transport provision and accessibility, setting out how the plan or strategy can address these key issues in consultation with (National Highways, and other transport stakeholders identified in NPPF paragraph 106b). It is the responsibility of the local authority undertaking its strategic policy-making function to present a robust transport evidence base in support of its plan or strategy. The company can review measures that would help to avoid or significantly reduce the need for additional infrastructure on the SRN where development can be delivered through identified improvements to the local transport network, to include infrastructure that promotes walking, wheeling, cycling, public transport and shared travel. A robust evidence base will be required, including demand forecasting models, which inform analysis of alternatives by accounting for the effects of possible mitigation scenarios that shift demand into less carbon-intensive forms of travel.” (our emphasis)

Within the text quoted above, references to National Highways and “the Company” can quite legitimately be extended, given the statements in NPPF paragraph 16, 25, 26 and 106b, to include all the relevant transport infrastructure and service providers in the plan area. Circular 01/2022 also has the weight of secondary legislation as a Written Ministerial Statement and thus should be considered to be highly material.
To date there has been little attempt to explore, to the degree necessary, strategies that conform to Circular 01/2022. It is thus not possible to conclude, as the Council has done, that the issues on the A27 that present a constraint to development, are insuperable.

In line with comments made elsewhere in the response to this pre-submission draft, the Plan thus requires substantial further work to be undertaken with key stakeholders to establish a suitably effective and demonstrably deliverable transport mitigation strategy, to sustainably meet the District’s identifiable development needs and where apparent and appropriate, also ensure that wider cross boundary strategic issues are appropriately addressed, in conformity inter alia, with the Duty to Cooperate, NPPF paragraph 16 and 104-111 inclusive, and DfT Circular 01/2022 and to ensure the Plan’s own Strategic Objectives can be met.

7.2. Policy T1 Transport infrastructure
Stagecoach Objects because the Plan:
• does not comply with the duty to cooperate
• is unsound as it does not conform to the National Planning Policy Framework
• is not effective
• is unsound because it is not based on relevant proportionate and up to date evidence

As described in comments elsewhere, Stagecoach does not see that a suitable proportionate and up-to-date basis exists to properly and appropriately address the transport issues in the plan area.

The 2023 Transport Study does not perform this role adequately but, contrary to the explanatory memorandum, is a scheme intended only to facilitate car-borne movements through some of the key junctions. There is no evidence that an holistic integrated and strategic approach to transport mitigations has been prepared. Certainly Stagecoach has not been involved in any of the discussion about appropriate transport measures in support of the plan, including the Transport Study 2023, contrary to the expectations set out in NPPF at paragraph 16 and 106.

Notwithstanding out fundamental concerns about the transport evidence case and mitigations strategy, Policy T1 reflects a weak and ineffective approach, that seeks to try and define a strategy post-adoption.

Contrary even to the explanatory memorandum for the policy, which seeks to maximise the contribution of sustainable modes, the policy is phased in such a way that it gives basis for previous “predict and provide” solutions to facilitate and support current levels of car dependency – already shown to be undeliverable and unaffordable – will nevertheless be the first rather than the last resort. There is no commitment to seek to maximise the contribution made by sustainable modes to meeting mobility needs. Nor is there any recognition that current chronic congestion and lack of network resilience jeopardises the ongoing attractiveness and long- term sustainability of the current public transport offer.

To be effective and create alignment with national policy, and also provide for an up-to-date transport evidence base and strategy to be adduced, Policy T1 should be modified to read:

“Integrated transport measures will be developed to mitigate the impact of planned development on the highways network, improve highway safety and air quality, promote more sustainable travel patterns and through providing in the first instance, new and improved infrastructure and services that will be credible effective in maximising the encourage increased use of sustainable modes of travel, such as public transport, cycling and walking.

To achieve this, the council will work with National Highways, West Sussex County Council, other transport and service providers (including through the Traffic and Infrastructure Management Group)
and developers to provide a better integrated transport network and to improve accessibility to key services and facilities…

All parties, including applicants, are expected to support these objectives by:

1. Ensuring that new development is well located and designed to avoid or minimise the
need for travel, encourages maximises the use of sustainable modes of travel as an a credible alternative
to the private car and directly provides or contributes towards new or improved transport infrastructure;

2. Working with relevant transport infrastructure and service providers to improve accessibility to key services and facilities with primary emphasis on sustainable modes, and to ensure that new facilities are easily accessible by sustainable modes of travel;

3. Targeting investment to provide local travel options as an that represent a clearly credible alternative to the car use, focusing on the delivery of improved integrated bus and train services, and improved pedestrian and cycling networks, including the public rights of way network, based on the routes and projects identified in the Local Transport Plan, West Sussex Bus Service Improvement Plan, Local Cycling and Walking Infrastructure Plan (LCWIP) and the Infrastructure Delivery Plan;

4. Planning to achieve the timely delivery of transport infrastructure on and approaching the A27 and elsewhere on the network, needed to support new housing, employment and other development identified in this plan;

5. Phasing the delivery of new development to align with and where possible facilitate the provision of new and improved transport infrastructure and services and the outcomes of monitoring travel demand on the network, including that arising from areas immediately adjoining the plan area. It may also be Where necessary to achieve this alignment proactively phase development will be phased to take into account the monitoring and effectiveness of travel plans demands on the network and to ensure that measures are implemented to support the highest possible level of encourage sustainable travel behaviour.;

6. Using demand management measures, such as travel plans, to manage robust methodologies to assess travel demand and minimise the need for new or improved transport infrastructure as part of the monitor and manage process.

7. Delivering a coordinated package of infrastructure improvements at and approaching to junctions on the A27 Chichester Bypass along with other small-scale junction improvements interventions within the
city and elsewhere, as identified through the monitor and manage process. These will increase road capacity, reduce traffic congestion, improve safety and air quality, and improve access to Chichester city from surrounding areas, first by maximising the contribution of sustainable modes to meeting mobility demands, then, and only as evidenced by robust modelling and option testing, providing increased highway capacity for general traffic.

…”

7.3. Policy T2 Transport and Development
Stagecoach Objects because the Plan:
• is not effective
• is unsound because it is not based on relevant proportionate and up to date evidence

Section 1 b) of T2 will be ineffective as, absent measures to ensure buses can run reliably and efficiently, improved bus services will not be possible, in support of the plan’s own stated broad approach to transport mitigation, as well as wider local and national policy.

The draft policy does not require improvements to the quality of services such that sustainable choices will be materially more attractive than car use for many local journeys. Without this the Plan’s Strategic Objectives cannot be fulfilled and the objectives of the Plan and this policy, read in its own terms, will not be realised, where reduction in private car use is concerned. It is thus ineffective.

Absent measures to make bus services more reliable and more efficient, by insulating them from chronic congestion as far as possible, still further operating resource and therefore costs, will be needed to just to reliably run existing service frequencies, and capacity, as vehicle productivity continues to be more and more adversely affected by chronic delay. This will be further aggravated by increasing incidence of severe unpredictable service breakdown arising from incidents of diverse kinds on the network, especially on or around the A27, including that arising from more regular severe weather events. Longer journey times can only be expected to lead to relative disadvantage of bus services compared to personal car use, entirely contrary to the objectives of national and local policy, including Policy T1. It can also expect to lead to a dampening effect not on car use, but on bus patronage, threatening the ongoing viability of bus services across the plan area.

Section 1 b) of T2 should be modified to read:
“b) Maximise opportunities for the use of sustainable travel modes through provision of direct and efficient access both to either the existing networks or and through providing such new infrastructure or public transport services, as can be credibly expected to reduce reliance on the private car and work towards achieving net zero in greenhouse gas
emissions by 2050;”

Section 1 d) of T2 will be ineffective as the location of development is fixed by this plan. We commend the fact that all the strategic allocations are or will be served by regular bus services.

However, the use of public transport services, where available, depends on the relevance and reliability of these services. Furthermore, provision of services without them generating sufficient patronage to support their long-term operation also threatens the sustainability of the plan and its supporting transport strategy. This is especially true of new services such as those intended to serve West of Chichester and Tangmere and East of Chichester Strategic Allocations.

This can only be assured by the plan being supported by specific measures to ensure buses can operate efficiently and reliably on the existing and projected services intended to serve the developments concerned, and also at the same time secure behavioural change from existing development.

To be sound and effective, the policy T2 1 d.) should be changed to read:
“d) Ensure major development is located to proposals and the supporting mitigation measures enable the use delivery of high-quality, reliable and effective public transport to present the most relevant possible choice to access local services and facilities including employment, leisure and education facilities”;

The Policy T2 makes no provision for buses, where necessary, to enter and make efficient and safe progress through major development sites. The plan is thus out of conformity with NPPF paragraphs 104-106. It makes no provision to ensure that penetration of bus services is achieved at a suitably early point in the development trajectory, undermining the achievement of the goals of the Plan and this specific policy. As a good example, West of Chichester Phase 1, currently under construction, cannot be served by buses as a strategy to effect interim bus penetration was never made.

Policy T2 1 f.) should therefore be amended to read:
f) Ensure that the layout and design of the site development proposals provides effective penetration of the site by sustainable modes, at all points in the development build-out, including public transport where appropriate; and sufficient space for all vehicles to manoeuvre without compromising the safety of pedestrians and cyclists, the efficiency of bus services, or the ability to provide an appropriate level of landscaping across the site”

Policy T2 3.) regarding Travel Planning depends entirely on its effectiveness on the quality and relative attractiveness of sustainable alternatives over car use. In the absence of efficient frequent, reliable and direct public transport services (or similarly, high quality facilities for active travel, Travel Plans will continue to be the entirely ineffective “tick box” exercises that they generally are today, evidenced by much lower levels of public transport use in most new developments than it seen in nearby established neighbourhoods, as demonstrated broadly by Census data in 2011, 2011 and 2021.

For this policy to be effective an up-to date transport evidence base and strategy, underpinning a series of specified interventions to promote the relevance and effectiveness of all sustainable does including public transport in particular, needs to be put in place.


8. Chapter 9 Infrastructure – Policy I1 Infrastructure provision
Stagecoach Objects because the Plan:
• does not comply with the duty to cooperate
• is unsound as it does not conform to the National Planning Policy Framework
• is not effective
• is unsound because it is not based on relevant proportionate and up to date evidence

Policy I1 could not expect to be effective without a clear understanding of the effectiveness and costs of a defined series of measures that are laid out in this Plan and its IDP, to mitigate the transport impacts of the development strategy.

Where the Chichester Transport Study is concerned the only meaningful work has focused on the definition and delivery of a range of highways capacity schemes mainly on the A27 around Chichester.

As we have discussed elsewhere the effectiveness of these schemes is insufficient as set out at Tables 8.1 and 8.2 of the Chichester Transport Study 2023. The plan itself admits that the deliverability of this package cannot be afforded by developer contributions alone.

The Chichester Transport Study 2023 does not attempt provide a realistic assessment of costs to deliver these schemes, despite the fact that they have been under evaluation for many years. Nor does it offer any assurance that the schemes are technically achievable. Rather, it states the opposite:

“9.2.3 No investigation has been carried out into specific land ownership details, or into the location details or cost of moving statutory undertakers and utility apparatus within the areas of the scheme. No design assessments were carried out at this stage to ascertain the deliverability of the proposals except where any Health and Safety concerns were raised.”

Thus on the grounds of effectiveness, deliverability and affordability, the measures on which the Plan relies must at the very least be considered to involve an exceptionally high level of risk. Since Policy I1 is founded on these assumptions, it cannot be considered effective.

As we set out elsewhere, the Plan has been advanced on the basis that if any additional sustainable transport measures are required, these mitigations should be retroactively considered and defined after adoption of the Plan. In the light of the doubts that are apparent of both the deliverability, affordability and effectiveness of the Chichester Transport strategy this is especially unsatisfactory even if existing baseline conditions were reasonably acceptable.

However, the Chichester Transport Study 2023, as did its predecessors, makes plain that that existing problems are acute, and can rightly be considered “severe” in the sense of NPPF paragraph 111. Waiting to define deliverable affordable alternatives is an entirely inappropriate approach to the local plan transport mitigation strategy. Such an approach also makes it impossible to consider prior to adoption how far the transport impacts of the plan can be cost-effectively mitigated by alternative means, or whether they are deliverable having regard to technical achievability, land control, development viability, or any combination of the above. Thus, the plan cannot be considered justified, or effective.

Given the mutual dependence of development strategies in Chichester and Arun in particular on these measures this should be seen as crucial of the fulfilment of the Duty to Cooperate.

The remedy for this is ultimately to put in place a suitable transport mitigation strategy following a strategic appraisal of options through review of the LSS. This then must be supplemented by more detailed development specific and localised scheme definition, including, where necessary, bus priority and other measures to support the substantial promotion of the attractiveness of public transport in key bus corridors over private car use. This would then be reflected by costed proposals in the IDP.

Leaving these fundamental weaknesses to one side, even if such a strategy and mitigation package were defined, there is no mention of public transport in the policy even though it is clearly a key part of the policy environment and mitigation strategy for the plan as expressed in the explanatory memorandum for I1, but also at Policies T1 and T2. I1 thus does not effectively support the realisation of the intent of Policies T1 and T2.

Policy I1 iii) should therefore be modified to read:

“(iii) Safeguard the requirements of infrastructure providers, having regard to requirements within and where appropriate across the boundaries of the plan area, including but not limited to:
…
• Highways including specific measures to accommodate improved active travel and public transport level of service and cycle lanes, and…”

At limb v) the Policy expects developers to meet the “in perpetuity costs of operating and maintaining infrastructure”. This shackles development management decisions to developers assuming what are infinite costs – given that “in perpetuity”, read properly, can only mean “without any limit in time”. This means that it is impossible to meet the statutory tests on developer obligations set out in the Community Infrastructure Levy Regulations 2010 (as amended) at Regulation 122, also repeated in NPPF. This policy cannot be lawfully implemented and it is thus ineffective.

In the absence of an up-to-date transport mitigation strategy that is fit for purpose, at the point the Plan is examined these costs of any additional infrastructure are not known in any case. The strategy and its costs, including its affordability and deliverability, are crucial to assessing if the Plan is sound.

Subject to an appropriate defined transport mitigation strategy being arrived at, to be sound, the Policy I1 v) should be modified as follows:

(v) To consider and meet as appropriate the in-perpetuity delivery costs of infrastructure and, where appropriate, improved services, to the point where its long-term operational sustainability is credibly assured from mainstream sources. Where adoption is not envisaged by local authorities, that must include arrangements for its future ongoing management and maintenance;


9. Strategic and Area Based Policies

9.1. Policy A1 City Centre Development Principles
Stagecoach Objects because the Plan:
• is unsound as it does not conform to the National Planning Policy Framework
• is not effective
• is unsound because it is not based on relevant proportionate and up to date evidence

Chichester City centre is rightly identified at 10.2 and 10.4 as the commercial and service hub of the District. It is also acknowledged to be the most accessible place in the District by sustainable modes, public transport in particular.

Boosting the vitality of the city centre is something that Stagecoach strongly supports. Irrespective, the enhancement of the commercial and cultural life of the District in the place where these opportunities can be accessed broadly by sustainable modes, is one that has long been at the heart of national planning policy for town centres, reflected in the “town centre first” approach to locating major trip generating uses.

Paragraph 10.5 exposes an unbalanced and unsound preoccupation with aesthetic matters in its approach to the town centre, and far too little to ensuring that the central place function is enhanced through protecting and enhancing the quality of public transport access.

The city is relatively small but at the heart of an extensive hinterland, and thus the role of bus in supporting sustainable access to and enhanced city centre venue is one that needs appropriate recognition and emphasis. It is important to note that a dominant number of key service and facilities such as the General Hospital are relatively close to the city centre. This directly contributes to driving travel demand into the city, causing congestion. Most importantly, it also makes the task of mitigation simpler, given the impact a suite of active and sustainable measures can have within the same close proximity.

Policy A1 does not provide this. As such, achieving the strategic objectives of the plan is seriously threatened, and the plan is thus not effective.

The Plan needs to ensure that the approach to city centre regeneration maintains and enhances public transport access, interchange and inter-modal connectivity. It also needs to ensure that bus service stopping and interchange facilities are able to address increases in future demand, anticipated by the clear intent expressed elsewhere in the Plan that public transport should be meeting a greater proportion of mobility needs, in a growing district. Achieving this demands an ambitious approach to the location, quality and capacity of bus stop and interchange.

We have been in discussions with the District Council about this, alongside West Sussex County Council, for a very considerable period. Stagecoach has always been keen to help facilitate the Council’s aspirations for the city centre, and we continue to hold this intention. However, this cannot be at the expense of a material diminishing of the convenience and fitness-for-purpose of bus stop infrastructure and interchange. Stagecoach has significant concerns that current proposals to remove the bus station and have all bus services operate from the street kerbside, on an inner distributor road with similar of reduced net stop capacity, fall short of promoting attractive, convenient bus access to the central area as a destination.

