Policy T1: Transport Infrastructure

This brings the sites A11 and A12 into conflict with the monitor and manage approach which the Chichester District Council Local Plan Transport Assessment suggests and Policy T1. The monitor and manage approach is focused on moving away from use of cars as is policy T1. The developments at A11 and A12 will all involve car reliance for primary school pupils.
Policy A11 and Policy A12 should be removed from the local plan.

Emphasis in the plan is use of public transport or walking. Sites in policy A11 and A12 have no primary school capacity and have no room for expansion. Schools identified to serve these sites are not within walking distance or reachable by public transport. Among the schools identified as suitable for the A11 and A12 sites are Funtington, Compton and Up-Marden, Westbourne and Thorney Island. These schools do not have transport links and are not within walking distance of A11 and A12 sites.

The stated conditions for new development are unrealistic and too vague.
For example: "Ensuring that new development is well located and designed to avoid or minimise the need for travel, encourages the use of sustainable modes of travel as an alternative to the private car and provides or contributes towards new or improved transport infrastructure;"
Based on planning consents to date and the planned scattered development sites this objective is going to be rarely met.

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

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

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

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

Basically there is a lack of priority in the plan to sustainable and active travel modes. All funding seems to be based on highway improvements to the A27 to accomodate the anticipated increase in car trips with no mitigation and no certainty of infrastucture improvements occuring in line with land release.

Only allow a number of new homes in line with what the current road network can handle and protect Chichester harbour AONB and wild life corridors from further pollution. For the roads to be better maintained before any new major development is permitted. To install 20mph zones for A259 villages and more pedestrian road crossings so people can cross safely. Consider alternative routes to the A259 when the A27 is closed.

The A259 in Fishbourne is already at capacity, with tailbacks from A27 roundabout to the village at rush hour. The road simply can not take any extra traffic as it currently is. The A259 and Clay lane road surfaces are not maintained well enough for the current flow, let alone for the planned new development from Chichester to Southbourne. Our homes on the A259 already shake from passing large vehicles, especially when the A27 is shut. Trying to cross the A259 as a pedestrian with children is already dangerous enough.

Public transport is not in the control of CDC and therefore it is not possible to guarantee improved and expanded services. The proposed the £7,728 charge per unit towards infrastructure is yet to be confirmed as legally compliant. Thus an even greater reduction in housing numbers to the Chichester area is required.

Over capacity at the Fishbourne roundabout was identified in 2014, there has been a massive increase in housing west of Chichester between 2014 and 2023 but no improvement to the roundabouts have been implemented to date. There is no guarantee that funding to improve the A27 or Fishbourne roundabout will be available within the timescale of the Plan.
Congestion has been a problem since 2014 and this strategy does not offer a solution. There is a clear omission here that funding is not available to facilitate the improvements required to address the current and worsening congestion caused by future development.

Agreed Statements of Common Ground need to agreed before the Draft plan is examined in public so that all parties can debate the practicality as well as the desirability of the key allocations. There are an absence of transport measures proposed, especially sustainable and active, to address the current levels of congestion, pollution and degradation of the environment.

No Statement of Common Ground has been agreed with neighbouring authorities and key statutory undertakers as required. e.g. National Highways. It is not sufficient to say this will be done in the future as many the large housing proposals require key infrastructure to be agreed in advance of development.

.

The locations and level of housing will not minimise the need to travel by car. The A27 improvements need to be in place before the housing before it becomes impossible to travel and the climate change targets are breached. Public transport requires increased capacity, infrastructure and frequency which will need considerable investment. Is this going to be provided by Southern Rail and Stagecoach? Where is the collaboration? The West Sussex Bus Plan does not address how this will happen. There is too heavy a reliance on developer contributions for all aspects of travel, including local networks and active travel.

Amend the plan as follows:
Policy T1: Transport Infrastructure
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 encourage increased use of sustainable modes of travel, such as public transport, cycling and walking. The council will work with Network Rail, ORR, Southern Railways, 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 including new train stops on existing lines (e.g. for Tangmere). 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 improve air quality, by:
• Avoiding or reducing the need to travel by car for journeys short and long;
• Enabling access to sustainable means of travel, including public transport, walking and cycling;
• Managing travel demand; and
- Mitigating the impacts of travel by car.
• Providing new station stops on existing train lines when large development is planned (e.g. Policy A14)

There is much to commend in this document and the supporting technical documents that accompany it, and I have listed in the appendix to this letter 26 such paragraphs and policies. I am happy for my support to be registered against these sections of your consultation document. There is also much upon which I must represent a concern, so I attach representations relating to 22 paragraphs or policies.

I am happy to participate in a hearing session, and I would flag at this stage that the common theme that links all of these representations is the need to safeguard the natural and built environment in and around Saxon Meadow, Tangmere from the risks of unsustainable development, I consider that the independent examiner should focus their review on the aspects of the local plan that relate to this matter.

Appendix 1: list of policies that I support
1. P14, 1.23, 1.24: Duty to cooperate
2. P24, para 2.30 "the council declared a climate emergency in July 2019"
3. P24, para 2.32 — "all proposal for new development should be considered in the context of a climate emergencV'
4, P30: Objective 2: natural environment: "development will achieve net gains in biodiversity'
5. P43, 4.1 "National policy promotes increasing energy efficiency, the minimisation of energy consumption and the development of renewable energy sources"
6. P43, 4.3: "Some renewable energy projects provide significant opportunities to enhance biodiversitV'
7. P53, Policy NE5: Biodiversity and Biodiversity Net Gain
8. P62, Para 4.42: Hedgerows and some types of woodlands are identified as a priority habitat
9, P62, Policy NE8: Proposals should have a minimum buffer zone of 15 metres from the boundary of ancient woodland or veteran trees to avoid rood damage (known as the root protection area)
10. P68, Policy NEIO: Criteria for Development in the Countryside - Does not prejudice viable agricultural operations or other viable uses
11. P80, Para 4.91: There are serious concerns about the impact of flooding, both in respect of current properties at risk but also the long-term management of the area.
12. 4.92: any development in the plan area must therefore have regard to flood and erosion risk.
13. 4.94: built development can lead to increased surface water run-off; therefore, new development should include SuDS to help cope with intense rainfall events
14. P81, Para 4.96: Environment Agency consent is required for any works within 16 m of tidal waters and 8m of fluvial watercourses in line with the Environmental Permitting Regulations 2016. This strip is required for access. The policy includes a setback requirement to ensure this access strip is not obstructed.
15. P80, 4.92, Any development in the plan area must therefore have regard to flood and erosion risk, now and in the future, by way of location and specific measures, such as additional flood alleviation, which will protect people, properties and vulnerable habitats from flooding. Recent changes to national guidance highlight the importance of considering flood risk from all sources, and this is particularly significant for the plan area as large parts of it are at risk from groundwater flooding, which needs to be recognised in development decisions alongside the well-established risks in relation to tidal, fluvial and surface water flooding. Appropriate mapping of all sources of flood risks is still evolving, and is likely to develop further over the plan period
16. P93, Policy NE20 Pollution: Development proposals must be designed to protect, and where possible, improve upon the amenities of existing and future residents, occupiers of buildings and the environment generally. Development proposals will need to address the criteria contained in, but not limited to, the policies concerning water quality; flood risk and water management; nutrient mitigation; lighting; air quality; noise; and contaminated land. Where development is likely to generate significant adverse impacts by reason of pollution, the council will require that the impacts are minimised and/or mitigated to an acceptable level within appropriate local/national standards, guidance, legislation and/or objectives.
17, P94, 4.127, Light pollution caused by excessive brightness can lead to annoyance, disturbance and impact wildlife, notably nocturnal animals. The design of lighting schemes should be carefully considered in development proposals to prevent light spillage and glare.
18. P94, 4.128, Dark skies are important for the conservation of natural habitats, cultural heritage and astronomy. The plan area includes three 'Dark Sky Discovery Site' designations, all located within the Chichester Harbour AONB; Eames Farm on Thorney Island, Maybush Copse in Chidham; and north of the John Q Davis footpath in West Itchenor. Development within or directly impacting these areas will be subject to particular scrutiny in terms of their impact on dark skies. The entire SDNPA area is also declared as an International Dark Sky Reserve. Development directly impacting this area will be subject to similar scrutiny.
19. P96, Policy NE22 Air Quality
20. P97, Policy NE-23 Noise
21. P142, Para 6.29, Amenity: Private space, shared space and the design quality and construction of communal spaces all contribute to amenity
22. P155-6, Policy P11:Conservation Areas "protecting the setting (including views into and out of the area)"
23, P55, Para 4.26 - The council is under a legal duty to protect designated habitats, by ensuring that new development does not have an adverse impact on important areas of nature conservation, and by requiring mitigation to negate the harm caused.
24. P58, Para 4.33 The council is under a legal duty to protect their designated bird populations and supporting habitats
25. P95, Para 4.129 The council has a duty to review and assess air quality within the district
26. P301, Conservation Area: An area of special architectural or historic interest, designated under the Planning (Listed Buildings & Conservation Areas) Act 1990. There is a statutory duty to preserve or enhance the character, appearance, or setting of these areas.