For the longer term and where the objectives of the draft plan are concerned looking ahead to 2039, they clearly fall short of enhancing the convenience and attractiveness of public transport use. Much less do they make sufficient provision for a material increase in bus frequency, connectivity, and interchange convenience, on which the draft plan explicitly relies. It is vital that the District Council is clear in policy about its objectives for public transport in the city centre. These objectives must also carry sufficient weight when held in tension with other aspirations for the centre and the constraints on achieving them.

For the Plan to be sound, properly effective and compliant with NPPF, the approach to the City centre cannot ignore its role in the provision of sustainable transport service and connectivity.

Policy A1 should therefore be modified to properly reflect this crucial function, on which the vitality of the city centre must increasingly depend if unacceptable impacts on congestion, air quality and amenity are not to arise. This is still more crucial if wider aspirations to secure a more sustainable society and mitigate carbon are to be achieved.

“…This will include provision for development and proposals that:
• Support and strengthen the vitality and viability of the city centre and its role as a shopping/visitor destination, employment centre, public transport hub and a place to live;

• Support and promote facilitate improved access to the city and with increased emphasis on sustainable modes of travel, with particular regard to enhancing the public transport interchange role of the city centre area, in accordance with the transport strategy for the city and…”

9.2. Policy A3 Southern Gateway Development principles Chichester Bus Station, Bus Depot and Basin Road Car Park
Stagecoach Objects because the Plan:
• is not effective
• is unsound because it is not based on relevant proportionate and up to date evidence

There has been aspiration to redevelop the bus station and nearby bus depot from many years. Stagecoach has been engaged with detailed discussion with the District Council on this matter over a very extended period. We confirm that these discussions have reached a relatively mature stage, however at the time of writing are not concluded.

Stagecoach recognises and supports in principle the Council’s wider aspirations for the “Southern Gateway”, and this has governed our approach to the Council to date. We continue to have no “in principle” objection to relocating our administrative, engineering, operational and customer service facilities.

Leaving our proprietary interests entirely to one side, it remains vital that in so doing, the effectiveness, attractiveness and convenience of these facilities is not compromised, as we have outlined in our representations to Policy A1, if wider national and local transport policy, and the local plan strategy itself, are to be effectively achieved.

The depot is crucial infrastructure to support the safe, reliable and legally-compliant operation of Stagecoach bus services over a very extensive area covering the entirety of the District and beyond. Without securing equivalent facilities, that are fit-for-purpose, many of our services would have to cease.

If buses are to provide a greater and more attractive level of service (still more so if they are to be electrified) larger, more capable depot facilities, and city centre bus interchange facilities will be necessary.

Notwithstanding that the bus station and depot sites are leased from the District Council, these leases terminate well beyond the end of the plan period.

Finding suitable sites for a replacement bus depot in Chichester, in common with all similar localities especially in southern England, is extremely challenging. As a sui generis use, bus depots do not automatically benefit from policy support on land allocated for employment uses. Most bus depots benefit from being legacy assets established under very different economic conditions. That is the case here. The value of a depot site for redevelopment net of demolition and remediation costs, rarely approximates to that able to sustain the acquisition of land in a tight wider employment land market, and the construction of suitable new facilities.

Furthermore, the costs of operating bus services are sensitive to the parasitic costs of vehicle and staff hours and mileage associated with “dead running” to a remote depot location from the operational network. Here, the existing depot site is ideal, and any replacement will unavoidable add ongoing operational costs to the operation that cannot be directly recovered.

We confirm that a replacement depot site has been identified and has in principle been agreed, subject to overcoming issues with the disposition of existing and future structures on the site. However, the site is recognised as not capable of accommodating meaningful operational expansion. This is just one of the most important foundational reasons why a positive transformation of bus productivity needs to be achieved, across the plan area and beyond, to support delivery of greater bus mileage and frequencies with the same level of operational resource. At the time of writing, we are not fully convinced that the proposals for the relocation will be sufficiently fit-for-purpose in the event the above is not achieved. Thus, we must raise a concern that the bus depot site might not be available during the plan period. While there is a strong probability it will be, the certainty surrounding the availability of the site, especially within the first 5 years of the plan, needs to be made transparent.

9.3. Policy A4 Southern Gateway - Chichester Bus Station, Bus Depot and Basin Road Car Park
Stagecoach Objects because the Plan:
• is not effective
• is unsound because it is not based on relevant proportionate and up to date evidence

Regarding the removal of the bus station, without equivalent replacement, Stagecoach has significant concerns. Pressures and conflicts at the current bus station site have been gradually rising for several years, arising from increasing use and the need for additional scheduled vehicle layover periods to reduce the risks of accumulated late running from traffic congestion. Peak passenger volumes have recovered strongly on several routes, however passenger accumulations resulting from more frequent delays and disruption have added substantial further pressure on limited space.

Under current plans, buses and bus passengers will be displaced to bus stops at new locations outside the city centre, along Avenue de Chartres. This road was always intended to be a relatively high-speed traffic route, outside the historic core of the city. The city centre has evolved in the subsequent years to reinforce already strong natural severance, with the highway lying beyond the city walls and the green space along the Lavant. It is a traffic dominated, unsurveilled and unattractive environment, reflecting the intended function of the road as an efficient movement corridor for high traffic volume, and nothing more. Avenue de Chartres is relatively close to the rail station and pedestrian connectivity can be provided at broadly equivalent distance to the current bus station, but again it is unsurveilled and currently unpleasant, lacking natural legibility or any sense of prominence.

We understand kerbside capacity on Avenue de Chartres will be strained even to accommodate current levels of service, with no expansion possible. There is therefore a strong probability that to accommodate more frequencies and key new routes, such as West of Tangmere, East of Chichester and West of Chichester allocations, additional future bus stops must occupy a different location. This makes interchange between routes and rail services substantially challenging and less attractive.

The emerging arrangements risk marginalising public transport and public transport users substantially. This strongly undermines achievement of the wider plan objectives and delivery of a significantly greater role for public transport. If substantial public transport growth is to be accommodated in a growing city and hinterland, as the draft plan anticipates, then a more ambitious strategic approach must be taken. This should plan for additional and improved facilities to accommodate all services predicted to be required, whilst enhancing the passenger experience to ensure meaningful and attractive modal choice.

There is therefore a need for the plan to evidence how these issues will be appropriately resolved, having regard to a suitably ambitious approach that properly supports clear objectives to boost the relevance of public transport. The current policy is weak, unspecific and indifferent to achieving the strategic objectives of the plan, including a transport strategy in support of the plan, and as such it is ineffective.

Policy A3 should therefore be modified to read:
“…
• Be designed to encourage and facilitate substantial increase in the use of active travel and public transport to, from and through the city centre.
…”

In line with the commentary above Policy A4 should also be modified to read:

3. Enhance the public interchange function of the immediate area, the public realm, particularly connections to the railway station and the city centre via South Street, Southgate and Basin Road for pedestrians, cyclists and public transport users, and to National Cycle Route 2 and Route 88 which run close by. Suitable replacement bus stops and layover facilities should be provided to replace those at the bus station in line with reflecting the objectives of the West Sussex Bus Service Improvement Plan, and to facilitate growth to meet the requirements of the plan’s development strategy. Routes and crossings should reflect pedestrian desire lines, and public art should be incorporated to create a sense of place;

4. Enhance the public realm, in support of this and wider objectives, incorporating public art and other measures to create a strong and attractive sense of place.
…(renumber remaining points)

9.4. Policy A6 Land West of Chichester

Stagecoach Objects because the Plan:
• is unsound as it does not conform to the National Planning Policy Framework
• is not effective

This is an existing Local Plan allocation. The public transport strategy for the site depends on the delivery of the second phase which Stagecoach notes is the subject of several applications now awaiting review and determination by the Council.

The site represents a compact form of development adjoining the city, as the most sustainable settlement, meeting housing needs close to where they arise, and affording very good opportunities for the use of sustainable modes, especially walking and cycling.

It is vital that a bus service is delivered to serve the site at the earliest potential. This was anticipated to be at the start of Phase 2 and will require the early delivery of the entire length of the spine road between the Old Broyle Road and Westgate and making it available for bus services.

It is not clear if the costs of pump-priming the service mentioned in the draft policy are anticipated to be met by the developer. Without such funding, the service will not be deliverable as years of losses will never credibly be covered from future profit. It is likely that the current wording will be interpreted by the developer as meaning that they have no such obligation binding upon them. Not does policy set out any specification for this service, thus its costs and the basis for securing developer contributions does not exist.

As such any wider transport strategy, that seeks to secure a greater role for the use of public transport, and the aspiration for this allocation cannot demonstrably be met. The policy is ineffective.

Policy A6 should be modified to read:
“…
10. Make provision to accommodate and secure delivery of for regular bus services linking running through the site to Chichester city centre operating at least every 30 minutes Monday-Saturday, and new and improved cycle and pedestrian routes linking the site with the city,
…”

9.5. Policy A7 Land at Shopwhyke
Stagecoach Supports
This is an existing Local Plan allocation, largely built-out, that benefits from an existing set of permissions.

The public transport strategy for the site depends on the delivery of effective bus priority at Oving Crossroads. The current recently implemented scheme, undertaken by National Highways, makes no provision for effective bus priority and needs considerable re-evaluation.

The site represents a compact form of development adjoining the city, as the most sustainable settlement, meeting housing needs close to where they arise, and affording very good opportunities for the use of sustainable modes, especially walking and cycling. It lies on a new bus corridor that will shortly be put in place, running to Tangmere via Shopwhyke. The allocation is being significantly consolidated by further development in the immediate vicinity which strongly supports the potential for this new service.

As we explain in our representations for East of Chichester proposed allocation A8, and West of Tangmere Allocation A14, a clear corridor strategy to effect bus priority is needed, that should be delivered in support of that further growth, and that at Tangmere SDL. However this allocation is a near complete commitment and there is no scope through policy regarding this land to effect this outcome.

It is notable that Point 6) of policy A7 makes mention of a bus service. This language reflects the currently adopted Local Plan policy and has underpinned the existing permissions. The failure of any bus service to be delivered demonstrates from first principles that this Policy has been entirely ineffective. It is important that lessons are learned from this in the Local Plan Review.

9.6. Policy A8 Land East of Chichester
Stagecoach Objects because the Plan:
• is unsound as it does not conform to the National Planning Policy Framework
• is not effective
• is unsound because it is not based on relevant proportionate and up to date evidence

This proposed allocation lies next to unallocated land that is already consented as a departure from the adopted development plan, with 143 units near completion south of Oving Road (20/02471/FUL). Additional land, also unallocated but similarly consented, has now commenced north of Oving Road (88 units under 21/02197/FUL). This and the allocation site consolidates earlier development at Shopwhyke brought forward under the current Local Plan, and allocated again as draft policy A7.

Development at Shopwhyke was brought forward on the basis of a premise that the developer would provide or somehow arrange a bus service, that was reflected in the policies of the current Local Plan. This was secured by an unenforceable condition. No bus service has been provided, as there was inadequate clarity regarding the basis on which the costs of establishing such a service would be met by the developer, and the expectations of policy on the developer. The site does however lies on a logical new bus corridor between Chichester and West of Tangmere along the Oving Road.

In addition, an expectation that modifications to the Oving Crossroads would effect bus advantage have proven false – the arrangements put buses into a similar or longer queue than if they use the route available to general traffic to and from the A27.

Stagecoach strongly supports the principle of bringing this land forward. However, the soundness of the site depends on deliverability of a regular, reliable and direct bus service along the Oving Road, taking advantage of effective bus priority.

Given the failure of existing policy in the adopted Local Plan covering the proposed A7 allocation to deliver a bus service, it is of great concern that there is no draft policy to adequately address the issue. The policy is out of conformity with NPPF paragraph 104-105 in that sustainable modes do not offer realistic choices, much less an attractive one, and as such also does not secure the objectives of national policy nor of the plan itself.

Currently the proposed allocation is not served at all by public transport. Policy needs to ensure there is a policy basis to secure contributions to deliver such a service, which may well take the form of a proportionate contribution to deliver a new service or enhance provision that is put in place between Chichester along the Shopwhyke Road to west of Tangmere.

To become sound Policy A8 must be modified to read:
“…
12. Provide for improved high quality connectivity by sustainable travel modes and focused in particular on a corridor between Chichester city centre and Tangmere along Shopwhyke Road, including new improved cycle and pedestrian routes, and a frequent bus service including linkages with Chichester taking advantage of effective bus priority measures on Oving Road at the A27;
…”

9.7. Policy A9 Land at Westhampnett/North East Chichester
Stagecoach Objects because the Plan:
• is unsound as it does not conform to the National Planning Policy Framework
• is not effective
• is unsound because it is not based on relevant proportionate and up to date evidence

This land is already allocated and consented as part of the existing 2016 Local Plan. All reserved matters are determined.

The site lies on service 55 between Chichester, Westhampnett and Tangmere. This established service benefits from additional demand from the development at Phase 1. Phase 2 which is currently well underway, does not benefit directly from bus services. However it is a compact and logical form of development where walking and cycling to local facilities and employment is a credible option.

The existing allocation rolls forward policies in the 2015 Local Plan. In so doing it is possible to see which have been effective.

Point 9. regarding bus service and routing has not been effective. In particular the potential for a bus only link between the site and Graylingwell has not been established as policy anticipated. Given congestion around the Portfield area acutely affects public transport this, or alternative methods to secure bus priority over private car use, a clear and unequivocal policy steer is required.

The lack of an up-to-date transport evidence base is ultimately at the root of these issues. Arguably the policy and allocation can only be made sound once this refreshed evidence base in place.

However, it is possible that the allocation could be made sound by modification of Policy A9 as follows:
“…
9. Make provision for regular, direct and reliable bus services linking the site with Chichester city centre, and new and improved safe and convenient cycle and pedestrian routes linking the site with Chichester city, the South Downs National Park and other strategic developments to the east of Chichester city including Tangmere. These objectives could include exploring the potential for a bus only route require a deliverable scheme to afford bus priority through Portfield, and potentially linking the development with the Graylingwell area through use of a modal filter;
…”

9.8. Policy A10 Land at Maudlin Farm
Stagecoach Objects because the Plan:
• is unsound as it does not conform to the National Planning Policy Framework
• is not effective
• is unsound because it is not based on relevant proportionate and up to date evidence

Stagecoach supports the identification of this site, which consolidates significant recent development on an existing public transport route. It is relatively close to the city and very near substantial centres of employment and services that can be reached by active travel modes, helping damp the demand for car use. It is a site which, with appropriate measures to substantially boost the relevance and attractiveness of sustainable choices, could be made sustainable.

The draft policy is not sufficiently clear and robust about the measures to support the damping of car trips that will be required to support development at this location without having an unacceptable impact on traffic conditions, congestion and the reliability of bus services at Portfield and over a wider area. In fact, the only reference that is made is that the development should fund highways capacity improvements. These improvements, as set out in the Chichester Transport Strategy, do not accommodate growth from additional sites over and above those already allocated in the 2015 Local Plan. They do not secure any mode shift away from car use. An update of this strategy has yet to be produced. This is an unsound, inadequately evidenced approach, that will be ineffective.

Policy A10 should accordingly be modified to read:
“…
5. Provide safe and suitable access points for all users, including a main vehicle access from Old Arundel Road and, subject to further assessment, a secondary vehicle access from Dairy Lane. The development should make the requisite contributions for off-site highway improvements to transport infrastructure and services, with an emphasis o maximising the attractiveness of sustainable modes, in conformity with the Policy T1 (Transport Infrastructure) and T2 (Transport and Development), which will include promoting sustainable transport options high quality pedestrian, cycling and public transport routes;
…”

9.9. Policy A11 Bosham – Land at Highgrove Farm
Stagecoach Objects because the Plan:
• is unsound as it does not conform to the National Planning Policy Framework
• is not effective
• is unsound because it is not based on relevant proportionate and up to date evidence

Stagecoach supports the identification of this site, which consolidates significant recent development on an existing high quality public transport route, including Stagecoach service 700 and the Coastway rail service available at Bosham Station. It is relatively close to the city and very near substantial centres of employment and services that can be reached by public transport and cycling, offering strong potential to materially damp the demand for car use.

There are serious risks that development in the A259 corridor west of Chichester could place further demands on the junctions at Fishbourne and approaching Emsworth, leading to even more chronic and severe delay to travellers and in particular to bus services.

Nevertheless, given the potential to effect bus priority on the approaches to Fishbourne Roundabout, it is a site which, with appropriate measures to substantially boost the relevance and attractiveness of sustainable choices, could be made sustainable.