The 'monitor and manage' strategy needs to be removed and become 'predict and provide' the emphasis being on the 'provide' being secured, which would assist in easing the predicted road congestion issues.

A railway station needs to be developed and built for the Tangmere area to improve easy access to rail travel for the increased population and this encourage alternative travel used.

To reduce the massive number of proposed new housing units to be built in and around the Tangmere area where there are already severe known traffic congestion issues, particularly at junctions and roundabouts that feed in and out and around Chichester and its surrounding.

See representation

The 'monitor and manage' strategy needs to be removed and become 'predict and provide' the emphasis being on the 'provide' being secured, which would assist in easing the predicted road congestion issues.
A railway station needs to be developed and built for the Tangmere area to improve easy access to rail travel for the increased population and this encourage alternative travel usage.

To reduce the massive number of proposed new housing units to be built in and around the Tangmere area where there are already severe known traffic congestion issues, particularly at junctions and roundabouts that feed in and out and around Chichester and its surrounds.

See representation

The plan needs to set out ways and means to reduce motorised traffic that are achievable and realistic. The walking and cycling projects need to be properly funded and achievable.

The Sixth Carbon Budget published by the Committee on Climate Change envisages that a reduction in traffic will be needed. This plan fails to put any suggestions forward to reduce traffic. https://www.theccc.org.uk/wp-content/uploads/2020/12/The-Sixth-Carbon-Budget-The-UKs-path-to-Net-Zero.pdf
We need to reduce total car miles by 2050 by 17% and I do not believe this plan has the detail and methods to effectively decarbonise surface transport enough. Due to lack of Compulsory purchase orders, lack of funds, landownership issues some of the vital routes needed for residents to travel sustainably won't be delivered in the plan period.

WGPC supports this approach but questions how it could be applied to Wisborough Green. This policy is Chichester-centric; Wisborough Green residents have no option other than to rely upon private cars.

WGPC supports this approach but questions how it could be applied to Wisborough Green, a village that relies upon private cars.

See my comments on paragraph 8.12 above

The objection relates to Criterion 7 in respect of which the same comments apply as for para 8.12 above

Support

We recommend that the BLD at Southbourne be CIL-exempt to catalyse the delivery of the infrastructure associated with the scheme and avoid the village’s infrastructure funding being stagnated within a larger and district-wide funding mechanism.

We acknowledge the emerging plan’s shift away from ‘predict and provide’ approach to recommending mitigation based on forecast growth, to an approach of ‘monitor and manage’, based on identifying a package of potential highway improvements which alongside schemes identified through the development management process, may be implemented following a monitoring process that will monitor the actual demand on the network and the requirement for the schemes.

We consider that a shift instead towards ‘vision and validate’ would be more aspirational for the plan. This approach will allow our Consortium to best envisage the place that Chichester District wants to create at Southbourne, and to target sustainable transport measures, alongside a carefully planned new community, that minimises travel needs and provides genuine sustainable options for movement. Such an approach needs to reimagine the hierarchy of transport users, prioritising pedestrians first, followed by cyclists, public transport, specialist service vehicles and finally other motor traffic. The scheme should prioritise support and encouragement for sustainable travel in line with this new hierarchy whilst now linking transport intrinsically with masterplanning, carbon reduction, air quality, health and lifestyle and biodiversity, instead of seeing it as a standalone consideration. We would therefore recommend Chichester District encourage ambitious developers to explore the ‘vision and validate’ approach within draft Policy T1

The land east of Southbourne will deliver a comprehensive development that also secures benefits for the existing community, including:

Delivery of a significant portion of the Green Ring, in both a central location and also an enhanced, longer walking route around the edge of the allocation. This has the benefit of creating a meaningful gap between settlements that is focused on the delivery of environmental enhancements and a wildlife corridor, whilst also offering alternative longer route for walking/recreation, reducing pressure on the Chichester Harbour SPA.
A connected integrated community that delivers sustainable transport improvements and alternatives for the whole of Southbourne.
A focus on connectivity through the green ring and connecting green corridors that focus movement on walking and cycling, rather than vehicular travel.
A central community hub that can deliver a new 2FE primary school, a community building, small scale retail and an enterprise hub to support homeworking, shared office space and start-ups.

With regards to the proposed S106 contribution per dwelling of £7,728 to act as A27 mitigation, we are concerned that this is not justified (see attached note from i-Transport). Furthermore, the imposition of CIL on the scheme at Southbourne would reduce the level of control over the above package of infrastructure improvements and sustainable movement provision associated with the development. With a contribution made to Chichester District in place of direct involvement of the consortium in the improvements to the village infrastructure, there is a risk that the enhancements that form a key element of the proposal may be delayed or fail to be delivered in a timescale that would best benefit the residents of the village.

Considering the above, we recommend that the BLD at Southbourne be CIL-exempt to catalyse the delivery of the infrastructure associated with the scheme and avoid the village’s infrastructure funding being stagnated within a larger and district-wide funding mechanism.

In regards to Policy T1 and Transport Infrastructure, we support efforts to secure ‘the timely delivery of transport infrastructure on the A27 and elsewhere on the network, needed to support new housing, employment and other development identified in this plan’.

In respect of contributions towards the A27, Miller and Vistry support the confirmation in the table beneath paragraph 8.20 that the contribution to be sought from the West of Chichester development towards A27 improvements will be £1,803 per dwelling.

Reference in the policy to “including applicants” should be removed. In the alternative, point 4 should be separated out as a council only policy.