The draft policy is not sufficiently clear and robust about the measures to support the damping of car trips that will be required to support development at this location without having an unacceptable impact on traffic conditions, congestion and the reliability of bus services on the approaches to the A27 and over the wider corridor to the west. In fact the only reference that is made is that the development should fund highways capacity improvements. These improvements, as set out in the Chichester Transport Strategy, do not accommodate growth from additional sites over and above those already allocated in the 2015 Local Plan. They do not secure any mode shift away from car use. An update of this strategy has yet to be produced. This is an unsound, inadequately evidenced approach, that will be ineffective.

Policy A11 should accordingly be modified to read:
“…
8. Provide safe and suitable access points for all users, including a main vehicle access
from the A259. The development should make the requisite contributions for off-site highway improvements to transport infrastructure and services, with an emphasis o maximising the attractiveness of sustainable modes, in conformity with the Policy T1 (Transport Infrastructure) and T2 (Transport and Development), which will include promoting sustainable transport options high quality pedestrian, cycling and public transport routes, and providing substantial peak journey time advantage for sustainable modes on journeys crossing the A27 at Fishbourne;


9.10. Policy A12 Chidham and Hambrook
Stagecoach Objects because the Plan:
• is unsound as it does not conform to the National Planning Policy Framework
• is not effective
• is unsound because it is not based on relevant proportionate and up to date evidence

Stagecoach supports the identification of this site, which consolidates significant recent development on an existing high quality public transport route, including Stagecoach service 700 and the Coastway rail service available at Nutbourne Station. Substantial centres of employment and services that can be reached by public transport and cycling, offering strong potential to materially damp the demand for car use.

There are serious risks that development in the A259 corridor west of Chichester could place further demands on the junctions at Fishbourne and approaching Emsworth, leading to even more chronic and severe delay to travellers and in particular to bus services.

Nevertheless, given the potential to effect bus priority on the approaches to Fishbourne Roundabout, it is a site which, with appropriate measures to substantially boost the relevance and attractiveness of sustainable choices, could be made sustainable.

The draft policy is not sufficiently clear and robust about the measures to support the damping of car trips that will be required to support development at this location without having an unacceptable impact on traffic conditions, congestion and the reliability of bus services on the approaches to the A27 and over the wider corridor to the west. In fact the only reference that is made is that the development should fund highways capacity improvements. These improvements, as set out in the Chichester Transport Strategy, do not accommodate growth from additional sites over and above those already allocated in the 2015 Local Plan. They do not secure any mode shift away from car use. An update of this strategy has yet to be produced. This is an unsound, inadequately evidenced approach, that will be ineffective.

Policy A12 should accordingly be modified to read:
“…
7. Development should make the requisite contributions for off-site highway improvements to transport infrastructure and services, with an emphasis on maximising the attractiveness of sustainable modes, in conformity with the Policy T1 (Transport Infrastructure) and T2 (Transport and Development), which will include promoting sustainable transport options high quality pedestrian, cycling and public transport routes, and providing substantial peak journey time advantage for sustainable modes on journeys along the A259, crossing the A27 at Fishbourne and where necessary on the approaches to Emsworth;

8. Facilitate improved sustainable travel modes, and new improved cycle and pedestrian
routes, including linkages with Chichester city and settlement along the East/West
Corridor;


9.11. Policy A13 Southbourne Broad Location for Development
Stagecoach Objects because the Plan:
• is unsound as it does not conform to the National Planning Policy Framework
• is not effective
• is unsound because it is not based on relevant proportionate and up to date evidence

Stagecoach agrees unequivocally that Southbourne is a location that could accommodate growth on a strategic scale. It has a substantial range of service available within the settlement, including secondary education. It is well connected by bus and rail service to key destinations, including Chichester, lying to the east and west.

This is one of the few locations identified for growth that represents substantial additional development in a new location to the strategy in the existing Local Plan adopted in 2015. Thus, the transport impacts of development on the substantial scale envisaged at Southbourne are not covered or accommodated by the Chichester Area Transport Strategy that lies behind the existing plan. This demands, from first principles, that substantial further transport mitigation measures are required.

We recognise and endorse fully that the intent of the draft plan for Southbourne as a Broad Location for Development on a strategic scale, includes “Maximising the potential for sustainable travel links through improved public transport, including consideration of opportunities to reduce community severance caused by the railway line as well as the inclusion of cycling and pedestrian routes.” (our emphasis).

The existing railway station at Southbourne is served regularly, however, it is not within the power of this plan to improve rail services. It is, however, well within the scope of action of the Local Planning and Highways Authority to work with bus operators to achieve a step change in the journey time, reliability, frequency and connectivity of bus services, and in particular the major corridor operated as service 700 by Stagecoach along the A259 between Havant and Chichester through Southbourne.

Notwithstanding the clear potential for sustainable connectivity in the western A259 corridor, there are very serious risks that development in the A259 corridor west of Chichester will place further significant car-borne demands on the junctions at Fishbourne and approaching Emsworth, leading to even more chronic and severe delay to travellers and in particular bus services, having the opposite effect to that intended: longer, less reliable and less frequent bus services, leading to a spiral of slowly declining use.

These risks, while very serious, look credibly likely to be entirely mitigated subject to carefully conceived and robust specified actions on the local highway network. It is perplexing to us that this potential still has not been identified, as part of a comprehensive “first principles” review of the transport evidence base. In particular given the former trunk status of the A259, the there is evident potential to effect bus priority on the A259, including on the approaches to Fishbourne Roundabout.

With appropriate measures, including but not limited to this, to substantially boost the relevance and attractiveness of sustainable travel choices, strategic development at Southbourne could well be made highly sustainable.

In the absence of a refreshed transport strategy and transport evidence base, the draft policy is not sufficiently clear and robust about the measures to support the damping of car trips that will be required to support development at this location without having an unacceptable impact on traffic conditions, congestion and the reliability of bus services on the approaches to the A27 and over the wider corridor to the west. In fact, the only reference that is made in Policy is that the development should fund highways capacity improvements. These improvements, as set out in the Chichester Transport Strategy, do not accommodate growth from additional sites over and above those already allocated in the 2015 Local Plan . They do not secure any mode shift away from car use. An update of this strategy has yet to be produced. This is an unsound, inadequately evidenced approach, that will be ineffective.

Policy A12 should accordingly be modified to read:

“…Development should be comprehensively masterplanned to achieve a high-quality design and layout that integrates well with the surrounding built and natural environments to enable a high degree of connectivity with them, particularly for pedestrians and cyclists, and provides good the highest possible quality of access to facilities and sustainable forms of improved public transport services.
…

4. Provide a suitable means of access to the site(s), and securing secure necessary off-site transport infrastructure and service improvements (including highways in particular to the A259 corridor between Emsworth and Chichester) in conformity with the Policy T1 (Transport Infrastructure) and T2 (Transport and Development) to promote sustainable transport options prioritising delivery of high quality pedestrian, cycling and public transport routes, and providing substantial peak journey time advantage for sustainable modes;
…”

9.12. Policy A14 Land West of Tangmere
Stagecoach Objects because the Plan:
• is unsound as it does not conform to the National Planning Policy Framework
• is not effective
• is unsound because it is not based on relevant proportionate and up to date evidence

Stagecoach strongly supports the principle of intensifying the level of development at the Strategic Development Location already identified and allocated West of Tangmere in the existing Local Plan. This serves to consolidate development at a location where effective and attractive public transport choices could be provided. It also conforms closely with the principle expressed in NPPF that the best possible use should be made of land on sites that are judged to be sustainable, or potentially sustainable locations for development.

It must be stressed that the current policy suite for the SDL has to date not brought forward development in this location. We recognise that a Master Plan has been adopted by the Council, and that a planning application (20/02893/OUT) for the full larger quantum of 1300 dwellings proposed in the draft plan has received a resolution to grant by the Council.

However, we are not aware that a sustainable transport strategy has been finalised.

Land West of Tangmere is not served by any existing regular bus services. Rather, an entirely new bus service corridor is anticipated to operate in the near term from Chichester through Tangmere and beyond towards Barnham. This would serve proposed allocations A7, A8 and West of Tangmere (A14) included in the draft Plan.

This is reflected in the language of the explanatory memorandum to Policy A14 at paragraph 10.65:
“Opportunities, in partnership with relevant authorities, to provide improved sustainable public transport routes linking the village with Chichester city, to improve cycle routes to the city, and better transport links to Barnham rail station and the ‘Five Villages’ area in Arun District; and..”

Initiating this service will be costly and will in large measure be funded not by developer contributions, but by DfT monies awarded through the West Sussex Bus Service Improvement Plan. It is crucial this service is both sustainable in the longer term without revenue support, and that the success of the service can be built on by scalable frequency improvements as strategic development comes forward in both Chichester District, and proposed allocations A7 A8 and A14, and in Arun District, in particular at Barnham, Eastergate and Westergate (BEW).

This demands measures to effect safe, direct and swift operation of the service especially within the city centre, where it approaches and crosses the A27 at Oving crossroads and on the eastern fringes of the District east and west of Tangmere. Without these measures, bus journey time and reliability will be severely compromised and the and impact of this service to damped car trip demands will be very substantially compromised. No such measures are proposed in the draft plan or its evidence base.

Changes to Oving Crossroads have recently taken place which, amongst other intentions, ostensibly provide bus advantage between Chichester and Shopwhyke. The junction in its current form does not offer material gain in bus journey time, as movements involve a less-direct route towards the city over an increased operating distance, much of which involves passage through heavily congested sections of the A27 and Westhampnett Road. A refreshed transport strategy supporting plan-led growth must revisit this area to secure an effective solution which offers bus customers the fastest and most reliable trip-time to and from the city.

In addition, the extension of public transport connectivity towards BEW and Barnham, including key links to secondary education and a logical railhead for journeys beyond towards Brighton and London as provided at Barnham Station, needs to facilitate bus priority between Tangmere and Nyton – whether using the A27, or preferably avoiding it altogether. There are significant safety concerns associated with the at-grade uncontrolled right-hand A27 exit onto the B2233 Nyton Road at Crockerhill Turn. This movement is also prone to extreme delay owing to the conflict with approaching westbound traffic on the A27, travelling at speed, which has priority. Our concerns with this junction in its current form can be expected to worsen with the increased traffic volumes predicted from new residential developments to the west of the city.

A solution providing a suitable short length of highway available only to sustainable modes, between Tangmere and Easthampnett, could provide a very effective solution to this. This would be deliverable within the scope of the separate proposed allocation at A19 Chichester Business Park, Tangmere. We comment on this separately.

Howsoever effected, a reliable direct and delay-free bus corridor between Barnham, BEW, Tangmere and Chichester could expect to secure very substantial elevation of the relative attractiveness of public transport over car use on the entire corridor and serve to effectively damp growth-related demands on this section of the A27. West of Tangmere, in the longer term, there is evident scope for the route corridor to operate as two branches – one via Shopwhyke and one via Westhampnett, effectively serving all the strategic developments proposed in the plan and transforming wider public transport connectivity to key employment destinations and services within and east of Chichester.

However, in common with all the other proposed allocations, the plan proposes no specific measures to provide, much less improve public transport or other sustainable modes to the site. This leaves the draft plan out of conformity with NPPF, especially paragraphs 104-106. The plan is inadequately evidenced and to the degree that public transport measures are identified and emergent, their successful implementation in the near and longer term will be jeopardised without clear measures to provide a safe as well as efficient bus route towards BEW and the Five Village area within Arun. The Duty to Cooperate is not effectively met and effective cross boundary collaboration on these strategic issues through the review of LSS is not demonstrated, despite the current version which identifies the issues.

To be made sound the LSS Review and a subsequent urgent review of the transport evidence base and strategy needs to take place. The strategic issues are especially critical east of Chichester, in our view.

Notwithstanding this foundational deficiency, to be made sound, Policy A14 should be modified to read:
“…
8. Subject to detailed transport assessment, provide primary road access to the site from the slip-road roundabout at the A27/A285 junction to the west of Tangmere providing a spine road link with secondary access from Tangmere Road. Development will be required to provide or fund mitigation for potential off-site traffic impacts through a package of measures in conformity with Policy T1 (Transport Infrastructure) and T2 (Transport and Development) and DfT Circular 01/2022 that maximise the relevance and use of sustainable travel modes, in particular bus services;

9. Make provision for improved sustainable travel modes between Tangmere and Chichester city, in partnership with relevant authorities, including improved direct, seamless safe and reliable and additional bus and cycle routes linking Tangmere with Chichester city, Shopwhyke and Westhampnett. In conjunction with measures in support of Allocation A19, Opportunities should also be explored contributions shall also be sought for providing improving high quality cycling and bus service transport links with the 'Five Villages' area and Barnham rail station in Arun District; and…”


10. Concluding comments

Stagecoach recognises its role as a key stakeholder in the plan, as well as a local employer and corporate citizen. We recognise the primacy of the plan-led system as the mechanism intended to resolve complex challenges, including the proper alignment of transport and spatial planning, which as the National Decarbonisation Strategy for Transport among other policies makes clear, has never been more vital.

In making our representations, we emphasise that we are entirely supportive of the Local Planning Authority and the relevant Highways and Transport Authorities, in their efforts to properly manage the amount and pattern of development to secure vital policy objectives. We recognise that balancing delivery of assessed development needs with a wide variety of other constraints is a very difficult task.

The transport issues faced by the plan are recognised in the draft plan as being serious and long-standing. We believe that there are ways to arrive at a suitable transport mitigation strategy that has regard to wider strategic issues and resolves existing problems in a much more effective way than those pursued to date.

We support the spatial strategy of the plan as it evidently provides the basis to secure the necessary step change in the quality and use of sustainable transport modes, as it explicitly seeks to do. However thus far, there has been insufficient work done to define the measures that will credibly secure these outcomes.

Stagecoach therefore urges the authorities to draw us into the necessary effective ongoing collaborations that is expected by NPPF paragraph 16 and 106; and DfT Circular 01/022, to do this work, prior to, rather than after the submission of the draft plan. We look forward to being approached to initiate this dialogue at the earliest opportunity.

Policy A15 should be removed and Policies H2 and H3 amended to reflect a realistic allocation of 125 houses which is still generous compared to other local area with better services.

I feel very strongly the local plan is ill thought through and a unbalanced distribution of houses that doesn't reflect the nature of rural villages. Loxwood is a rural village with no public transport links that are usable for the working population, no work opportunities, a serious lack of sewage capacity, no local grocery shop and yet the council deem it suitable for over 312 houses which will give a 50% increase in dwellings and a potential for significantly more as a 'strategic' location-it is completely bonkers. We are not a town!

It is also very disrespectful of the council to ignore our latest neighbourhood plan-we have accepted the national need for additional houses and have spent significant time and funds to produce this. It has completely demoralized the parish council and make a mockery of the whole process.

I have included my comments below why i believe this is not a viable plan for the council.


CDC have not consulted on revised housing numbers in North of the district-it quote the restrictions of the A27 which prevents the southern development however the A281 is a bigger constraint which will also have Dunsfold adding pressure.
Allocation of 220 houses plus a further 91 houses on already allocated sites is not sustainable in rural Loxwood-it a huge Percentage increase and will destroy the village.
CDC Sustainability Appraisal is weak in its justification for allocation of 220 houses
There is no viable bus, lack of sewerage capacity, a village school, shops to support large increase in housing

Policy A15 should be removed and Policies H2 and H3 amended to reflect a realistic allocation of 125 houses which is still generous compared to other local area with better services.
Loxwood should not be deemed to be a strategic location-it is a small rural village
LPC have spent time and effort to create a Revised Neighbourhood Plan which allocates 126 houses plus 17 carried forward from the Made Neighbourhood Plan giving 143 houses. It has reached Regulation 14 consultation stage and is based upon the Preferred Approach Local Plan consultation. The residentsof the Parish and Loxwood Parish Council have satisfied themselves through evidence gathered that 126 homes is a sustainable allocation given the constraints that exist-it should not be ignored due to water neutrality issues
This protects the village and the community and reflects the importance of Neighborhood plans for Loxwood and the rest of the country -there is a process and it should be respected otherwise it makes a mockery of the whole planning system and developers win every time.
Please can you protect the rural nature of this county and vote against plan.

Allocate sites instead of leaving to Neighbourhood Plans.

See attached representation.

Allocate site - Land to the north of Brandy Hole Lane and west of Plainwood Close for up to 300 dwelling units to meet the required housing need for the district.

1 INTRODUCTION

1.1 These representations are to the Chichester Local Plan 2021-2039: Proposed Submission (Regulation 19) Consultation (hereafter referred to as the “Reg 19 Plan”). These representations have been prepared by Genesis Town Planning, on behalf of D G Phillips (Bosham) Ltd and Phillips Build Ltd as owners of the site comprising approximately 9ha of agricultural land north of Brandy Hole Lane and to the west of Plainwood Close, Chichester.

1.2 The representations also include at Appendix 1 a plan indicating the proposed amendment to the settlement boundary and the inclusion of the site as a suitable housing allocation for up to 300 dwellings. Such an allocation is proposed to address the Council’s failure to adequately deliver sufficient housing through the Reg 19 Plan. The site is suitable, available and deliverable and complies with the sustainability objectives set out in the Reg 19 Plan and national policy and ensures that sites, adjacent to the primary settlement of Chichester, are appropriately considered as suitable sites to accommodate further housing.

1.3 These representations, in addition to seeking the inclusion of the site as a housing allocation and an amendment to the settlement policy boundary, also seeks to remove the proposed inclusion of the site within a strategic wildlife corridor. The inclusion of the land in such a corridor has no bearing on the characteristics of the site, its agricultural form, the fact that it is separated from the wildlife corridor to the south by Brandy Hole Lane and extensive housing development. This is an illogically thought through designation, which has paid no regard to the site character or its location and has been deliberately imposed to prevent housing development coming forward on the site. There is no wildlife, ecological or environmental features on the site, with the exception of boundary trees and vegetation, that would justify such a designation washing over the site and neighbouring land, which includes a former landfill site and a solar farm.

1.4 Accompanying these representations are the appropriate representation forms in respect of Settlement Map SB1, Map NE4b, Policy S1 and paragraph 3.7, policy H1, and Policy NE4. These forms are to be read in conjunction with this submission.



2 LEGAL COMPLIANCE

2.1 One of the requirements for the preparation of a Local Plan as set in the Planning and Compulsory Purchase Act 2004 and the Town and Country Planning (Local Planning) (England) Regulations 2012, (as amended) is the publication of a Sustainability Appraisal (SA) that shows how the SA has been carried out, the information that is used as part of the process and what the outcomes were. The SA is a tool for assessing how the plan, when judged against other reasonable options will help achieve environmental, economic and social objectives.

2.2 The SA suggests that there is little or no argument for setting a housing requirement above the minimum local housing need of the 638 dwellings per annum (dpa) as set by the standard method (763dpa minus 125dpa for South Downs National Park area). This approach is contrary to paragraph 11a) of the National Planning Policy Framework (NPPF) in that it requires all plans to promote a sustainable pattern of development that seeks to meet the development needs of their area.

2.3 It is noted that paragraph 11b) confirms that strategic policies should, as a minimum, provide for objectively assessed needs for housing and other uses, as well as any needs that cannot be met within neighbouring areas unless this is demonstrated to be unsustainable. The background evidence base for the Reg 19 Plan does not clearly demonstrate the reasons for restricting the overall scale, type and distribution of development in the plan area or that the adverse impacts of doing so would significantly and demonstrably outweigh the benefits.

2.4 It is noted that the standard method requirement of 638dpa for the plan area is arrived at by removing 125dpa for the part of the district that falls within the South Downs National Park. The lack of any meaningful assessment for providing sufficient housing to meet the standard method figure is a significant error. Without such an assessment, the SA disregards the possibility of providing for sustainable development at the outset and does not therefore accord with the regulatory requirements referred to above.

2.5 Table 5.3 of the SA identifies a range of development scenarios with dwelling requirements for the plan area ranging from 567dpa to 606dpa. These figures result in a shortfall of between 32dpa and 71dpa when compared to the standard method requirement of 638 dpa. As neither of these figures is significantly above the standard method figure, it is not unreasonable to expect the SA to also test a housing requirement/scenario of 638dpa, so that it reflects the confirmed minimum housing need of the plan area. This would be a reasonable alternative and should be tested. Only when this has been carried will it be possible to fully understand the likely implications of meeting housing needs in full. In doing this, the Plan will then comply with the Legal and Procedural Requirements.



3 SOUNDNESS

3.1 As set in paragraph 35 of the NPPF when local plans and spatial development strategies are examined they should be prepared in accordance with legal and procedural requirements to ensure that they are sound. It goes on to state that:
“Plans are sound if they are:
a) Positively prepared – providing a strategy which, as minimum, seeks to meet the area’s objectively assessed needs; and is informed by agreements with other authorities, so that unmet need from neighbouring areas is accommodated where it is practical to do so and is consistent with achieving sustainable development;
b) Justified – an appropriate strategy, taking into account the reasonable alternatives, and based on proportionate evidence;
c) Effective – deliverable over the plan period, and based on effective joint working on crossboundary strategic matters that have been dealt with rather than deferred, as evidenced by the statement of common ground; and
d) Consistent with national policy – enabling the delivery of sustainable development in accordance with the policies in this Framework and other statements of national planning policy, where relevant.”

3.2 As set out above, the Reg 19 Plan does not provide a strategy that seeks to meet the area’s objectively assessed housing need, and the SA does not test all the reasonable alternatives. On this basis the plan has not been positively prepared and is not justified. As a result it is contrary to paragraphs 35a) and 35b) of the NPPF.

3.3 In addition to this, there is no clear evidence of effective and on-going working with neighbouring authorities as part of the statutory duty to cooperate. The SoCG should be made publicly available throughout the plan making process to provide transparency. Based on paragraph 1.25 of the Reg 19 Plan this requirement has not been carried out. This confirms that a SoCG is currently being prepared and will be made available for review on the council’s website. As a result, the SoCG should have been made available on the LPA’s website at the time the Reg 19 Plan was published for consultation. This does not appear to have been the case, which means that this part of the plan making process does not meet the requirements set out in paragraphs 27 and 35c) of the NPPF. As such the effectiveness test has not been complied with in full. The lack of a fully detailed SoCG on the Duty to Cooperate is particularly important in Chichester District as there is a substantial unmet need for housing arising in neighbouring authorities and other nearby authorities across the same sub-region. As yet the evidence base of the Reg19 Plan does not explain or demonstrate how the unmet housing need will be met.

3.4 This is an important omission as it does not accord with the procedural requirements. Until the outcome of this process is known and fully understood it is difficult to know if or how the strategy in the Reg 19 Plan is appropriate or needs modification.
4 COMMENTS ON THE REG 19 DRAFT PLAN

Policy H1 – Meeting Housing Needs
4.1 No exceptional circumstances exist in Chichester District to justify an alternative approach that deviates from the standard method figure of 763dpa. Taking account of the South Downs National Park requirement of 125dpa results in a minimum need of 638dpa for Chichester District.

4.2 Furthermore, the housing needs of particular groups are not reflected in the current standard method requirement of 638dpa. These include the following groups:
• Students – which creates a need for an additional 29dpa;
• people who require affordable housing- which generates a need of 433 affordabled pa (based on this figure and the thresholds set out in draft Policy H4: Affordable Housing it would be necessary to deliver 1,083 homes per annum to meet affordable housing need in full); and
• the unmet housing needs of neighbouring authorities and/or authorities in the same subregion, which at best are between 10,141 and 10,620 homes.

4.3 When the needs of students are added to the standard method figure the minimum need dwelling requirement would be 666dpa or 11,988 dwellings over the 18-year plan period 20212039.

4.4 When the full affordable need of 1,083 dpa is factored in this results in a need for at least 19,494 dwellings over the plan period.

4.5 In addition to the above figures, there is also an unmet need for over 10,000 homes in related authorities over the plan period.

4.6 Based on the above there is clearly a need for significantly more homes than is suggested by the minimum standard method figure.

Infrastructure Capacity
4.7 Whilst it is noted that there are long-standing highway capacity issues on the A27 Chichester Bypass and more intermittent capacity problems with Wastewater Treatment facilities in the southern part of the district, these could be resolved if the emerging Reg 19 Plan made provisions to improve their capacity through proper long-term planning.

4.8 This approach is supported by paragraph 22 of the NPPF which confirms that plan-making should respond to long-term infrastructure requirements; and by paragraph 059 Ref ID 61-059 of the Planning Practice Guidance (PPG) which requires local planning authorities and policies that set out infrastructure deficiencies and how these will be addressed.
4.9 Existing capacity problems on the A27 are referred to throughout the Reg 19 Plan and its evidence base. Paragraph 5.2.11 of the SA refers to the southern plan area (i.e. the east-west corridor and Manhood Peninsula) as being highly constrained by capacity on the A27 and to detailed discussions with National Highways and West Sussex County Council (WSCC) over the course of 2019-2022 that led to a resolution that there is capacity for no more than 535dpa in this area. The background evidence does not, however, make it clear as to how the 535dpa figure was arrived at or the implications/infrastructure improvements that would be required to accommodate a higher dwelling provision in this part of the plan area.

4.10 It is important to note the “Chichester Transport Study - Local Plan Review Transport Assessment” (January 2023) prepared by Stantec is mainly focused on testing a single Local Plan spatial scenario for the period to 2039. Section 5.6 confirms that in addition to testing the 535 dpa in the south of the plan area that a sensitivity test for the delivery of 700 dpa in this part of the plan area was also carried out. Paragraph 5.6.1 confirms that higher levels of Local Plan development would enable higher levels of developer contributions to be raised towards funding the required Local Plan mitigation; and paragraph 5.6.3 comments that generally the proposed Strategic Road Network (SRN) mitigation can accommodate, in the most part, additional increase in development to 700dpa. This is reiterated in paragraph 5.6.5 where it concludes “that in the main, the 70dpa (southern plan area) demands can generally be accommodated by the mitigation proposed for the 535dpa core test although at the Portfield roundabout and Oving junction, capacity issues get worse with the 700dpa demands, with additional mitigation being required”.

4.11 Paragraph 8.5 of the Reg 19 Plan comments that in 2021 National Highways confirmed that the A27 Chichester By-Pass major improvement scheme is included in the Road Investment Strategy Pipeline for the period 2025-30 (RIS3), but at this stage funding is not guaranteed. This situation is not uncommon as are many infrastructure projects which are considered necessary to support the emerging Local Plan. This is demonstrated by Table 3 of the Infrastructure Delivery Plan (January 2023). The fact that the funding has not yet been secured towards certain types of infrastructure, such as healthcare, should not be used as a reason to constrain the level of housing proposed in the emerging Local Plan. This approach also applies to transport infrastructure.

4.12 The approach of the Reg 19 Plan to impose limits on the amount of development over the Plan period because of existing infrastructure capacity issues is inconsistent with the objectives of national policy and could undermine the prospects of securing the funding necessary to improve infrastructure capacity. The approach of the emerging plan is therefore negative worded as it has the effect of constraining the level of housing below the minimum level needed and does not accord with the PPG or the objectives of national policy. A better, and more positive approach would be to plan for the necessary infrastructure, which in turn will maximise the prospects of securing the required infrastructure instead of deferring it.

4.13 The emerging Local Plan advocates a “monitor and manage” approach such that the funding for the necessary improvements to the A27 will be monitored, which itself will jeopardise that funding, and if the funding is secured then presumably the corresponding level of housing will
be released to address some of the housing need. Instead of this approach, the emerging plan should pursue a “plan, monitor and manage” approach to meeting housing needs in full by committing to the delivery of the infrastructure improvements and if necessary, phasing the housing requirements towards the end of the plan period.

The Proposed Housing Requirement
4.14 These submissions confirm that the housing needs of the plan area will not be met by the proposed 10,350 dwelling requirement set out in Policy H1 of the Reg 19 Plan.

4.15 According to the standard method the minimum housing need is 11,484 dwellings (638 x 18). When the growth of the student population (28dpa) is factored in the minimum housing need increases to 11,988 homes, and when the full affordable housing needs (433 dpa) are taken into account the overall need increases to at least 19,485 dwellings. Finally, there is a need for excess of 10,000 more homes to address the unmet needs of the sub-region.

Suggested Modification
4.16 Based on the above it is clear that the Policy H1 requirement needs to be reconsidered and increased. This can be achieved if the Local Plan seeks to address infrastructure requirements including the capacity constraints on the A27 as required by paragraph 22 of NPPF.

4.17 In setting a revised housing requirement, the District Council must take into account the needs of particular groups (i.e., students and persons in need of affordable homes) and complete the Duty to Cooperate process by preparing a SoCG in respect of the unmet needs of the sub-region and then consider how/whether the Local Plan can provide for some of these unmet needs. In addition, the Reg 19 Plan should seek to allocate the land the subject of these representations for up to 300 dwellings to make up the shortfall identified.

Policy S1 - Spatial Development Strategy
4.18 Chapter 3 and Policy S1 of the Reg 19 Plan sets out the spatial strategy of the emerging plan.
These seek to disperse development across the plan area by:
1. Focusing the majority of planned sustainable growth at Chichester city and within the eastwest corridor;
2. Reinforcing the role of the Manhood Peninsula as home to existing communities, tourism and agricultural enterprise; and
3. Where opportunities arise, supporting the villages and rural communities in the North of the Plan Area.

4.19 An increased dwelling requirement (as suggested in the context of Policy H1 above) could be accommodated without the need to significantly alter the proposed spatial strategy of the Reg 19 Plan.

4.20 In addition to Chichester city and the east-west corridor being the primary focus of growth, additional development could be accommodated through the re-appraisal of the settlement boundaries, particularly those around Chichester City to include the site subject of these representations.

4.21 In this respect the inclusion of additional land would make a significant contribution towards the delivery of the required housing need for Chichester, providing a flexible approach to housing delivery in a sustainable, planned and progressive way.

Suggested Modification
4.22 The inclusion of land to the north of Brandy Hole Lane and west of Plainwood Close, as set out in Appendix 1 to these submissions, should be secured through an amendment to the settlement boundary on Plan SB1. Further, the site should be allocated as a suitable housing site for up to 300 dwelling units to meet the required housing need for the district.

4.23 In support of this approach the Council undertook an assessment of the site’s suitability for development as part of the HELAA process in 2021. A copy of the HELAA Assessment and associated plan is contained at Appendices 2 and 3. This confirms that the site is in agricultural/ pasture use and is suitable for development subject to consideration of matters such as access, landscape and trees. The assessment goes on to confirm that there are no known constraints that would make the development unachievable in principle.

Policy NE4
4.24 Despite the above assessment, the subject site has been included within proposed Policy NE4 of the Reg 19 Plan as a Wildlife Corridor to function in conjunction with the designation of the land to the west of the strategic allocation which lies to the south of Brandy Hole Lane and the B2178. The site the subject of these representations is fundamentally distinct in character from the wooded areas to the south of the B2178 and to the west of the strategic allocation. These comprise compartmentalised fields and clusters of woodland which frame the field boundaries. In contrast, the subject site comprises agricultural land with a modest treed boundary and is largely open in character, but visually contained. The remainder of the proposed Wildlife Corridor in this location comprises open agricultural fields with limited landscape boundaries, the former landfill site at Hunters Race and the solar farm to the north. None of these areas possess the qualities of the land further to the south to justify being designated a Wildlife Corridor. Such a designation has been imposed merely as a tool to prevent further development of what would otherwise be deemed suitable land for housing.

Suggested Modification
4.25 The proposed Wildlife Corridor to the north of Brandy Hole Lane should be deleted from the Reg 19 Plan and removed from the settlement map NE4b. Furthermore, Policy NE4 requires any development within the designated Wildlife Corridor to be subject to a sequential test which places a significantly higher bar than that set out within the NPPF. The does not comprise a designated landscape, and proposed Policy NE4 fails to identify any special qualities that apply to the designated area in this location.

It is proposed therefore that Policy H2 Strategic Locations/Allocations 2021- 2039 be amended so that the following strategic sites: A2, 4, 5, 8, 10, 11 and 13 are only released one year after work commences on the A27 improvements at the Fishbourne and Bognor roundabouts, and, where appropriate, waste water treatment works.

Contributions to the two A27 roundabouts for the uncommitted housing, 3351, about 40% of
total, is assessed at £7,728 per house at current prices. This is 4 times higher than
current level of £1,803. Nowhere does there appear to be an assessment as to whether this
is viable for the land developers and house buyers. Viability is a key test with regard to
deliverability but the Plan is silent on this key issue. So, is the plan deliverable? Does it
further price first-time buyers out of the market. Chichester
has already one of the highest Ratio of Affordability in Sussex .

These representations are made on behalf of our client, the Birkett Family and the Chichester Local Plan 2021 – 2039 Proposed Submission Regulation 19 Version.

Background

The Birkett Family are local landowners who live in Easthampnett. They own approximately 44 acres of farmland to the west of Easthampnett which is edged red at Enclosure 1. The land has been promoted intermittently to Chichester District Council but they wish to confirm to Chichester District Council and the Inspector that the land is available for development should they consider Tangmere as an area for additional growth.

Site suitability

The land comprises farmland which could be redeveloped to meet a local housing need. Although limited work has been undertaken to date, the landowner is in the process of negotiating to enter into an agreement with a developer / promoter to promote the land to Chichester District Council to ensure it is deliverable.