Please refer to submitted representations document.

Relying on developers contributions to resolve the issues of over capacity on the A27 is totally inadequate..It will not help local traffic and through traffic will suffer further delays of a much long duration.
There needs to be substantial investment from Highways England to provide more capacity and reduce the accidents occurring on this road.

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 .

It is therefore suggested that Policy E4 of the local plan allows for development associated with the horticultural industry to come forward within HDA designations in order to comply with the objectives of Policy T1 of the Local Plan and in the interests of minimising congestion and vehicular movements.

Conflict with restrictions of policy E4 and associated text.

The Council’s desire to ensure that new development is well located and designed to avoid and minimise the need for travel is supported as stated within Policy T1. Minimising transport movements on the A27 corridor is particularly critical given the acknowledged constraints of the corridor (ref. policy T1)

This is in direct conflict with the wording of policy E4 of the Local Plan which allows for horticultural development and ancillary development only. This policy wording would seek to require associated development, such as office space and storage and distribution uses, to be located within settlement boundary areas or other established employment sites. The siting of associated functions within these locations would increase the number of vehicular journeys associated with the industry.

It is therefore suggested that Policy E4 of the local plan allows for development associated with the horticultural industry to come forward within HDA designations in order to comply with the objectives of Policy T1 of the Local Plan and in the interests of minimising congestion.

Chichester District Council's Regulation 19 Local Plan Policy T1 Transport Infrastructure should account for the cross boundary mitigation contributions and remove the uncertainty over how cross boundary contributions towards schemes such as Bognor Road and Whyke road roundabouts will be pooled to other A27 mitigation solutions, such that there are no averse implications for delivering committed developments in Arun (e.g. West of Bersted, Pagham North and South). The policy or supporting text (e.g. paragraph 8.11) should also clarify whether any additional housing achieved via the monitor and manage approach above 575 dwellings per annum will safeguard against potential adverse cross boundary implications (e.g. on the A259 at Oystercatcher and Comet corner junctions in Arun) and how necessary mitigations would be phased/triggered with additional housing.

Arun District Council (ADC) is concerned that the proposed Policy T1 Transport Infrastructure is not effective or justified. Subject to ongoing Duty to Cooperate discussions with Chichester District Council (CDC), ADC hopes to resolve these matters with a view to securing a Statement of Common Ground and subsequent withdrawal of these objections before the plan is submitted:-

- The infrastructure constrained approach delivering only the two scheme improvements on the A27 at Fishbourne and Bognor roundabouts (delivering reduced housing numbers), and the potential cross boundary impact with additional mitigation scheme costs and uplift from ADC planned and committed development (e.g. West of Bersted) - uncertainty over ADC developments (i.e. West of Bersted, Pagham North and South) and their contributions towards A27 mitigation improvements e.g. A27 Whyke Road Roundabout;
- The strategy is silent about cross boundary future growth assumptions (e.g. Arun) that may assist with A27 capacity. This may cap A27 capacity and ADC's future plan making and developments unviable because of the need for additional improvements;
- A259 safety schemes in Arun at Comet Corner and Oystercatcher are accommodated in Chichester's infrastructure constrained development str5ategy approach up to 2039 without significant adverse impact and need for cross boundary mitigation. However, Arun would also wish to see this demonstrated for any additional development scale above the infrastructure constrained approach (575 dwelling per annum) to Chichester's full housing requirement over the plan period to 2039 and whether any cross boundary mitigation provision would be needed within this policy.

Hunston Parish Council is concerned as to whether the traffic management proposals are workable.
Hunston Parish Council notes that the reality of climate change and the impact on the area are not adequately addressed.
Hunston Parish Council is concerned that the housing standards for any new build do not meet PassivHaus standards or equivalent. There is no mention of solar panels for example.

The proposed per dwelling contribution to improvements to the A27 infrastructure has not been properly justified when the responsibility for trunk road infrastructure rests with National Highways. The policy requires further testing at the forthcoming Examination.

The ‘tests of soundness’ for Local Plan preparation are set out in paragraph 35 of the July 2021 NPPF. They require the 2021-39 Local Plan to have been:

• Positively prepared – providing a strategy which, as a 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;

• Justified – an appropriate strategy, taking into account the reasonable alternatives, and based on proportionate evidence;

• Effective – deliverable over the plan period, and based on effective joint working on cross-boundary strategic matters that have been dealt with rather than deferred, as evidenced by the statement of common ground; and

• Consistent with national policy – enabling the delivery of sustainable development in accordance with the policies in this Framework.

Local Plan reviews are a legal requirement every 5 years in accordance with Regulation 10A of the 2012 Town and Country Planning (Local Planning) (England) Regulations. The Regulation 19 Plan is not legally compliant as it has not been reviewed within 5 years of the last Plan adopted in July 2015. It is also disappointing that the failure of the current Regulation 19 Local Plan to meet objectively assessed need (OAN) of 638 dpa outside the national park has not been properly evidenced in any up to date statement of common ground with neighbouring authorities with regards to the ‘duty to cooperate’.

At this stage we believe the Plan as drafted therefore fails the positively prepared, effective, and consistent with national planning policy tests.

Duty to Cooperate

The 2014-2029 Local Plan adopted in 2015 does not meet the full objectively assessed housing needs for the area. But it did recognise that future proposals to improve the capacity of the A27 and wastewater treatment works could facilitate additional housing growth. For this reason, it committed the Council to a review of the Plan within five years to ensure that housing needs could be met. That undertaking to review within 5 years was not met.

In 2021 the Council invited an advisory visit from PINS to advise on how the present Local Plan should be prepared. The inspector advised that if the Plan was prepared which did not meet the full housing needs of the area, it would have to show that it had followed the duty to co-operate with neighbouring authorities in maximising the effectiveness of plan preparation.

The inspector said the Duty to Cooperate was therefore critical in the preparation of the Local Plan Review. At the time of the meeting, the council said discussions with neighbouring authorities had been carried out on the basis that the Local Plan Review would meet the full objectively assessed housing needs (OAN) for the area. However if this was not the case, the inspector said evidence of constructive, active, and on-going engagement to determine whether or not development needs could be met elsewhere would need to be shown. Importantly, the inspector said,1) ‘a failure to meet the Duty to Cooperate cannot be remedied during the examination process because it applies to the preparation of the Plan, which ends upon submission’, and 2) local planning authorities should make every effort to secure the necessary cooperation on strategic cross boundary matters before submitting plans for examination.

The Duty to Cooperate Statement of Compliance (January 2023) forms part of the evidence base for the Submission Local Plan. In the event, the Local Plan excluding the national park only provides for 575 dpa against an OAN of 638 dpa. However this under provision against need has not been justified anywhere in discussions with neighbouring authorities before the Plan was submitted. Appendix 1 of the Statement of Compliance lists those authorities that were consulted during the earlier Regulation 18 Preferred Approach consultation. Appendix 2 lists those authorities where Statements of Common Ground have been agreed with Chichester DC for the Regulation Submission 19 Plan. No statements have produced or agreed. Therefore as it stands the under provision of housing against OAN in the Plan has not been justified. The failure to meet the duty to cooperate cannot be remedied because it has already ended with the Submission Plan. The plan therefore fails the positively prepared and justified tests. It also fails to comply with national policy in the NPPF paragraph 24-27 which advises on the duty to cooperate approach.