Therefore, in time and at the request of the Council or Inspector, additional reports and surveys could be provided to support any future housing allocation. However, a highways appraisal has been undertaken, and access to the site is achievable and this can be provided at request.

Soundness

Policy H2 of the Chichester Local Plan allocates 1,300 dwellings at the Tangmere Strategic Development Location. This site has an outline permission and is subject to a Compulsory Purchase Order. For clarity, our client does not object to this allocation, but supports it as it shows that Tangmere is a location that can be seen to grow.

Policy H3 does not allocate any additional housing to Tangmere Parish other than the Strategic Development Location. It is considered that along with the strategic development to the West, that our client’s land to the East of Tangmere can provide additional housing in Tangmere.

We trust our comments will be considered as part of the Local Plan review, and please do not hesitate to make contact if you require anything further.

We write in response to the above consultation on behalf of our client, the Church Commissioners for England (CCE). CCE owns a large amount of land in the area largely to the south, west and east of Chichester.
We welcome the opportunity to further engage with the Local Plan process. Whilst we support some aspects of the Local Plan, we consider that some changes are likely to be necessary to ensure that the Plan can be found sound.

By way of background, CCE submitted several sites for consideration as part of the Housing Economic Land Availability Assessment (HELAA) in 2021. These sites were previously promoted as part of the Preferred Approach Local Plan Regulation 18 Consultation in 2019.
As part of these representations, we take the opportunity to re-promote a number of CCE’s sites, which could assist the Council in delivering much needed housing for the district. CCE has updated its technical work and provide Vision Documents in relation to its landholdings in Southbourne, Oving, and Hunston Parishes to demonstrate how additional housing can be delivered. These Vision Documents are enclosed.
We consider this and other aspects of the emerging Local Plan below.

Chapter 2: Vision & Strategic Objectives

The Local Plan Vision details a positive approach to supporting sustainable development in the context of the climate emergency. CCE welcomes the Vision for Chichester, particularly the importance placed on the delivery of new homes in ‘Objective 3’ and the delivery of new infrastructure to support the new development in ‘Objective 7’.

Chapter 3: Spatial Strategy and Settlement Hierarchy

The Spatial Strategy builds on the previous Local Plan by focussing growth on Chichester city as the main sub-regional centre. Outside Chichester city and its closest settlements, development will focus on the two settlement hubs within the east-west corridor at Tangmere and Southbourne. This approach is supported by CCE.

Policy S1 Spatial Development Strategy

Draft Policy S1 (Spatial Development Strategy) identifies the broad approach to providing sustainable development in the plan area, which includes ensuring that new residential development is distributed in line with the settlement hierarchy, with a greater proportion of development in the larger and more sustainable settlements. We support this strategy, with particular support for development at the settlement hubs of Southbourne (Policy A13) and Tangmere (Policy A14). We also support that provision is made for extant Site Allocations and the Tangmere strategic site remains allocated under draft Policy A14.

Policy A14 continues to allocate Land West of Tangmere for 1,300 dwellings. CCE questions the Council’s decision to not amend the existing settlement boundary of Tangmere to include the land subject to the allocation. Without amending the settlement boundary, the future growth of Tangmere may be hindered. As such, the settlement boundary of Tangmere should be amended to include the allocated site to ensure that the plan is justified.

Draft Policy S1 also refers to development in service villages such as Bosham, Hambrook and Loxwood.
Hunston is excluded from the Spatial Strategy but is identified as a Service Village within the Settlement Hierarchy in draft Policy SP2 (Settlement Hierarchy). The draft Local Plan suggests that the allocation of homes in Hunston has been removed as a result of growth in the Manhood Peninsula. CCE acknowledges that the overall housing numbers across the district have been reduced as a result of local constraints but reiterate that their landholding in Hunston remains a suitable site for housing should the Council need to identify more land for housing. This is discussed further below.

Policy S2 Settlement Hierarchy

As stated in paragraph 3.31 of the draft local plan, ‘The NPPF encourages housing delivery where it will enhance or maintain the vitality of rural communities’. Paragraph 79 of the NPPF (2021) states that ‘To promote sustainable development in rural areas, housing should be located where it will enhance or maintain the vitality of rural communities. Planning policies should identify opportunities for villages to grow and thrive, especially where this will support local services. Where there are groups of smaller settlements, development in one village may support services in a village nearby’.

CCE owns substantial land holdings in South Mundham, which is in close proximity to North Mundham/Runcton which is defined as a Service Village. As such, whilst South Mundham does not contain any services, development in the hamlet would enable sustainable growth to support facilities in North Mundham and Runcton. To ensure that the draft plan is consistent with national policy, South Mundham should be considered as part of North Mundham as a Service Village when considering the future pairing/grouping of some settlements where the facilities and services could be shared to capitalise on the close connections some settlements have.
Development outside the settlements listed in the hierarchy in SP2 is restricted to proposals which require a countryside location or meet an essential local rural local need or supports rural diversification in accordance with Policy NE10. To this end, CCE has smaller land holdings in Tangmere, Oving, South Mundham, Birdham, Chidham and Sidlesham, which may be suitable for conversion for residential use or via windfall housing. Location plans for each of the sites can be found in Appendices 1-8.

Chapter 4: Climate Change and the Natural Environment

Policy NE4 Strategic Wildlife Corridors

The East of City strategic wildlife corridor has been relocated to the eastern side of proposed Site Allocation A8 (Land to the East of Chichester). The relocation of this wildlife corridor follows additional evidence that shows that the commuting route for Barbastelle Bats is along Drayton Lane.

CCE owns land to the east of Drayton Lane (immediately adjacent to the wildlife corridor and to the east of draft allocation A8) and surrounding the village of Oving. Its land has been identified in the HELAA (2021) as being developable, including site HOV0017 (Drayton Lane). The land east of Drayton Lane is sustainably located being close to Chichester and its amenities. The site provides an opportunity to sensitively and sustainably provide additional homes for the District. In accordance with Draft Policy NE4, the proposals for the Land East of Drayton Lane will not have an adverse impact on the integrity and function of the wildlife corridor and will not undermine the connectivity and ecological value of the corridor. This Vision Document will be shared under separate cover.

The eastern edge of the relocated wildlife corridor encroaches into CCE land. Any proposal on this land would be required to take the statutory protection for bats and other protected species into consideration and managed as part of a sensitive masterplan for development and on this basis, it is considered unnecessary to extend the wildlife corridor to encroach into the CCE site.

It is also considered that the detail of policy NE4 goes beyond the purpose of the policy, which should be to safeguard wildlife rich habitats and wider ecological networks. The policy is clear that development should only be permitted where it would not create an adverse effect upon the ecological value, function, integrity and connectivity of the corridors. It does not resist development in principle. This therefore makes redundant policy text 1, which seeks to introduce a sequential test for preferable sites outside of a wildlife corridor. It is considered that this test conflicts with the underlying purpose of the policy, which is to safeguard wildlife corridors from harmful impacts that cannot be mitigated, and should therefore be deleted.

Policy NE7 Development and Disturbance of Birds

CCE is broadly supportive of Policy NE7. However, they would like to note that the situation regarding the national guidance on nutrient neutrality is still evolving and therefore, this policy is only relevant to current legislation. Policy NE7 may therefore not be relevant throughout the entirety of the plan period. As such, CCE considers that it is necessary in this instance to ensure that an appropriate reference to changing legislation is included within the policy to prevent it from becoming out of date and would also ensure that the policy remains effective once adopted.

Policy NE10 The Countryside

CCE is supportive of the inclusion of a policy referencing the conversion of existing buildings in the countryside, however, we believe that Policy NE10 is not consistent with national policy. Policy NE10 criteria B states that proposals for the conversion of buildings in the countryside will be permitted where ‘it has been demonstrated that economic and community uses have been considered before residential, with residential uses only permitted if economic and community uses are shown to be inappropriate and unviable’. This policy is not in accordance with Paragraph 152 of the NPPF (2021) which states that the reuse of existing resources should be encouraged, including ‘the conversion of existing buildings’. Under paragraph 152, there is no prerequisite to adopt a sequential approach, or to give preference to other uses. As such, criteria B should be omitted from Policy NE10. Reference to criteria B should also be removed from criteria C.

Chapter 5: Housing

Policy H1 Meeting Housing Needs

The Preferred Approach Local Plan was based on meeting the identified objectively assessed housing needs of the plan area of 638 dwellings per annum. However, due to constraints, particularly the capacity of the A27, the Submission Version of the Local Plan has planned for a housing requirement below the need derived from the standard method. The Plan proposes to deliver 535 dpa in the southern plan area and a further 40 dpa in the northern plan area, a total supply of 10,350 dwellings over the plan period from 2021 – 2039 (575 dpa).

The Planning Inspectorate has previously asked the Council to determine what level of housing could be achieved based on deliverable improvements to the A27 and to consider whether the full housing needs could be met another way. It is acknowledged that the Council has carried out the additional work required and the local constraints have resulted in a proposed lower housing requirement.

The NPPF (2021) confirms that to determine the minimum number of homes needed, strategic policies should be informed by a local housing need assessment, conducted using the standard method in national planning guidance – unless exceptional circumstances justify an alternative approach (para. 61). CCE acknowledges that that housing numbers have been reduced as a result of local constraints and it will be down to the Inspector to determine whether the Council’s exceptional circumstances justify this. Should the Planning Inspector find that the Council requires additional land to meet the housing need using the standard method, CCE’s land at Southbourne, Oving, Drayton Land and Hunston are suitable, available and developable for housing. In addition, CCE’s rural development sites could also contribute to meeting the housing need.

Policy H2 Strategic Allocations

Draft Policy H2 confirms that the Tangmere Strategic Development Location is carried forward from the 2015 Local Plan and this is supported by CCE. Strong support is also given for the Broad Location of Development in Southbourne (Policy A13) for up to 1,050 dwellings.

Policy H5 Housing Mix

Draft Policy H5 confirms that the housing mix for a development will be based on the most up to date HEDNA to address identified local needs and market demands. We suggest that the Council considers a range of criteria, including site characteristics, when determining the housing mix for individual sites and this should be reflected in wording of Policy H5.

Policy H7 Rural and First Homes Exception Sites

Draft Policy H7 relates to rural and first homes exception sites. CCE is supportive of the principle of the inclusion of a rural exceptions policy. However, we have concerns over criteria contained within the policy which limits the amount of development that can be delivered under it.

The NPPF (2021) at paragraph 78 states that planning policies and decisions should be responsive to local circumstances and support housing development that reflect local needs. Furthermore it also states that ‘local planning authorities should support opportunities to bring forward rural exception sites that will provide affordable housing to meet identified local needs’.

The key aspect of the policy is to enable the delivery of rural exception sites which would address an identified local need. Within the policy, there is no limit on the amount of development that can be delivered and therefore, it is considered that if Policy H7 is limited to a maximum of 30 dwellings it could serve to hinder development (especially on slightly larger sites), which would otherwise be sustainable. As such, we consider that the amount of development should not be limited and rather should be dictated on a site and need specific basis. CCE considers that for Policy H7 to be positively prepared and in accordance with National Policy, criteria 2 should be removed.

In addition, criteria 6 states that proposals for affordable housing on rural exception sites will only be supported where ‘the site is located adjacent or as close as possible to the existing settlement boundary and does not result in scattered or isolated development in rural areas’. The NPPF (2021) does not specify the location of rural exception sites. As such, to be consistent with national policy, criteria 6 should also be omitted.

Furthermore, Policy H7 states that ‘applications for first homes exception sites that propose the inclusion of a small proportion of market housing will be expected to provide robust evidence…’.
However, in the policy there is no allowance for the provision of market housing on rural exception sites in addition to first homes exception sites. As a result of this, the requirements of the policy are again not consistent with national policy. Paragraph 78 of the NPPF (2021) is supportive of ‘some market housing’ where it would facilitate the delivery of rural exception sites. As such, CCE considers that Policy H7 should be amended as follows:

‘Applications for rural and first homes exceptions sites that propose the inclusion of a small proportion of market housing will be expected to provide robust evidence that the site would be unviable without such housing being included’.

Policy H8 Specialist Accommodation

Draft Policy H8 confirms that all housing sites over 200 units, including those allocated in this plan, will be required to provide specialist accommodation for older people with a support or care component. We request that this policy is amended to add ‘where appropriate and viable’, acknowledging that viability and site-specific factors need to be taken into consideration.

Chapter 6: Place-making

Policy P3 Density

We support the objective of Draft Policy P3 (Density) to make the most efficient use of land and follow a design led approach to achieve the optimum density for a site. The Policy does not prescribe an appropriate density for the District and this is supported. However, we consider that reference should be made to the fact that density may vary depending upon site specific circumstances and could be higher where transport links and access to services is good.

Chapter 7: Employment and Economy

Policy E3 and E4 Horticultural Development

Chapter 7 of the draft Local Plan confirms that 67 hectares of land is identified to meet the future horticultural land need within four Horticultural Development Areas (HDAs) over the plan period. It is confirmed that an additional 137 hectares of horticultural land is also forecast to be required outside of HDAs to meet future need.

CCE has significant landholdings which could assist the Council in addressing the insufficient availability within the current HDAs. The CCE sites which are considered suitable for horticulture development are listed below and location plans for each of the sites can be found in Appendices 9-13.
• Somerley Farm, NE East Wittering, PO20 7JB
• Fisher Farm, South Mundham, PO20 1ND
• Church & Haise Farm, Sidlesham
• Cowdry Farm, Birdham
• Groves Farm, nr Merston, PO20 2DX / Colworth Manor Farm PO20 2DU.

CCE supports draft Policy E3 which confirms that “approximately 137 hectares of land is also needed outside of HDAs to meet anticipated horticultural and ancillary development land need for the plan period.” Support is also given for draft Policy E4 in relation to land outside HDAs. This Policy confirms that proposals for horticultural development can come forward outside the HDAs, subject to a set of criteria. We would welcome continued discussion with the Council on how these sites could help meet the districts horticultural needs in the future.

Chapter 10: Strategic and Area Based Policies

CCE supports Chichester District Council’s proposal to allocate additional land for housing at
Southbourne and to maintain the existing allocation at Tangmere. We also consider that CCE’s land at Hunston and Oving could assist the Council in meeting its housing needs, should additional housing be required. We consider these opportunities in turn below.

Policy A13 Southbourne Broad Location for Development

CCE supports draft Policy A13 and the allocation of a Broad Location for Development in Southbourne for a mixed-use form of development including 1,050 dwellings.

CCE has significant landholdings around Southbourne which is suitable, available and developable. The land to the north and west of Southbourne measures 70ha and is wholly within CCE’s control. The land adjoins the existing settlement and provides an opportunity for a sustainable extension to Southbourne with the potential to deliver c. 1,200 homes for the village, as well as employment, community uses and a significant amount of new public space and green open space. A new Vision Document is enclosed which explains one way in which this opportunity could be realised. Importantly, it is considered that there are no technical impediments that would prevent development from coming forward on this site.

This site has been promoted throughout the Southbourne Neighbourhood Plan process, most recently in the December 2022 consultation. The new Vision Document demonstrates that the CCE site presents the opportunity to provide a comprehensive development that would contain strategic housing growth, significant areas of green infrastructure and open space in a sustainable location. The key access strategy for the site is to provide two new access points from the south A259 Main Road and the east Stein Road. These access points would connect to a spine road which would form a continuous vehicle route around the north-western edge of Southbourne.

The site almost entirely comprises a Secondary Support Area under the Solent Waders and Brent Goose Strategy (SWBGS), which aims to protect the network of non-designated terrestrial wader and brent goose sites that support the Solent Special Protection Areas (SPA) from land take and recreational pressure associated with new development. Due to the designation of the site, discussion was undertaken with the Hampshire and Isle of Wight Wildlife Trust with a view to determine a suitable approach for the scheme and an appropriate survey effort to establish the use of the site by designated birds. As a result of these discussions, wintering bird surveys are taking place. The aim of these surveys is to explore opportunities for mitigation for this SWBGS support area such that development within the red line can proceed without adverse impacts to the bird populations noted within this strategy. Following the survey, the results and approach will be presented to Natural England for further discussion.

In relation to viability, we note that Policy A13 sets several policy objectives for development at Southbourne. The NPPF (2021) notes that where there are up-to-date policies which have set out the contributions expected from development, planning applications that comply with them should be assumed to be viable (para. 58). With this in mind the policy objectives outlined within Policy A13 will require viability testing to be undertaken to ensure a policy compliant scheme is both viable and deliverable. This is necessary to ensure that the policy is sound.

The Policy suggests that employment opportunities are required to be delivered as part of the allocation but there is no specific reference to the amount of use required. CCE supports this proposed approach as it is sufficiently flexible to enable an amount of employment land to be proposed in response to market conditions at the appropriate time and this will help to support delivery of the allocation.