Local Plan Policies

The remainder of these comments deal with the proposed Settlement Hierarchy - policy S2, policy H1 – Meeting Housing Need, Non-Strategic Housing Sites – Policy H3 and T1 Transport Infrastructure.

Policy S2 – Settlement Hierarchy
The Settlement Hierarchy background paper prepared for the Regulation 18 draft Local Plan provides the justification for the hierarchy in Policy S2 of the Regulation 19 Local Plan. We agree that Plaistow & Ifold has been properly identified as a service village in the settlement hierarchy.

Policy H1 – Meeting Housing Needs
The identified housing need has been informed by the 2022 Housing and Economic Development Needs Assessment (HEDNA). It explains that based on the standard methodology, since the last HEDNA in 2020, the district wide housing need has increased from 746 dpa to 763 dpa (621 dpa in the Plan Area to 638 dpa) with the balance to be found in the national park. The proposed 638 dpa for the area of the district outside the national park is the figure that will be tested at the forthcoming Examination.
We have already explained why the failure of the Council to plan for the 638 dpa in the Regulation 19 Local Plan has not been justified in connection with the duty to cooperate and no evidence has been presented in any statement of common ground with neighbouring authorities to show how development needs could be met elsewhere.
We note from policy H1 that the components of housing supply include outstanding housing commitments without planning permission from the 2015 adopted Local Plan, the Site Allocations DPD, and ‘made’ Neighbourhood Pans.
However, it is unclear how the above housing supply components have been calculated and how they have translated into the strategic and non-strategic allocations in policies H2 and H3.
In the case of Plaistow and Ifold, the last adopted 2015 Local Plan identified the settlement with an allocation of 10 dwellings. The subsequent Site Allocation DPD identified land north of Little Springfield Farm for 10 no. units. A Neighbourhood Plan for Plaistow and Ifold was produced but was withdrawn and no site allocations were confirmed. The allocated site north of Little Springfield Farm remains undeveloped.
With specific reference to Plaistow & Ifold we would therefore query whether 1) the existing housing commitments without planning permission in the 2015 Local Plan and the Site Allocations DPD have been double counted, and 2) whether the non-implementation of the 10 units from the 2015 Local Plan have been ring fenced to count against the new proposed allocation of 25 dwellings at the settlement? In which case, we would question why a further 15 dwellings are only proposed at a service village in the hierarchy compared to other service villages in the NE part of the district which are proposed for higher levels of development (Loxwood 220 dwellings, Kirdford 50 dwellings and Wisborough Green 75 dwellings).
If the 25 dwelling allocation at Plaistow & Ifold is intended to be additional to the 10 units identified in the last 2015 Local Plan, then the allocation should be increased to 35 dwellings as a minimum to reflect the non-implementation of the 2015 allocation.
Policy H3 – Non-Strategic Parish Allocations
Policy H3 identifies non-strategic parish allocations. We have explained above our queries with the 25 dwelling allocation to Plaistow & Ifold, whether it has allowed for the non-implementation of the 10 units in the last 2015 Plan and why it compares so unfavourably with much higher levels of development for the other service villages in the NE part of the district.
We would also query why the options outlined in the PINS advisory visit of 2021 have not been more thoroughly tested for increased housing provision in the north part of the district to increase the supply of housing to meet OAN. There is no updated Settlement Hierarchy background paper, and the revised housing distribution has not been justified anywhere in the evidence base for the Regulation 19 Local Plan.

Policy T1 – Transport Infrastructure
The policy objectives to ensure new development is well located and designed to avoid or minimise the need for travel and encourage the use of sustainable modes of travel as an alternative to the private car are supported. However, the proposed contribution of £7.7k per dwelling towards A27 highway improvements applies to new housing across the district even in the NE part of the district where impacts from development on the A27 will be less than developments in the south of the district.
In any event it is unclear how the contributions are justified when the responsibility for trunk road infrastructure improvements rests with National Highways.
The proposed contribution in T1 is therefore questioned and in our view, flawed. The level of contribution set out in the policy and the principle of a contribution will therefore require further testing at the forthcoming Examination.

Request further technical work is undertaken to develop schemes and measures in sustainable transport package prior to the examination. Focus on:
1. St. Paul’s & Parklands cycle routes
2. Improving existing public transport services towards Madgwick Lane
3. Provision of improved bus services for village serving development areas of Southbourne Parish
4. Improving cycling connectivity to link built-out areas of Shopwhyke Lakes with Tangmere and Oving etc

As not all severely impacted A27 junctions have a reasonable prospect of being physically improved in Plan period, more investigation into potential public transport enhancements also required, particularly to strengthen routes that cross bypass. May require further amendments to the IDP.

Work should aim to identify options for sustainable transport schemes that can be a priority for investment, provide information to enable safeguarding of routes (e.g. cycle routes) from development and provide a basis for applications for third party funding to support their delivery. The relative priority of such measures would need to be considered under the monitor and manage approach by the proposed Traffic and Infrastructure Management Group for implementation in addition to the proposed improvement at the A27/A259 Fishbourne junction.

To address this issue and support delivery of the sustainable transport package, the County Council also recommends the following minor amendments to Policy T1: Transport Infrastructure:

At bullet point .7 change “other small-scale junction improvements” to read “other sustainable transport and safety focused improvements, including at junctions” and change “These will increase road capacity, reduce traffic congestion, improve safety and air quality, and improve access to Chichester city from surrounding areas” to “These will increase road capacity on strategic roads, and on both strategic and local roads reduce traffic congestion, improve safety and air quality, and improve access to Chichester city from surrounding areas notably by encouraging and prioritising sustainable modes.”

The comments included below from WSCC are Holding Objections. We will continue to work with Chichester District Council and as further work is completed will consider if objections can be withdrawn.

Transport Overview
The County Council has worked with Chichester District Council to develop the Chichester Local Plan and its supporting evidence base and will continue to do so. Although the overall direction of the Local Plan is supported, from a highways and transport perspective, there are three key issues remaining that need to be addressed in order to demonstrate that the Plan is sound:

1. There is insufficient evidence to demonstrate that key infrastructure (i.e. Terminus Road Diversion) will be deliverable;
2. The package of sustainable transport infrastructure and measures is not yet sufficiently well-developed to demonstrate that it is deliverable as part of the monitor and manage process; and
3. There is insufficient evidence to demonstrate that the capacity of the transport network can accommodate the scale of development proposed as part of the Southbourne Broad Location for Development.
The following sections explain; a) the reasons for these issues; b) why they affect the soundness of the Local Plan; and, c) what changes should be made to the Local Plan to remedy the issues.

Deliverability of Key Infrastructure

The recommended transport mitigation strategy, as assessed using the Chichester Area Transport Model for 2039 has been demonstrated to be capable in-principle to prevent the development from resulting in severe residual cumulative impacts on the highways and transport network. However, there are significant risks to deliverability of junction mitigation measures, which have required further work to be undertaken on developing a short to medium term strategy based on phased prioritisation of infrastructure and sustainable transport improvements, to be governed under a monitor and manage approach.

There are three locations where new highway alignments are proposed outside of existing highways boundaries. Two of these may include significant earthworks or structures to be delivered, being Stockbridge Link Road and Terminus Road diversion. The cost of the mitigation strategy exceeds the likely value of developer contributions and additional funding has not yet been secured.