The scale of development proposed has been reduced from 1,250 to 1,050 dwellings to reflect the proportionate reduction in housing numbers across the parishes in the east west corridor as a consequence of the limit on numbers in the southern plan area. If the Inspector finds that additional housing is required, the Vision Document submitted demonstrates that the CCE site in Southbourne could deliver c. 1,200 homes and so could increase housing without needing to identify additional land for development elsewhere.

To summarise, the site could accommodate approximately 1,200 homes which could be delivered on a phased basis early in the plan period. There are no overriding physical or technical constraints that would act as an impediment to development. There is also a clear access arrangement proposed.

Policy A14 Land West of Tangmere

CCE supports that Policy A14 is carried forward into this Local Plan to facilitate the delivery of a residential-led development of at least 1,300 dwellings.

Additional sites

Hunston

CCE further promotes land (15.31ha) located east of the B2145 Selsey Road in Hunston for 240 new homes. The land is deliverable and is fully within CCE’s control. The site is highly accessible, located within a maximum of 5-6 minutes walking distance to Selsey Road, where several bus routes connect the village to Chichester.

CCE notes that the Council assessed the HELAA site (ref. HHN0016) as ‘developable’. A Vision Document has previously been prepared and submitted to demonstrate the commitment to it being brought forward for residential development within the plan period. This document is enclosed.

To address the Council’s concerns in relation to flooding, following publication of the Chichester Strategic Flood Risk Assessment (SFRA), we have prepared an updated Flood Risk Scoping Study which provides an overview of flood risk constraints across the site from a range of sources. Various mitigation measures are recommended in line with recommendations of the Chichester SFRA and prevailing local and national guidance and best practice. With these measures in place, it is likely that the flood risk could be managed effectively in accordance with the requirements of the NPPF. Detailed data has also been requested from the Environment Agency, which will feed into further technical work that is being carried out.

Should the Inspector conclude that additional housing is required, CCE considers that their site is the most appropriate and sustainable location for development in Hunston. The site provides an opportunity to sensitively and sustainably extend the existing village boundary to provide additional homes to meet an identified housing need.

Land East of Drayton Lane

CCE owns land to the east of Drayton Lane which is bound by Tangmere Road to the north and crosses Oving Road and the railway line to the south. The site is c.1km from the centre of Chichester and comprises 49ha. The site was assessed in the HELAA 2021 as developable ‘HOV0017’. A Vision Document has been prepared and was presented to the Council in 2022. This includes a detailed analysis of the site and its surroundings and provided justification as to why the site is suitable for development. This technical review of the site concludes there are no technical impediments to development.

The Vision Document demonstrates how the proposals for the land east of Drayton Lane could be developed as an extension to the draft allocation A8 (Land to the east of Chichester) for up to 700 new homes. The land east of Drayton Lane is fully within the CCE’s control, is available for development now and is deliverable with some development achievable within the first five years of the plan period. It represents an opportunity to provide new homes, facilities and significant community benefits, through a sensitively designed development that integrates into the surrounding landscape.

The Vision for this site is a landscape and ecology led masterplan which would celebrate the rich wildlife characters of the different surrounding landscapes and uses the connection between countryside and community to generate its character and identity. The Vision Document demonstrates that this is a suitable location for development.

Should the Inspector conclude that additional housing is required, CCE considers that the land east of Drayton Lane would form a natural extension to allocation A8 and is an appropriate and sustainable location for new development.

Appendix C Additional Guidance
Appendix C provides additional guidance on evidence which needs to be submitted in support of certain planning applications related mainly to development in the countryside. As mentioned in the comments above provided in response to Policy NE10, there is no prerequisite contained within the NPPF (2021) that requires an applicant to demonstrate that previous uses were proven unviable prior to the conversion of a building in the countryside to residential use. As such, to be in accordance with national policy, reference to Policy NE10 should be omitted from Appendix C.

Conclusion

CCE welcomes the opportunity to comment on the Local Plan and is keen to continue to engage with the Council, especially in relation to the Broad Location for Development in Southbourne. CCE is supportive of the Council’s aspirations in the Local Plan. However, the changes set out above are considered likely to be necessary to ensure the plan is sound.

CCE is a considerable landowner in Chichester with land largely to the south, west and east of
Chichester which could assist the Council in meeting their housing and development needs throughout the plan period.

See attachments for site information.

See attachments.

Consideration of Land at Farmfield Nurseries, Selsey Road, to address housing need.

Mission Town Planning Ltd, have been engaged by a client to make representation to the emerging Chichester District Council Local Plan consultation closing on 17th March 2023.
We have been commissioned to make representations on the plan so far as it impacts sites that are of interest to my client, specifically with Hunston, and the site to the south of the village known as Land At Farmfield Nurseries, Selsey Road. The site was provisionally
proposed for allocation with the Hunston Neighbourhood Plan, which was the only allocated site proposed under policy H1. This was for the provision of a minimum of 200 homes.
This in part was in response to the Chichester District Council Regulation 18 plan which was set out within proposed policy AL11, which will not specifying a site proposed an allocation within Hunston of a minimum of 200 dwellings.

Representations
These Representations are focused solely on matters of direct relevance to my client’s land interest within Chichester District Council’s authority.
We have set out these Representations by reference to the relevant chapter or subject heading in the proposed Local Plan along with reference to the specific policy and page number where appropriate.
While we note that the Council have used a web-based system, we have endeavoured to address those elements that are relevant to the site mentioned
above.
The purpose of this representation is to comment solely in relation to the omission of allocation within Hunston.

As a starting point it is worth noting that the regulation 18 consultation identified a need of 12,478 dwellings over the plan period this being from 2016 to 2035. During the period from this regulation 18 consultation being undertaken, and now the regulation 19 consultation the Council have consistently been unable to demonstrate a five year housing supply, this
currently standing at 4.74 years, with a requirement of 3,350 from 2022-2027.
The regulation 19 consultation has now reduced this number to 10,359 units. The reasoning for this is set out within Chapter 5 of the consultation, where is notes constraints particularly the A27 capacity as a barrier to allow for the requisite amount of growth meaning that the Council is below the requirements of the standard method.
The national planning position set out within the NPPF (National Planning Policy Framework) at paragraph 61 which states;
To determine the minimum number of homes needed, strategic policies should be informed by a local housing need assessment, conducted using the standard method
in national planning guidance – unless exceptional circumstances justify an alternative approach which also reflects current and future demographic trends and
market signals. In addition to the local housing need figure, any needs that cannot be met within neighbouring areas should also be taken into account in establishing the amount of housing to be planned for.

While the provisions of the emerging NPPF are noted, this was a consultation document and is not yet/ may not be planning policy.

From the submission while the constraint of the A27 is noted this is not beyond mitigation and the fact that Highways England are, and have sought contributions to rectify this would suggest that this would not constitute an exceptional circumstance. Moreover, the plan
further states that it is a strategic objective to mitigate the impacts on the A27.

In the period between the preferred approach (reg 18) and this approach (reg 19) the plan notes that, there has been moderate growth, and again notes the constraints, although these remain ambiguous. It is noted that the moderate growth was still not sufficient to deliver a 5 year housing land supply.

Within the consultation plan, it is shown within Map B1 – Areas designated as Rural and Non Rural Area’s that Hunston is within the non-rural area. Given this is seems perverse to then remove and form of allocation for housing within this designation urban area.
The issue then comes that the defined settlement boundary as per the Site Allocation DPD adopted 2019, would considerably restrict any housing growth when taken in context of the emerging plan and its policy on developments outside of the settlement boundary, i.e.
within the countryside.
Such an approach to proposal reducing housing numbers following consistent under delivery and to allow no mechanism to allow for sites to be considered will simply fail to the housing people and families need. The over reliance on larger and strategic sites, which
have been bought forward from previous plans shows the significant issues with their historic lack of delivery and indeed whether they should be consider within the plan in the first place.

I would urge the Council to consider its approach to housing delivery and its obligations to delivery much needed family housing. Every borough and district will have to contend with constraints, however the exists a statutory duty to deliver housing.
The National Housing Federation “People in housing need 2021” report summarises that;
• 8.5 million people in England have some form of unmet housing need.
• For 4.2 million of these people (around 1.6 million households) social rented housing would be the most appropriate tenure to address that need.
• This is around half a million more families than the 1.1 million households currently recorded on official waiting lists.
• Two million children in England (1 in every 5) are living in overcrowded, unaffordable or unsuitable homes.
• 1.3 million of these children are in need of social housing, as this is the only suitable and affordable type of home for their families.
• Overcrowding is the largest problem nationally, affecting nearly 3.7 million people

Summary
I trust that these Representations are of assistance in considering the current drafting and submission of the Local Plan. My client would request that we continue to be engaged in the plan making process and we look forward to hearing from you with regard to the next steps.

Make a strategic scale allocation as part of Policy H2; set a housing figure of at least 200 homes for Hunston in Policy H3 which could be delivered as part of Neighbourhood Plan process.

See attachments.

I write in response to the regulation 19 consultation version of the Chichester Local Plan 20212039 on behalf of my client Obsidian Strategic.

Obsidian Strategic have an interest in a site to the South of Main Road, in Hermitage, within the Southbourne Neighbourhood Plan Area. Further details in relation to the site are set out within the appendices of these representations and referred to throughout.

Housing Requirement

The identified housing need for Chichester District Council (CDC) as calculated by the standard method is 638 dwellings per annum (dpa). However, the local plan only seeks to provide 575 dpa or a total supply of 10,350 over the plan period (2021-2039). As result the proposed strategy represents an under supply of 1,134 over the plan period. Furthermore, the undersupply means that CDC is unable to accommodate the unmet arising from the South Downs National Park.

In recent years CDC has not been able to demonstrate a five year housing land supply nor has it delivered housing against the requirements of the Housing Delivery Test. It is therefore important that the unmet need is made up within the early part of the plan period.

Paragraph 5.2 of the plan states that the under supply is due to constraints across the district particularly the capacity of the A27.

Policy H1 (Meeting Housing Needs) sets out the housing target of 10,350 dwellings to be delivered over the plan period 2021-2039. Considering the existing commitments, allocations and permissions this gives a remaining figure without planning permission of 3,056 homes for allocation in the Local Plan.
Strategic Allocations
Policy H2 of the reg 19 plan sets out the following strategic site allocations which are carried forward from the 2015 Local Plan:

**Table**

Table 11 of the latest Annual Monitoring Report (AMR) (produced in November 2022) show the progress of delivery from these allocations:

**Table**

Table 12 of the AMR sets out the progress of the large sites towards future delivery as follows:

**Table**

The Housing Trajectory as set out in Appendix E of the Local Plan shows delivery of the existing allocations as set out under policy H2. Given that the Land at Shopwyke (A7) and the Land at Westhampnett/North-East Chichester (A9) already have permission for the number of dwellings in the allocation and construction has already started, there is no objection to the predicted levels of delivery as set out in the trajectory.
However, the housing trajectory sets out delivery from the Land West of Chichester (Phase 2) (A6) and Tangmere SDL as follows:

**Table**

Given that neither of these sites have outline permission then the delivery of units from both sites in a little over 5 years from the adoption of the plan is considered wholly unachievable.

CDC has presented no evidence to justify how this timeframe would be achieved and it is considered that the trajectory is unreliable as a result.


The Local Plan sets out a Broad Location for Development at Southbourne which would be delivered through either the Neighbourhood Plan process or a Site Allocation DPD:

**Table**

The Housing Trajectory as set out in appendix E of the Local Plan sets out the following delivery from this site:

**Table**

Given that policy A13 remains as a ‘broad area for development’ it is not considered that there is adequate justification for the trajectory as set out. Notwithstanding the effectiveness of allocating a site in this way, an exact location for the housing is yet to be defined, nor is delivery through the neighbourhood plan/DPD confirmed (further details on this is set out within the reps). Until a more detailed site can be defined and delivery confirmed it is not considered that CDC is able to guarantee delivery of dwellings in the housing trajectory as it has done so within the plan.

Non-Strategic Parish Housing Requirements
Policy H3 sets out the following housing requirements from individual parishes.

**Table**

The supporting text of policy H3 sets out that if draft neighbourhood plans making provision for at least the minimum housing numbers of the relevant area have not made demonstrable progress the council will allocate sites for development within a development plan document in order to meet the requirements of this Local Plan.

Table 13 of AMR identifies that there has been historically poor delivery of net housing completions from parishes:

**Table**

The overall strategy as set out by CDC in the plan is highly dependent on the delivery of housing from Neighbourhood Plan areas. Whilst this approach is not un-sound in itself, it is considered that the plan in its current form allows for little mitigation or alternatives should delivery not come forward in the neighbourhood plan areas.

In order for the plan to be considered positively prepared and justified it is recommended that additional wording is added to policy H3 to state that individual applications can come forward on sustainable sites outside of existing settlement boundaries in parishes should delivery not come forward within the first five years of the plan period. Priority should be given to any sites already identified within draft versions of Neighbourhood Plans.

on sustainable sites outside of existing settlement boundaries in parishes should delivery not come forward within the first five years of the plan period. Priority should be given to any sites already identified within draft versions of Neighbourhood Plans.
Southbourne
As set out, the Local Plan proposes a ‘Broad Location for Development’ at Southbourne for the delivery of 1,050 dwellings. This approach follows the withdrawal of the previously draft version of Neighbourhood Plan after it was found not to comply with basis conditions following examination in early 2022. Southbourne Parish Council is now pursuing a revised Neighbourhood Plan which has been submitted to CDC for a regulation 16 consultation. Obsidian previously responded to the regulation 14 consultation in late 2022 and these are appended to these representations.
The revised Southbourne Neighbourhood Plan does not seek to allocate any new housing allocations and instead takes a protectionist stance against any new development as an interim position whilst the Local Plan is prepared. However, once the Neighbourhood Plan is made, it would form part of the development plan for CDC. It is highly likely that a made Neighbourhood Plan in the form currently proposed by Southbourne would make the allocation of additional housing in the parish less likely rather than more likely.
The Sustainability Appraisal (SA) as prepared for the regulation 19 of the Local Plan sets out the proposed approach to Southbourne as follows:
3.1. With the decision of Southbourne Parish Council to no longer proceed with the inclusion of a strategic allocation in their neighbourhood plan, the Council considered three options for taking forward development in Southbourne, namely:
• Option 1 - redistribute the housing number elsewhere
• Option 2 - allocate a strategic site
• Option 3 - identify a Broad Location for Development
The SA goes on to set out the reason for option 1, for redistributing the housing number elsewhere, being discounted as follows:
3.2. As set out in the Housing Background Paper, the preferred spatial strategy is to focus the majority of growth at Chichester and the east west corridor, with a focus on the Settlement Hubs within the corridor. To redistribute the housing number to other parts of the plan area would not be consistent with the preferred spatial strategy nor reflective of the role of Southbourne as one of the more sustainable locations in the plan area capable of delivering strategic scale development. The ability to redistribute the number to other locations within the east/west corridor is also severely limited due to infrastructure constraints (impact on A27 junctions) or environmental restrictions (wastewater treatment capacity). For these reasons, Option 1 was discounted.
Whilst it is accepted that the redistribution of the entire requirement of 1,050 homes would be problematic, it is considered that CDC should have tested the allocation of other alternative sites such as that at Main Road, Hermitage and other suitable alternative sites.
The SA goes on to set out consideration of option 2 as follows:
3.3. In order to allocate a site in a Local Plan, it needs to have gone through a rigorous process to ensure that the Council can demonstrate that the allocated site is suitable, given reasonable alternatives, and is based on proportionate evidence. Given there is more than one site or combination of sites that could come forward as an allocation in Southbourne, a clear process setting out for why one site was chosen over another would be needed, informed by site specific technical information.
This is correct and it is therefore not accepted that an approach to allocate a broad area for development would be robust, deliverable or effective. The SA goes on to state:
3.5. The allocation of a strategic site at Southbourne would also be a significant change in approach at a late stage of the Local Plan preparation process. The additional technical evidence that would need to be undertaken to justify a Local Plan allocation at this stage would impact significantly in terms of delay to the finalisation of the Regulation 19 Local Plan and its subsequent submission to the Secretary of State for examination. For these reasons Option 2 was discounted.
This provides further weight to the position set out within these representations that the expectation of delivery from the ‘broad area’ at Southbourne is overly ambitious and it is clear there is significant technical work to undertake on the delivery of homes from the allocation as part of the future plan making process.
The SA goes on to set out the justification of option 3 as follows:
3.6. The identification of a BLD is consistent with the National Planning Policy Framework (NPPF). Paragraph 68 states that for years 6 -10 of the plan, local authorities should through their planning policies identify a supply of ‘specific, developable sites or broad locations for growth’.
3.7. There is no definition of ‘broad locations’ in national policy. It is generally taken to be an area within which housebuilding could reasonably be expected to take place based on the availability of land having regard to the Housing and Economic Land Availability Assessment (HELAA). A BLD does not have a specific geographic location or physical boundary. Areas are identified as broad locations because at that stage it is not yet possible to identify the precise boundaries of a site until further detailed site work has been done. By identifying a broad location gives flexibility and may increase the prospect of appropriate and effective growth i.e. where there is some doubt as to the most effective site boundary could prevent growth coming forward or prevent the most sustainable solution. However, a broad location might be expected to accommodate a significant amount of development; in some cases a single site may be of a sufficient size to accommodate all of the potential development or a number of sites that abut other sites may be considered together.
This is not considered a rational approach to take. Whilst there is no definition of ‘broad location’ within national policy it is considered that the words ‘specific’ and ‘developable’ must be taken at their basic meaning and indeed as set out in the glossary of the framework. It is not considered that the allocation of such a large area for a ‘broad location’ would be specific, effective or justified against the tests of soundness in the NPPF.
The allocation of Southbourne under policy A13 would represent over 10% of the total housing delivery in the plan. This is considered too significant to leave to a broad location for development.
As set out, Southbourne Parish Council is already at advanced stages of a revised Neighbourhood Plan which does not include the allocation of any of the development parcel envisaged under policy A13. In terms of delivery through the Site Allocations DPD, the timetable for this is set out within the most recent Local Development Scheme (January 2023) which sets out the following:

**Table**

As set out, the housing trajectory assumes delivery of dwellings from the allocation at Southbourne in 2028/29. Given that the Site Allocation DPD would not be delivered until Winter 26/27 at the earliest, and the delivery through the Neighbourhood Plan has been discounted by the progression of a NP without the allocation, then the deliverability of any development at Southbourne remains wholly unjustified within the plan period.
The SA goes on to set out the approach to alternative sites in Southbourne Parish as follows:
4.3. The 2021 HELAA assessed 41 sites in Southbourne Parish (see Appendix 1). Of these, 18 sites were discounted because the site either had planning permission/were under construction (five sites); it was within the Chichester Harbour Area of Outstanding Natural Beauty (AONB) (eight sites); there was insurmountable access issues (two sites); it was in Flood Zone 3 (one site); or there was a legal restriction on the site use (in this case a Section 106 Agreement restricting use to open space) (two sites). These sites were not considered further for inclusion within the BLD.
The land at Main Road was one of the sites discounted due to being located in the AONB. For the reasons set out within subsequent sections of these representation, it is not considered that it was necessary to discount sites within the AONB as other councils have taken the decision to use such sites to meet housing need and not considered the AONB as an absolute constraint.
Specialist Accommodation for Older People
Para 5.41 of the regulation 19 of the Plan sets out the following:
The Housing and Economic Development Needs Assessment (HEDNA) 2022 estimates the greatest population increase in the district by 2039 to be those in age groups 75 and over. To support an ageing population there should be provision of suitable housing options for the differing needs of individuals, including:
• Sufficient adaptable and/or accessible market housing stock so that those wishing to remain in their own homes can do so as their needs change.
• Smaller homes, for those wishing to downsize, and bungalows.
• Extra care housing, for those able to live relatively independently but requiring on-site support.
• Care homes, for those needing additional support.
Table 8.1 of the HEDNA sets out the current population breakdown for separate groups over 65 and demonstrates that CDC has a significantly higher percentage in all age groups over 65 than the average in West Sussex, the South East or England:

**Table**

Policy 8.12 of the HEDNA goes on to set out the need for different groups as follows:

**Table**

The HEDNA sets out the following commentary in this regard:
8.41 It can be seen by 2039 there is an estimated need for between 2,131 and 2,872 additional dwellings with support or care across the whole study area. In addition, there is a need for 429-800 additional nursing and residential care bedspaces.
8.42 Typically for bedspaces it is conventional to convert to dwellings using a standard multiplier (1.80 bedspaces per dwelling for older persons accommodation) and this would therefore equate to around 238-445 dwellings.
8.43 In total, the older persons analysis points towards a need for around 2,369-3,317 units over the 2021-39 period (132-184 per annum) – the older person need equates to some 17-24% of all homes needing to be some form of specialist accommodation for older people.

Given the significant need for Specialist Housing Accommodation across the district it is vital that this is planned for adequately within the emerging Local Plan. The Planning Practice Guidance sets out why it is important to plan for housing needs of older people as follows:
The need to provide housing for older people is critical. People are living longer lives and the proportion of older people in the population is increasing. In mid-2016 there were 1.6 million people aged 85 and over; by mid-2041 this is projected to double to 3.2 million. Offering older people a better choice of accommodation to suit their changing needs can help them live independently for longer, feel more connected to their communities and help reduce costs to the social care and health systems. Therefore, an understanding of how the ageing population affects housing needs is something to be considered from the early stages of plan-making through to decision-taking.
Paragraph: 001 Reference ID: 63-001-20190626 Revision date: 26 June 2019
The PPG goes onto state how housing requirements of such groups should be addressed in plans:
Plan-making authorities should set clear policies to address the housing needs of groups with particular needs such as older and disabled people. These policies can set out how the planmaking authority will consider proposals for the different types of housing that these groups are likely to require. They could also provide indicative figures or a range for the number of units of specialist housing for older people needed across the plan area throughout the plan period.
Paragraph: 006 Reference ID: 63-006-20190626 Revision date: 26 June 2019
Policy H8 states:
All housing sites over 200 units, including those allocated in this plan, will be required to provide specialist accommodation for older people to include a support or care component. The specific type and amount of accommodation required will depend on the size and location of the site.

Proposals for specialist housing, such as homes for older people, student, HMOs or essential worker accommodation, and other groups requiring specifically designed accommodation will be supported where the following criteria are met:

1) There is an identified need;
2) It will not lead to a concentration of similar uses in an area that would be detrimental to the character or function of an area and / or residential amenity;

3) It is in close proximity to everyday services, connecting by safe and suitable walking / cycling routes or public transport for the intended occupier;
4) It can be demonstrated that the development is designed to provide the most appropriate types of support for the target resident;
5) It can be demonstrated that revenue funding can be secured to maintain the longterm viability of the scheme (if relevant to the type of accommodation proposed); and
6) The scheme is supported by the relevant agencies (if relevant to the accommodation type to be provided).

Proposals which may result in the loss of specialist needs accommodation will not be permitted unless it can be demonstrated that there is no longer a need for such accommodation in the plan area, or alternative provision is being made available locally through replacement or new facilities.

Whilst this approach goes some way to addressing the care needs it is felt that the policy lacks effectiveness and should take a far more constructive and positive approach to the provision of housing for older people.
The wide range of different housing typologies is set out within the Planning Practice Guidance as follows:
• Age-restricted general market housing: This type of housing is generally for people aged 55 and over and the active elderly. It may include some shared amenities such as communal gardens, but does not include support or care services.
• Retirement living or sheltered housing: This usually consists of purpose-built flats or bungalows with limited communal facilities such as a lounge, laundry room and guest room. It does not generally provide care services, but provides some support to enable residents to live independently. This can include 24 hour on-site assistance (alarm) and a warden or house manager.
• Extra care housing or housing-with-care: This usually consists of purpose-built or adapted flats or bungalows with a medium to high level of care available if required, through an onsite care agency registered through the Care Quality Commission (CQC). Residents are able to live independently with 24 hour access to support services and staff, and meals are also available. There are often extensive communal areas, such as space to socialise or a wellbeing centre. In some cases, these developments are known as retirement communities or villages - the intention is for residents to benefit from varying levels of care as time progresses.
• Residential care homes and nursing homes: These have individual rooms within a residential building and provide a high level of care meeting all activities of daily living. They do not usually include support services for independent living. This type of housing can also include dementia care homes.
[Paragraph: 010 Reference ID: 63-010-20190626].

It is considered that a residential care home (including housing for dementia needs) could be developed on the Land South of Main Road without causing harm to the AONB and this would provide for a clear need within the village whilst also providing employment to local workers.
Development in AONB
The NPPF sets out the following in relation to development in the AONB at paragraph 172 as follows:
Great weight should be given to conserving and enhancing landscape and scenic beauty in National Parks, the Broads and Areas of Outstanding Natural Beauty, which have the highest status of protection in relation to these issues. The conservation and enhancement of wildlife and cultural heritage are also important considerations in these areas, and should be given great weight in National Parks and the Broads. The scale and extent of development within these designated areas should be limited. Planning permission should be refused for major development55 other than in exceptional circumstances, and where it can be demonstrated that the development is in the public interest. Consideration of such applications should include an assessment of:
a) the need for the development, including in terms of any national considerations, and the impact of permitting it, or refusing it, upon the local economy;
b) the cost of, and scope for, developing outside the designated area, or meeting the need for it in some other way; and
c) any detrimental effect on the environment, the landscape and recreational opportunities, and the extent to which that could be moderated
Footnote 55 of paragraph 172 is relevant for the consideration of what is considered as major development and states:
For the purposes of paragraphs 172 and 173, whether a proposal is ‘major development’ is a matter for the decision maker, taking into account its nature, scale and setting, and whether it could have a significant adverse impact on the purposes for which the area has been designated or defined.
No evidence is set out within the Local Plan or supporting evidence base to state what is considered to be a major development site in the district. Neither the Chichester Harbour AONB: State of the AONB Report (May 2018) or the Chichester Harbour AONB Landscape Character Assessment (April 2019) contain any references to what is considered to constitute a major development.
This is a matter which has been considered at length within other Local Plan examinations. As part of the evidence for its Local Plan, the South Downs National Park sought successive legal opinions from James Maurici QC on what should be considered as ‘Major Development’ in the AONB and have subsequently become widely known as the ‘Maurici Opinions’ in other Local Plan examinations. The opinions set out the following conclusions:
• It is a matter of planning judgement to be decided by the decision maker.
• Major development is to be given its ordinary meaning, and it would be wrong to apply the definition of major development contained within the Town and Country Planning (Development Management Procedure) (England) Order 2015. It would also be wrong to apply any set or rigid criteria for defining major development, and the definition should not be restricted to development proposals that raise issues of national significance.
• The decision maker may consider whether the proposed development has the potential to cause a significant adverse impact on the purposes for which the area has been designated or defined, rather than whether there will indeed be a significant adverse impact from the proposed development.
• The decision maker may consider the proposed development in its local context as a matter of planning judgement.
• There may be other considerations but which may not determine whether a proposed development is major development. For example, if the proposed development is Environmental Impact Assessment (EIA) development.
• The ordinary sense of the word ‘major’ is important and the decision maker should take a common sense view as to whether the proposed development could be considered major development.

In the Mid Sussex District Council Site Allocations DPD Evidence Base there is a topic paper setting out consideration of Major Development in the AONB and concludes that several of the allocations, in some cases up to 70 dwellings, would not be classed as major development in the AONB following a detailed review of each of the factors as set out in footnote 55 of the NPPF against each proposed allocation.
It is considered that this approach should have been undertaken for each of the individual sites discounted in the Local Plan (including Main Road, Hermitage), rather than simply discounting on the sole fact that they were in the AONB.
Sustainability Appraisal
The legal frameworks for SAs are set out within section 19 of the Planning and Compulsory Purchase Act 2004 which states that the authority must prepare a plan with the objective of contributing to the achievement of sustainable development. Moreover, the requirements of the Environmental Assessment of Plans and Programmes Regulations 2004 states that SAs must ensure that the potential environmental effects are given full consideration alongside social and economic issues.

It is not considered that the council has given full consideration to all effects nor are the conclusions of the SA in respect of those impacts robust and logical.
Paragraph 32 of the framework goes on to state that the SA should demonstrate how the plan has addressed relevant economic, social and environmental objectives (including opportunities for net gains). Significant adverse impacts on these objectives should be avoided and, wherever possible, alternative options which reduce or eliminate such impacts should be pursued. Where significant adverse impacts are unavoidable, suitable mitigation measures should be proposed (or, where this is not possible, compensatory measures should be considered).
The SA sets out whether it was reasonable to explore higher growth scenarios as follows:
5.2.12 As discussed above, the PPG on Housing and Economic Needs Assessment sets out reasons for providing for ‘above LHN’ through local plans, referring to situations where there are “growth strategies for the area... (e.g. Housing Deals); strategic infrastructure improvements that are likely to drive an increase in [need]; or an authority agreeing to take on unmet need from neighbouring authorities...” Also, affordable housing needs can serve as a reason for considering setting the housing requirement at a figure above LHN, with the PPG stating: “An increase in the total housing figures included in the plan may need to be considered where it could help deliver the required number of affordable homes.”
5.2.13 However, in the Chichester context there is little or no argument for exploring scenarios whereby the housing requirement is set at a figure above LHN, given the issues discussed above at paragraph 5.2.11. Unmet housing needs are a widespread issue across the sub-region, but there is no realistic potential to provide for unmet housing needs within Chichester. At the time of the Preferred Approach consultation (2018/19), the proposal was to provide for both locally arising housing needs in full and a proportion of the unmet needs arising from the SDNP (41 dpa). Also, it is noted that the SA report published as part of the consultation considered scenarios – considered to be ‘reasonable’ at that point in time – that would see the housing requirement set at figures significantly above LHN (800 dpa and 1,000 dpa were tested). However, at the current time, in light of the latest available evidence, scenarios involving setting the housing requirement at a figure above LHN can be safely ruled out as unreasonable.
It is not considered that a figure at or above the LHN would be considered unreasonable and that this matter has not been given full consideration (as per the requirements of the SA regulations), particularly in regard to the social impacts of not meeting housing need in full.
Appendix V of the SA sets out commentary in regard to Parish Scenarios. This sets out the following in relation to Southbourne (with emphasis added):

With regards to the extent of the broad location, this matter is considered fairly uncontentious (for the current purposes of arriving at reasonable growth scenarios). Specifically, the proposal is to identify an area of search that includes developable HELAA sites that relate relatively well to the Southbourne settlement edge and avoid the Strategic Wildlife Corridor associated with the Ham Brook, also naturally mindful of the need to maintain a landscape gap to settlements within Chidham and Hambrook Parish, to the east. It is important to note that the total theoretical capacity of developable HELAA sites within this broad area is far in excess of the number of homes that would need delivered under any reasonably foreseeable scenario.
The broad location provides flexibility to identify a detailed allocation either through a Site Allocations Plan or, should the Parish Council wish to do so, a revised Southbourne Parish Neighbourhood Plan. Site selection considerations will likely include: transport and access (including mindful of links to the train station and by car to Portsmouth); accessibility and community infrastructure (mindful of the secondary school, recreation ground and employment area at the western edge of the village); heritage (e.g. there is a historic rural lane to the east, associated with two listed buildings), topography and landscape (including any visual links to the SDNP and/or the AONB) and the potential to secure a strategic scheme that delivers more than just new market homes, and potentially significant ‘planning gain’ for the local community.
With regards to the number of homes that should be supported, there is logic to further exploring the scale of growth that was previously considered through the now withdrawn Southbourne NP, and it is not clear that there is an argument for considering lower growth. Additionally, there is a clear argument for exploring the possibility of higher growth, to ensure a suitably comprehensive scheme, with a high level of ‘planning gain’.
In conclusion, there are two scenarios for Southbourne Parish, namely completions, commitments and windfall plus either: 1) a broad location for 1,050 homes; or
2) a broad location for ~1,500 homes.
As set out, it is not considered that the SA has considered adequate reasonable alternatives to growth at Southbourne which would include allocation of sites elsewhere in the village including within the AONB that can deliver in the early part of the plan period.

Conclusions
There are significant concerns on the soundness of the plan in terms of whether it is effective, justified, positively prepared or consistent with national policy in accordance with paragraph 35 of the NPPF.

It is not considered that the Council has justified the extent of the under supply of housing against the established housing need. There are significant concerns over the delivery of housing from the strategic allocations within the unjustified timescales as set out within the trajectory contained in the plan.
The Council has not adequately considered reasonable alternatives through the Sustainability Appraisal as published alongside the plan which should have included consideration to the allocation of the site in order to deliver housing in the early part of the plan period.
The plan fails to adequately consider the need for housing for older people, given that the population over 65 across CDC is significantly in excess of the average in the county, south east and county as a whole.
CDC discounted all sites within the AONB, including the site at Main Road, Hermitage, at an early stage of the plan making process. This is not considered effective or consistent with national policy which does not class such sites as an absolute constraint. Other local authorities have allocated such sites in order to deliver the full objectively assessed needs.
ABC will continue to make further representations on the deliverability of the site as part of the plan making progress.

See attached representation.