At the Regulation 18 consultation stage in December 2018 to January 2019 the County Council identified delivery risks with the Stockbridge Link Road and Terminus Road Diversion schemes due to the earthworks likely to be required and to confirm the extent of land take required for both schemes. The County Council stated that feasibility work would need to be undertaken for these improvements prior to Plan submission to confirm that the schemes are deliverable. A brief for such a feasibility study was agreed in 2019, but to date, this work has not been commissioned. It is the County Council’s view that Stockbridge Link Road (SLR) should be disregarded as a potential part of a long-term transport mitigation strategy for 2039 and beyond until such time as it can be demonstrated that the scheme is deliverable. Paragraph 8.14 of the Local Plan acknowledges that the SLR is not deliverable as part of the Local Plan mitigation package.

The Terminus Road Diversion is still identified as part of the highest priority in the Local Plan mitigation package (i.e. A27 Fishbourne Junction) which is expected to be delivered once sufficient funding is collected. The County Council considers that in the absence of this feasibility work, the deliverability of the Terminus Road Diversion cannot be confirmed. In particular, given the recent impacts of inflation in the construction industry, this work will need to robustly estimate the costs and confirm delivery arrangements. In the absence of this feasibility work, there is currently insufficient evidence to confirm that the Local Plan complies with Paragraphs 11 and 106 of the NPPF as key infrastructure does not appear to be deliverable.

In order to remedy this issue regarding the Terminus Road Diversion, the County Council requests that feasibility work is undertaken prior to the examination to confirm deliverability of the proposed Terminus Road Diversion.

Sustainable Transport Infrastructure & Measures

The transport study modelling for end of Plan period also includes some proposed highways mitigation schemes within Chichester City. The County Council has previously requested that these be replaced by sustainable transport improvements to comply with the West Sussex Transport Plan 2022-2036. However, only limited modification has been made to these proposed schemes, with a suggestion in text at paragraph 7.3.2 of the main transport study that the costs for these schemes can be reallocated to sustainable transport improvements which are not specified. Although this does help to explain how sustainable transport infrastructure schemes and measures can be at least partially funded, it is rare that schemes will be fully funded using developer contributions. Furthermore, funding is not the only issue that needs to be overcome to secure delivery of these schemes and measures.

The Infrastructure Delivery Plan (IDP) lists the proposed mitigation measures and in some cases provides information on the rationale, phasing, cost, funding and delivery arrangements. However, there are still many gaps in the information, probably because schemes are currently at an early conceptual stage. The County Council’s experience is that it is unlikely that schemes will be fully funded using developer contributions (because doing so would not be compliant with the CIL regulations) so delivery of these schemes will be partially dependent on securing funding from central Government or other sources. The IDP currently fails to identify the scheme-specific requirements for additional funding and the overall scale of additional funding required.

The County Council considers the level of information currently available on the sustainable transport package to be insufficient to demonstrate deliverability of a credible and coordinated sustainable transport package of improved infrastructure and services. Therefore, there is insufficient evidence to confirm that the Local Plan complies with Paragraphs 11 and 106 of the NPPF.

In order to remedy this issue, the County Council requests that further technical work is undertaken to develop the schemes and measures in the sustainable transport package prior to the examination. In particular, this should focus on the following schemes and measures and some cases, this will build on work that has already taken place:
1. St. Paul’s & Parklands cycle routes
2. Improving existing public transport services towards Madgwick Lane
3. Provision of improved bus services for the village serving the development areas of Southbourne Parish
4. Improving cycling connectivity to link the built-out areas of Shopwhyke Lakes with Tangmere and Oving etc

As not all the severely impacted A27 junctions have a reasonable prospect of being physically improved in the Plan period, more investigation into potential public transport enhancements is also required, particularly to strengthen routes that cross the bypass. This may require further amendments to the IDP.

This work should aim to identify options for sustainable transport schemes that can be a priority for investment, provide information to enable safeguarding of routes (e.g. cycle routes) from development and provide a basis for applications for third party funding to support their delivery. The relative priority of such measures would need to be considered under the monitor and manage approach by the proposed Traffic and Infrastructure Management Group for implementation in addition to the proposed improvement at the A27/A259 Fishbourne junction.

To address this issue and support delivery of the sustainable transport package, the County Council also recommends the following minor amendments to Policy T1: Transport Infrastructure:

At bullet point .7 change “other small-scale junction improvements” to read “other sustainable transport and safety focused improvements, including at junctions” and change “These will increase road capacity, reduce traffic congestion, improve safety and air quality, and improve access to Chichester city from surrounding areas” to “These will increase road capacity on strategic roads, and on both strategic and local roads reduce traffic congestion, improve safety and air quality, and improve access to Chichester city from surrounding areas notably by encouraging and prioritising sustainable modes.”

Southbourne Broad Location for Development

The scale of development that can be accommodated at the Southbourne Broad Location will be, at least partially, dependent on the capacity of the transport network to accommodate the associated traffic movements. As the Broad Location spans the railway line, many of these traffic movements would need to cross the railway line. The County Council is concerned that there is currently insufficient capacity of the existing level crossings, notably at Stein Road, to accommodate the additional traffic movements. This could mean that the cumulative impact of development on the traffic network is severe, which is not consistent with Paragraph 111 of the NPPF.

The transport evidence base does not yet provide sufficient assurance that the proposed scale of development can be accommodated. This is because the base level of traffic flow has not been compared to local traffic counts, either in the initial validation of the strategic model or through a new count which the County Council has previously requested, and the assumptions about level crossing downtimes have not been validated against observed data. The County Council is concerned that the assessment of capacity of the local road network to accommodate the quantum of dwellings proposed for the Broad Location may be overoptimistic by underestimating existing flow levels and the duration of level crossing downtime. As a consequence, the proposed quantum may not be deliverable without unacceptable impacts to the conditions on Stein Road and to the level of traffic seeking to use rural lanes to the north of the village to avoid the level crossing.

In order to remedy this issue, the County Council requests that either additional transport evidence is provided prior to the examination to demonstrate that the proposed scale of development is deliverable, or that Policy A13 is changed to remove the proposed scale of development until such evidence is provided.

The following comments from education, minerals and waste, Adults Services and Health, highways & transport and public rights of way, do not affect the soundness of the Plan. However, Chichester District Council should take these into account and, where possible, make minor amendments to the Local Plan and/or evidence base studies before submission of the Local Plan for examination. Officers are happy to meet and discuss any of these comments, and proposed minor amendments to address these comments, ahead of submission:

1) Education

Land West of Chichester

Previous comments have been made requesting that the policy refers to ‘Phase 2 should include expansion of the primary school for the further 1FE of teaching accommodation with nursery and SEND provision’. While it is recognised that reference is made to this in the IDP this is a supporting document to the Local Plan and should not be solely relied on. It is requested that paragraph 10.19 is amended to read: ‘a local centre with retail, community and employment uses (minimum of approximately 2500 sqm E(g)(i) Use Class), two form entry (2FE) primary school and one form entry (1FE) teaching accommodation with nursery and SEND, informal and formal open space (including a country park), allotments,…’

This should also be included in the 3rd bullet point of Policy A6 or the wording of the policy should be drafted to reflect more recent policy requirements i.e. Provide for infrastructure and community facilities in accordance with the most recent Infrastructure Delivery Plan.