None

Chichester Local Plan – Proposed Submission
Duty to Co-operate
The Statutory Housing Authority welcomes the opportunity to comment on the Chichester Local Plan 2021 – 2039 and strongly commends the Local Planning Authority on progressing with its plan-making activities at a time when a number of Local Planning Authorities across the country have stalled owing to a state of flux in the national policy picture.
Chichester District Council Housing Authority considers that the Chichester Planning Policy Team have engaged in a pro-active manner in an ongoing basis to meet the needs of our communities. Furthermore, the authority has been consulted throughout in the crafting of the proposed housing policies H1 – H10 and confirm that the Duty to Co-operate has been met in this regard.

Is it legally compliant?
The Housing Authority consider the plan as presented, to be legally compliant and have no specific comments in relation to the Sustainability Appraisal, Habitats Regulations Assessment or the Statement of Community Involvement.

Soundness
The Housing Authority is satisfied that the plan is positively prepared and seeks to meet the housing need for both market and affordable housing, so far as is practicable, whilst having consideration for the various constraints of the plan area including AONB designation, heritage matters, flooding matters and infrastructure capacity issues. The Housing Authority believe the plan seeks to balance between these competing demands in a sustainable and realistic manner for the plan period 2021 -2039.
The Housing Authority consider the plan provides for a reasonable evidence based strategy which is consistent with national planning policy and guidance and contributes to the delivery of sustainable development, having regard to the reasonable alternatives available.
Meeting housing need
The Housing Authority considers the plan meets housing need so far as is realistically possible considering the constraints of the plan area.
Policy H1, including the Broad Spatial Distribution - is noted.
Policy H2, the strategic locations are broadly located in areas where the Council held Housing Register indicates the highest level of housing need.
Policy H3 - is noted.
Policy H4 – The Housing Authority fully endorse and support the provisions contained in Policy H4.
Policy H5 - The Housing Authority is supportive of the housing mix outlined in policy H5 and the ability to reflect local need where it is appropriate to do so. Furthermore it is right to provide this level of certainty, whilst allowing for some degree of flexibility.
Policy H6 - The Housing Authority are in full support of this policy and fully endorse the opportunity for Neighbourhood Planning groups to bring forward Self and Custom Build serviced plots. The Housing Authority are encouraged by the potential that may arise with the call for sites for such plots. We look forward to working with our colleagues and communities to bring forward Self and Custom Build opportunities within the plan area.
Policy H7 - The Housing Authority recognise the difficulties in bringing forward exception sites for affordable housing and welcome this policy which seeks to enable the needs of our rural communities to be met.
Policy H8 - The Housing Authority strongly advocate for the inclusion of specialist accommodation for older people, and the intention is to secure affordable housing across all specialist accommodation for older people, including Extra Care to meet the needs of those unable to secure such accommodation in the open market.
H9 – The Housing Authority support the policy to retain accommodation for rural workers.

H10-H14 – The Housing Authority has no observations to make in relation to these polices.

See attachment.

Consideration of omission site (HELAA reference HCC0038) Land north of New Bridge Farm for 264 dwellings, adjacent to site allocation A6 West of Chichester.

These representations are made on behalf of our client, the Sadler Family who wish to Policy NE4 of the Chichester Local Plan 2021 – 2039 Proposed Submission Regulation 19 Version.
Background
Our clients own approximately 17 acres of farmland at Salthill Park which is edged red at Enclosure 1. The land has been promoted at all relevant opportunities to Chichester District Council but wish to confirm to Chichester District Council and the Inspector that the land is available for development.
Site suitability
The land is edged red in Appendix 1 of this statement and is identified as land east of Salthill Road. It has been identified in the HELAA under site ref HCC0038, Land north of New Bridge Farm for 264 dwellings. The land consists of agricultural land and a well-defined landscape boundary on all sides.
The land immediately adjoins site allocation A6 West of Chichester for 1,600 units. Phase 1 of this land now has detailed permission, whilst the reserved matters for Phase 2 is being considered by Chichester District Council. In addition, we are also promoting part of an additional parcel of land to the south of this which is referenced HCC0038 in the HELAA.
Our clients have promoted the land at all opportunities and wanted to continue to make Chichester District Council and the Inspector aware of its availability.
Policy NE4
The policy is considered to be unsound, inconsistent national policy and is unjustified.
The owners object to these Strategic Wildlife Corridor (SWC) locations. The Council has not published its evidence base in the Regulation 19 consultation version for applying this new constraint layer. It states ‘significant habitat surveys, data collection and evidence gathering to enable the mapping of the proposed corridors’ has been undertaken, but it is not available to review for the Regulation 19 consultation.
Nor do the Council state the current use of these corridors, some are arable farmland and therefore do not necessarily present the best place for blanket ‘additional layer of planning restraint’ wildlife corridor. The Council have also not considered that these sites could have future development potential and maybe some of the better and more sustainable (with minimal other constraints) for future development in terms of sequential testing and are therefore precluding sustainable future development in these locations without having undertaken a proper assessment of all sites in the District.
The built environment and nature can work in unison and doesn’t require blanket policy designations. Furthermore, the Council have not fully set out the methodology for applying a blanket ‘strategic wildlife corridor’ at the locations it proposes in the changes to the policy map. The Council have not fully consulted those affected by SWC and other stakeholders. The Council is further applying yet another restrictive ‘additional layer of planning restraint’ in a District which is already highly constrained, for example AONB, extensive areas covered by a National Park, the District contains large numerous ecological designations SSSI/SPA, Local Nature Reserves/National Nature Reserves and Nutrient Neutrality applies.
Accordingly, this further constraint, which appears to be located in areas adjacent to the existing settlements, where logically future periods of Plan growth would be located, appears unjustified and inappropriate in its current form.

We strongly support an amendment to be made to Policy H2 to allow for the provision of circa (or a minimum of) 1,250 dwellings at Southbourne

We broadly support the sixteen development requirements included within the allocation wording of emerging policy A13; these are briefly addressed in turn below;

Provide an appropriate mix of housing types, sizes and tenures to meet evidenced local need including affordable housing and specific provision to meet specialised housing needs including 16 serviced self/custom build plots, accommodation for older people and accessible and adaptable homes in accordance with relevant Plan policies; The scheme would present an emerging policy compliant mix of housing types and tenures. We would look to work closely with the local community to identify the appropriate location and phasing for self and/or custom build plots within the Masterplan to ensure the plots come forward in a suitable location that has been considered alongside the wider masterplanning exercise.
Provide 12 gypsy and traveller pitches in accordance with Policy H11; Whilst we recognise the need for the provision of G&T pitches within the District; based on the previous discussions with the Neighbourhood Planning group and local community we feel that the Council would benefit from exploring more appropriate areas for new sites and/or the intensification of nearby sites.
Provide a serviced site(s) for travelling showpeople which should deliver 12 plots, each of sufficient size to allow for the provision of accommodation and equipment plus storage/maintenance, in accordance with Policy H11; As above.
Provide a suitable means of access to the site(s), securing necessary off-site improvements (including highways) in conformity with the Policy T1 (Transport Infrastructure) and T2 (Transport and Development) to promote sustainable transport options; The comprehensive masterplanning approach that has been and will continue to be taken with the scheme will ensure a cohesive layout and access arrangement to best integrate with the existing community. Paragraphs 2.20-4 above outline our recommendation to the Council with regards to infrastructure improvements and we maintain that the most effective way of securing on- and off-site improvements is to place the onus on the developer to ensure their delivery and integration with the local community.
Provide any required mitigation to ensure there is no adverse impact on the safety of existing or planned railway crossings; Any submission will be supported by a robust transport assessment and mitigation strategy.
Ensure adequate provision of supporting infrastructure including education provision, community facilities and transport in accordance with the most up to date Infrastructure Delivery Plan; We support the need for supporting infrastructure, which forms a primary objective of the proposals on last east of Southbourne. We feel that their delivery will be most appropriately secured outside of the limitations of CIL.
Give detailed consideration of the impact of development on the surrounding landscape, including the South Downs National Park and Chichester Harbour AONB and their settings. Development should be designed to protect long-distance views to the South Downs National Park; We support the desire to protect these areas and their settings. Any submission will be supported by a full landscape and visual impact assessment to demonstrate that the scheme east of Southbourne can be a cohesive visual element into the existing built form of the village and avoid any element of incongruousness or harmful impact on the surrounding protected areas.
Ensure that multifunctional green infrastructure provision is well related to the overall layout and character of the development as well as providing opportunities to extend into the wider countryside and surroundings; The proposed scheme to the east of Southbourne would be capable of delivering a significant portion of the Green Ring, originally allocated in the Southbourne Neighbourhood Plan 2015. The Consortium is also supportive of a central feature through the site and the approach to align the Green Ring with the north-south public right of way which connects with the green infrastructure on the eastern edge of the neighbouring Cooks Lane development. This approach would allow the green ring to be cohesive with the neighbouring green infrastructure, whilst also maintaining the public rights of way, in conformity with paragraph 98 of the NPPF. Whilst this central ‘Inner’ Green Ring could include play, gym trail, walking and cycling, benches and a variety of greenspace (amenity and natural), which would create a varied and engaging corridor, we would work wish to with the Neighbourhood Plan Group to identify the best mechanism to position sports and allotments through a masterplanned approach.
Demonstrate that development would not have an adverse impact on the nature conservation interest of identified sites and habitats including the strategic wildlife corridors; We support the desire to protect key habitats and the scheme will be informed by extensive habitat surveys and mitigation strategies.
Provide mitigation to ensure the avoidance of adverse effects on the SPA, SAC and Ramsar site at Chichester Harbour including contributing to any strategic access management issues, loss of functionally linked supporting habitat and water quality issues relating to runoff into a European designated site; We echo the need to avoid adverse effects on the SPA, SAC and Ramsar site at Chichester Harbour and all necessary mitigation will be provided on- and off-site where required.
Protect any other key views; We support the desire to protect the key views of the wider area. Any submission will be supported by a full landscape and visual impact assessment.
Ensure that allocations and policies accord with the sequential approach to flood risk, and that development will be safe for its lifetime, taking account of climate change impacts, as per the requirements set out in national policy and having due regard to the council's latest Strategic Flood Risk Assessment; We support this requirement and discussions with the Environment Agency and the LLFA will inform the most effective flood mitigation and drainage strategy for the site.
Ensure sufficient capacity within the relevant wastewater infrastructure before the delivery of development as required; Addressed in Paragraphs 2.5-10 above, we have concerns regarding the emerging plan’s wording around the future capacity improvements of WwTW in the Apuldram catchment.
Demonstrate that development would not have an adverse impact on the significance of heritage assets or their settings; Any submission will be supported by a full heritage assessment and the layout and scale will be adjusted accordingly to best protect any nearby heritage assets.
Maintain the character and integrity of existing settlements and provide clear separation between new development and neighbouring settlements including through the definition and protection of landscape gaps. The consortiums approach allows for the masterplan to be designed to best protect the existing settlement of Southbourne from any coalescence with surrounding hamlets. The location of development to the east of the village and the inclusion of the Green Ring is the most appropriate and effective way to protect the village’s visual separation and identity.
Consider the Minerals Safeguarding Area and in line with the West Sussex Joint Minerals Local Plan, a minerals resource assessment may be required to assess if the land contained a mineral resource that would require extraction prior to development. Account should also be taken of the West Sussex Waste Local Plan and associated guidance in relation to safeguarding policy W2. We support this inclusion, and any proposal will be accompanied by a minerals resource assessment if needed.

In general, we support the comprehensive masterplanning approach for development in Southbourne. Our proposals are the result of a complete collaboration between landowners and reiterate that the Consortium has always maintained a desire to deliver a comprehensive development that secures substantial benefits to the existing community. It is obviously important that any landowners included within the proposed allocation are required to work collaboratively with others and the local community, sharing the overall infrastructure and policy requirements fairly and proportionately.

We strongly support an amendment to be made to Policy H2 to allow for the provision of circa (or a minimum of) 1,250 dwellings at Southbourne. The accompanying sustainability appraisal, discussed later, supports a larger quantum of development on this site, with benefits realised of accessibility, environmental quality, climate change mitigation, community enhancement, health, historic environment and landscape. A major element of our proposals at Southbourne are in the infrastructure and community improvements to the local residents and increasing the overall housing numbers by less than 20% on this site is key in the wider delivery of package of the infrastructure improvements associated with the scheme.

There is no intention to deliver piecemeal development proposals within the area, which would likely prejudice the delivery including infrastructure delivery. We maintain the most effective way to ensure the infrastructure improvements associated with the scheme would come forward at an effective and appropriate time would be to remove the need for the proposals to contribute to CIL and instead have a direct commitment between the scheme and the improvements to Southbourne.

The quantum of development at Southbourne (A13) should be 1,250 to reflect the conclusions of the sustainability appraisal, the capacity within the land east of Southbourne and the importance in bringing forward all infrastructure improvements to the village and wider area.

REPRESENTATION SUMMARY

CDC fails on a number of counts to provide a sound reason for constraining development delivery to 535 dwellings per annum. We find that the Council’s failure to adhere to the OAN on the basis of ineffective evidence results in plan that has not been positively prepared and adopts a strategy that is not justified. We believe the plan is capable promoting a greater level of housing delivery which will, in turn, help bring the estimated infrastructure contribution per dwelling to a more deliverable and realistic level.

This representation provides continued support and draft policy context for the development on land east of Southbourne. We consider it to provide a suitable and sustainable location for large-scale strategic residential growth and substantial associated infrastructure improvements.

The area was due for allocation within the Southbourne Neighbourhood Plan, having been initially allocated 1,250 dwellings on ‘land east of Southbourne’, prior to its removal post Examination (based on concerns of the Examiner over a pre-emption of the emerging local plan). Importantly, the Examiner did not conclude that the proposed allocation was unsustainable for growth or inappropriate in size, but simply that the timing of the Neighbourhood Plan was too early against the emerging Local Plan timetable which had unfortunately been delayed.

We continue to recommend that the land east of Southbourne (Policy A13 in the emerging LP) provides the most appropriate location for development at Southbourne. Indeed, the land to the east of the settlement was chosen as the most appropriate location, as opposed to the land to the west which is more constrained by the A27 and would likely result in amalgamation with the settlement of Emsworth.

We consider that the increase in the quantum of development at Southbourne from 1,050 to c1,250 not only ensures the highest level of community enhancements and infrastructure improvements for Southbourne and the wider area but also helps mitigate certain aspects of the emerging plan that risk being found unsound, including the potential for delays in housing delivery across the largest strategic sites and the potential for Chichester District to accommodate unmet need across neighbouring authorities (and within SDNP).

Considering the above, and in terms of specific policy amendments, we recommend the following policies be reworded to ensure the plan’s overall soundness:
Policy H1 – Meeting Housing Needs – The housing requirement (10,350) for the plan period 2021-2039 must reflect Objectively Assessed Need to avoid the risk of failing to be seen as positively prepared. The evidence base on which the justification for a reduction in housing delivery is flawed and not credible. The plan fails the tests of soundness to this regard and Policy H1 should be amended in line with a reassessment of highway constraints.
Policy H2 – Strategic Locations/Allocations 2021-2039 – The quantum of development at Southbourne (A13) should be 1,250 to reflect the conclusions of the sustainability appraisal, the capacity within the land east of Southbourne and the importance in bringing forward all infrastructure improvements to the village and wider area.
Policy A13 – Southbourne Broad Location for Development - In line with the above, the total number of dwellings allocated to Southbourne should be 1,250. Further, it is recommended that a specific location is selected within Southbourne, to align with all other allocations within Chapter 10 and to avoid a significant risk to the delivery of housing. No rationale is presented as to why development in Southbourne should be delayed until the adoption of a subsequent DPD or Neighbourhood Plan. The long-term assessment and findings of the Neighbourhood Plan group and the plan examiner remain sound and should be respected and reflected in a specific and precise housing allocation for the village. We recommend this policy is rewritten to allocate 1,250 dwellings on land east of Southbourne and to align with the comprehensive masterplanning exercise that has been completed to-date.
These representations bring to light a number of recommended reconsiderations with regards to the emerging local plan, these include a reassessment of the quantum of development in Southbourne, the mechanism for infrastructure funding and delivery, the contingency planning around wastewater treatment capacity and the supporting of Vision & Validate as an approach for encouraging safe, efficient and sustainable transport.
For the reasons outlined throughout, these representations also raise significant concerns that the plan as drafted, in particular the housing delivery strategy, risks being found ‘unsound’ on the grounds of failing to be positively prepared and lacking a fully considered highways evidence base. We believe the changes outlined above with regards to reflecting OAN and adding realistic capacity and specificity to the proposed allocation in Southbourne will help address these concerns.

Reduce the number of houses so that the density is significantly lowered and is not concentrated in one area to 'dwarf' existing houses at Saxon Meadow

See attached representations