There are some inconsistencies with the wording of the strategic policies, not every policy includes the criterion ‘Provide for infrastructure and community facilities in accordance with the most recent Infrastructure Delivery Plan.’ While this may be due to some policies being carried through from the adopted local plan it is inconsistent.

Policy A8 Land East of Chichester

As an education authority WSCC do not request 1FE schools in line with government guidance. As per our earlier comments and discussions we requested a 2 FE primary school for the site.

3rd bullet point of Policy A8 should be amended to read: ‘A neighbourhood centre incorporating local shops, a community centre, flexible space for employment/ small-scale leisure uses and a one-form (expandable to two-form) two form entry primary school with provision for early years/ childcare and special educational needs and disability…’

2) Minerals and Waste

The references to safeguarding minerals is inconsistent and it is suggested that the wording in the email sent to CDC (attached) in relation to Policy AL3 should be used in the policies for the other sites for consistency. Reference to safeguarding minerals and waste infrastructure should also be included in some other policies as previously indicated:

• Policy A2 – needs to include reference to safeguarding minerals and waste infrastructure.
• Policy A7 – needs to include reference to safeguarding waste infrastructure.
• Policy A15 (Loxwood) – needs to include reference to minerals safeguarding as within the clay MSA.
• Policy A21 – needs to include reference to minerals safeguarding.

Also, the reference to the safeguarding guidance needs to be checked to ensure that it is worded correctly as ‘Minerals and Waste Safeguarding Guidance’.

3) Older Person Housing

It is noted that the plan refers to older person housing as specialist housing. WSCC strategy supports the provision of ‘extra care housing’ while this might be similar development it enables younger people to access the accommodation for whatever medical reason i.e. MS, strokes rather than limiting it to a certain age group. Officers are happy to meet and discuss this further.

4) Highways and Transport

Public Transport Priority Infrastructure

The Public Transport section of the main transport study report starting at paragraph 6.2.7 requires revisiting. There is reference to “an expansion of the bus priority lane system within Chichester City Centre” which does not match the existing bus provision in the City which does not provide bus priority lanes on street. It does have restrictions on motor traffic in the adjoining parts of South Street and West Street which provide for bus and cycle only access in both directions of travel plus access for essential goods vehicle loading in the westbound direction only. In addition, the suggestion in the following paragraph for “a time-based system where certain routes are restricted to public transport only during specific times” is not evidenced or developed and as such considered unlikely to be practical and enforceable at most locations used by bus routes in the City. More developed proposals for additional bus priority, improvements to bus passenger facilities or testing of specific locations for bus-only access would be welcomed as part of developing a costed sustainable transport mitigation package.

Park and Ride

The discussion of possible park and ride facilities for the City at paragraphs 6.2.9 to 6.2.16 of the main transport study should also acknowledge. An important part of making park and ride well used by motorists is increasing the price of city centre parking to provide a financial incentive to take up significantly cheaper park and ride charges for parking and travel. However, if park and ride sites are not provided accessible to all major approach routes to the city, such a charging strategy would not be seen to be equitable, whereas only a single site is proposed in the District Council’s emerging parking strategy and the report acknowledges at 6.2.11 that “locations for potential park and ride sites are also deemed to be limited”. The bullet at 6.2.15 “Cost of schemes compared to benefit are likely to be initially lower than highway schemes” may have been incorrectly worded given that this is listed as an issue rather than a benefit. The text may have been intended to say that the ratio of benefit to cost for park and ride schemes may be lower than for conventional highway schemes?

A286 New Park Road / A286 St Pancras Road (Junction 7)
This junction scheme includes pedestrian crossing facilities which are welcomed and also includes a length of advisory cycle lane starting in the middle of the junction for cyclists remaining on St Pancras. However, the approach to the junction on St Pancras from Eastgate Square remains intimidating to cyclists, so further measures would need to be added to make the layout cycle-friendly or the cycle facility is likely to be of limited benefit. This could include decreasing traffic speeds. Until this is done the conclusion at 8.4.4 of the main transport study; “The mitigation scheme includes improvements for pedestrians and cyclists which will lead to increased use of active travel modes and reduce the need for physical mitigation here” is only supported for pedestrians, not for cyclists.

A259 Via Ravenna / A259 Cathedral Way Roundabout (Junction 8)
It is stated at 7.3.8 of the main transport study that “the mitigation may be required to avoid queuing back towards the A27, as well as for capacity issues”. In light of this potential safety issue for the previous junction on Cathedral Way and for the A27 Fishbourne junction, the proposal at 7.3.6 that the scheme delivery should be tied to the monitor and manage regime to see if and when it is required is accepted. This is different to the approach for other junctions in the City because of the potential safety issue. This monitoring approach would be likely to follow after the A259 Cathedral Way / Fishbourne Road East / Terminus Road (as diverted) (Junction 10) improvement, which is to be brought forward as an integral part of the A27 Fishbourne roundabout mitigation scheme, but may allow for increased eastbound flows on Cathedral Way.

A286 Northgate Gyratory
An additional mitigation scheme is proposed at paragraph 7.3.134 of the main transport study for the A286 Northgate Gyratory along its southern arm from Oaklands Way to Orchard Street. The proposal to add traffic signals is welcomed in concept as it can help to control traffic speeds making the junction more friendly for cyclists and pedestrians. However, the layout shown at figure 7-8 does not maximise the opportunity to improve convenience and safety for pedestrians by providing a priority link to reach the central island, which contains employment space and the fire station, nor to assist crossing the exit towards Orchard Street. The scheme would benefit from further development to prioritise active travel movements and should also be fitted with transponders for bus priority.

Fishbourne Road West / Appledram Lane South (Junction 11)
At paragraphs 7.4.1 to 7.4.2 of the main transport study, the junction of Fishbourne Road West / Appledram Lane South (Junction 11) is considered. The proposal to mitigate impacts at this junction through delivery of the Stockbridge Link Road scheme is not considered deliverable, so the approach at this location requires re-thinking. The County Council would not support measures to increase capacity for through traffic on Appledram Lane South, the approach should be to reduce severance and improve safety and comfort for active travel on Appledram Lane by reducing vehicle speeds and as far as possible volume. This should consider the needs of pedestrians and cyclists both for local access and for users of the Salterns Way leisure cycling route.

TEMPro Background Traffic Growth Comparisons
At section 10.2 of the main transport study a comparison is made of the TEMPro 7.2 growth rates used in the study for external traffic with new TEMPro 8.0 growth rates since released by the Department for Transport, which notes that the TEMPro 8.0 rates are significantly lower, if these rates were used then the level of transport impacts could be lower. Unfortunately, a number of highways authorities in the Transport for the South East (TfSE) area including the County Council and Hampshire County Council have concerns that the planning assumptions used in TEMPro v8 core growth scenario underestimate the numbers of additional households forecasted compared to targets in adopted Local Plans for delivering new dwellings. TfSE are currently raising these collective concerns with DfT with a view to obtaining an early update to TEMPro 8 planning assumptions. Although for the purposes of this study TEMPro is not applied to trips produced in Chichester District, from the County Council’s analysis TEMPRo v8 core underestimates the increase in households per year in Arun District by over 50% and in Horsham District by 30% when compared with adopted development plans. On this basis it may be useful to instead compare TEMPro 7.2 with TEMPro 8.0 high growth scenario.

North of District Spatial Scenarios Testing
For the Northern Spatial Scenarios Test provided as an appendix to the main transport study, this had not been updated for the final preferred spatial strategy or in light of the County Council’s previous comments on the March 2022 issue to the District Council. The spatial strategy now is similar but not identical to the Scenario 4: Significant Growth 1 option in the reported tests, totalling 370 dwellings across the four northern parishes, compared to 410 in the test. In both cases the largest allocation is at Loxwood; 220 dwellings were proposed in the Scenario 4 as compared to 200 in this test. Some other tests proposed higher numbers.
The testing in the northern part of the district had used the same trip generation rates per dwelling as in the South of the District, but the County Council considers that in practice private motor vehicle trip generation per dwelling is likely to be higher due to the rural nature of the area, including a lack of local facilities and shops within walking distance of development, a very low level of public transport services and lack of surfaced cycle routes.
The level of development proposed is not at the level capable of delivering transformative transport improvements to match the trip making patterns around Chichester and the A259 corridor to Bosham and Southbourne. This may be offset in part by the lower total amount of development compared to the tested scenario 4. Nonetheless, it would be helpful to adjust the scenario for the spatial strategy now proposed and to provide information on additional traffic movements per peak hour from these parishes using the A272 at junctions at Wisborough Green and reaching the A272/A29 junction at Billingshurst and the A272/A283 junction at the north of Petworth.

Neutral Month and Summer Month Comparison Technical Note
The Neutral Month and Summer Month Comparison Technical Note in the main transport study treats July as a neutral month rather than a summer month. Paragraph 1.3.1 states “The flows were analysed by looking at traffic data for August 2019 this being considered to represent summer traffic. This was compared against traffic data from the neutral months of June, July, September and October also from 2019.” The County Council does not accept this methodology as school summer holidays start part way through July and education traffic is also affected by the formal exam period, whilst there is typically a high level of seasonal leisure traffic including summer outdoor events in this month. It is acceptable to use August alone as the summer comparator month. However, July traffic should be removed from the neutral months analysis and should be substituted with May traffic data from the same year of 2019, provided that sufficient data is available from that month.

5) Public Rights of Way (PRoW)

It is a positive step to see PRoW acknowledged as valued by communities and as part of the area’s green infrastructure. Whilst Policy P14 (Green Infrastructure) states that development proposals should not be detrimental to the network of public rights of way and bridleways (please note bridleways are Public Rights of Way), a more proactively positive approach that seeks enhancements to the network as mitigation, would be welcomed. The improvement, upgrading of existing PRoW and creation of new PRoW where possible, to allow for a greater number of users to access the network would be beneficial. This is somewhat addressed in Policy T1 which refers only to routes identified in the Local Transport Plan, Local Cycling and Walking Infrastructure Plan (LCWIP) and the Infrastructure Delivery Plan. Opportunities to these, should not be limited if they arise elsewhere.
It is surprising to see there is no mention of PRoW within Chapter 8 under Active Travel – Walking and Cycling. The PRoW network provides extensive walking and cycling opportunities, often off-road, and important links between places and non-PRoW routes.

The comments included below from WSCC are Holding Objections. We will continue to work with Chichester District Council and as further work is completed will consider if objections can be withdrawn.

Transport Overview
The County Council has worked with Chichester District Council to develop the Chichester Local Plan and its supporting evidence base and will continue to do so. Although the overall direction of the Local Plan is supported, from a highways and transport perspective, there are three key issues remaining that need to be addressed in order to demonstrate that the Plan is sound:

1. There is insufficient evidence to demonstrate that key infrastructure (i.e. Terminus Road Diversion) will be deliverable;
2. The package of sustainable transport infrastructure and measures is not yet sufficiently well-developed to demonstrate that it is deliverable as part of the monitor and manage process; and
3. There is insufficient evidence to demonstrate that the capacity of the transport network can accommodate the scale of development proposed as part of the Southbourne Broad Location for Development.
The following sections explain; a) the reasons for these issues; b) why they affect the soundness of the Local Plan; and, c) what changes should be made to the Local Plan to remedy the issues.

Deliverability of Key Infrastructure

The recommended transport mitigation strategy, as assessed using the Chichester Area Transport Model for 2039 has been demonstrated to be capable in-principle to prevent the development from resulting in severe residual cumulative impacts on the highways and transport network. However, there are significant risks to deliverability of junction mitigation measures, which have required further work to be undertaken on developing a short to medium term strategy based on phased prioritisation of infrastructure and sustainable transport improvements, to be governed under a monitor and manage approach.

There are three locations where new highway alignments are proposed outside of existing highways boundaries. Two of these may include significant earthworks or structures to be delivered, being Stockbridge Link Road and Terminus Road diversion. The cost of the mitigation strategy exceeds the likely value of developer contributions and additional funding has not yet been secured.

At the Regulation 18 consultation stage in December 2018 to January 2019 the County Council identified delivery risks with the Stockbridge Link Road and Terminus Road Diversion schemes due to the earthworks likely to be required and to confirm the extent of land take required for both schemes. The County Council stated that feasibility work would need to be undertaken for these improvements prior to Plan submission to confirm that the schemes are deliverable. A brief for such a feasibility study was agreed in 2019, but to date, this work has not been commissioned. It is the County Council’s view that Stockbridge Link Road (SLR) should be disregarded as a potential part of a long-term transport mitigation strategy for 2039 and beyond until such time as it can be demonstrated that the scheme is deliverable. Paragraph 8.14 of the Local Plan acknowledges that the SLR is not deliverable as part of the Local Plan mitigation package.

The Terminus Road Diversion is still identified as part of the highest priority in the Local Plan mitigation package (i.e. A27 Fishbourne Junction) which is expected to be delivered once sufficient funding is collected. The County Council considers that in the absence of this feasibility work, the deliverability of the Terminus Road Diversion cannot be confirmed. In particular, given the recent impacts of inflation in the construction industry, this work will need to robustly estimate the costs and confirm delivery arrangements. In the absence of this feasibility work, there is currently insufficient evidence to confirm that the Local Plan complies with Paragraphs 11 and 106 of the NPPF as key infrastructure does not appear to be deliverable.

In order to remedy this issue regarding the Terminus Road Diversion, the County Council requests that feasibility work is undertaken prior to the examination to confirm deliverability of the proposed Terminus Road Diversion.

Sustainable Transport Infrastructure & Measures

The transport study modelling for end of Plan period also includes some proposed highways mitigation schemes within Chichester City. The County Council has previously requested that these be replaced by sustainable transport improvements to comply with the West Sussex Transport Plan 2022-2036. However, only limited modification has been made to these proposed schemes, with a suggestion in text at paragraph 7.3.2 of the main transport study that the costs for these schemes can be reallocated to sustainable transport improvements which are not specified. Although this does help to explain how sustainable transport infrastructure schemes and measures can be at least partially funded, it is rare that schemes will be fully funded using developer contributions. Furthermore, funding is not the only issue that needs to be overcome to secure delivery of these schemes and measures.

The Infrastructure Delivery Plan (IDP) lists the proposed mitigation measures and in some cases provides information on the rationale, phasing, cost, funding and delivery arrangements. However, there are still many gaps in the information, probably because schemes are currently at an early conceptual stage. The County Council’s experience is that it is unlikely that schemes will be fully funded using developer contributions (because doing so would not be compliant with the CIL regulations) so delivery of these schemes will be partially dependent on securing funding from central Government or other sources. The IDP currently fails to identify the scheme-specific requirements for additional funding and the overall scale of additional funding required.

The County Council considers the level of information currently available on the sustainable transport package to be insufficient to demonstrate deliverability of a credible and coordinated sustainable transport package of improved infrastructure and services. Therefore, there is insufficient evidence to confirm that the Local Plan complies with Paragraphs 11 and 106 of the NPPF.

In order to remedy this issue, the County Council requests that further technical work is undertaken to develop the schemes and measures in the sustainable transport package prior to the examination. In particular, this should focus on the following schemes and measures and some cases, this will build on work that has already taken place:
1. St. Paul’s & Parklands cycle routes
2. Improving existing public transport services towards Madgwick Lane
3. Provision of improved bus services for the village serving the development areas of Southbourne Parish
4. Improving cycling connectivity to link the built-out areas of Shopwhyke Lakes with Tangmere and Oving etc

As not all the severely impacted A27 junctions have a reasonable prospect of being physically improved in the Plan period, more investigation into potential public transport enhancements is also required, particularly to strengthen routes that cross the bypass. This may require further amendments to the IDP.

This work should aim to identify options for sustainable transport schemes that can be a priority for investment, provide information to enable safeguarding of routes (e.g. cycle routes) from development and provide a basis for applications for third party funding to support their delivery. The relative priority of such measures would need to be considered under the monitor and manage approach by the proposed Traffic and Infrastructure Management Group for implementation in addition to the proposed improvement at the A27/A259 Fishbourne junction.

To address this issue and support delivery of the sustainable transport package, the County Council also recommends the following minor amendments to Policy T1: Transport Infrastructure:

At bullet point .7 change “other small-scale junction improvements” to read “other sustainable transport and safety focused improvements, including at junctions” and change “These will increase road capacity, reduce traffic congestion, improve safety and air quality, and improve access to Chichester city from surrounding areas” to “These will increase road capacity on strategic roads, and on both strategic and local roads reduce traffic congestion, improve safety and air quality, and improve access to Chichester city from surrounding areas notably by encouraging and prioritising sustainable modes.”

Southbourne Broad Location for Development

The scale of development that can be accommodated at the Southbourne Broad Location will be, at least partially, dependent on the capacity of the transport network to accommodate the associated traffic movements. As the Broad Location spans the railway line, many of these traffic movements would need to cross the railway line. The County Council is concerned that there is currently insufficient capacity of the existing level crossings, notably at Stein Road, to accommodate the additional traffic movements. This could mean that the cumulative impact of development on the traffic network is severe, which is not consistent with Paragraph 111 of the NPPF.

The transport evidence base does not yet provide sufficient assurance that the proposed scale of development can be accommodated. This is because the base level of traffic flow has not been compared to local traffic counts, either in the initial validation of the strategic model or through a new count which the County Council has previously requested, and the assumptions about level crossing downtimes have not been validated against observed data. The County Council is concerned that the assessment of capacity of the local road network to accommodate the quantum of dwellings proposed for the Broad Location may be overoptimistic by underestimating existing flow levels and the duration of level crossing downtime. As a consequence, the proposed quantum may not be deliverable without unacceptable impacts to the conditions on Stein Road and to the level of traffic seeking to use rural lanes to the north of the village to avoid the level crossing.

In order to remedy this issue, the County Council requests that either additional transport evidence is provided prior to the examination to demonstrate that the proposed scale of development is deliverable, or that Policy A13 is changed to remove the proposed scale of development until such evidence is provided.

The following comments from education, minerals and waste, Adults Services and Health, highways & transport and public rights of way, do not affect the soundness of the Plan. However, Chichester District Council should take these into account and, where possible, make minor amendments to the Local Plan and/or evidence base studies before submission of the Local Plan for examination. Officers are happy to meet and discuss any of these comments, and proposed minor amendments to address these comments, ahead of submission:

1) Education

Land West of Chichester

Previous comments have been made requesting that the policy refers to ‘Phase 2 should include expansion of the primary school for the further 1FE of teaching accommodation with nursery and SEND provision’. While it is recognised that reference is made to this in the IDP this is a supporting document to the Local Plan and should not be solely relied on. It is requested that paragraph 10.19 is amended to read: ‘a local centre with retail, community and employment uses (minimum of approximately 2500 sqm E(g)(i) Use Class), two form entry (2FE) primary school and one form entry (1FE) teaching accommodation with nursery and SEND, informal and formal open space (including a country park), allotments,…’

This should also be included in the 3rd bullet point of Policy A6 or the wording of the policy should be drafted to reflect more recent policy requirements i.e. Provide for infrastructure and community facilities in accordance with the most recent Infrastructure Delivery Plan.

There are some inconsistencies with the wording of the strategic policies, not every policy includes the criterion ‘Provide for infrastructure and community facilities in accordance with the most recent Infrastructure Delivery Plan.’ While this may be due to some policies being carried through from the adopted local plan it is inconsistent.

Policy A8 Land East of Chichester

As an education authority WSCC do not request 1FE schools in line with government guidance. As per our earlier comments and discussions we requested a 2 FE primary school for the site.

3rd bullet point of Policy A8 should be amended to read: ‘A neighbourhood centre incorporating local shops, a community centre, flexible space for employment/ small-scale leisure uses and a one-form (expandable to two-form) two form entry primary school with provision for early years/ childcare and special educational needs and disability…’

2) Minerals and Waste

The references to safeguarding minerals is inconsistent and it is suggested that the wording in the email sent to CDC (attached) in relation to Policy AL3 should be used in the policies for the other sites for consistency. Reference to safeguarding minerals and waste infrastructure should also be included in some other policies as previously indicated:

• Policy A2 – needs to include reference to safeguarding minerals and waste infrastructure.
• Policy A7 – needs to include reference to safeguarding waste infrastructure.
• Policy A15 (Loxwood) – needs to include reference to minerals safeguarding as within the clay MSA.
• Policy A21 – needs to include reference to minerals safeguarding.

Also, the reference to the safeguarding guidance needs to be checked to ensure that it is worded correctly as ‘Minerals and Waste Safeguarding Guidance’.

3) Older Person Housing

It is noted that the plan refers to older person housing as specialist housing. WSCC strategy supports the provision of ‘extra care housing’ while this might be similar development it enables younger people to access the accommodation for whatever medical reason i.e. MS, strokes rather than limiting it to a certain age group. Officers are happy to meet and discuss this further.

4) Highways and Transport

Public Transport Priority Infrastructure

The Public Transport section of the main transport study report starting at paragraph 6.2.7 requires revisiting. There is reference to “an expansion of the bus priority lane system within Chichester City Centre” which does not match the existing bus provision in the City which does not provide bus priority lanes on street. It does have restrictions on motor traffic in the adjoining parts of South Street and West Street which provide for bus and cycle only access in both directions of travel plus access for essential goods vehicle loading in the westbound direction only. In addition, the suggestion in the following paragraph for “a time-based system where certain routes are restricted to public transport only during specific times” is not evidenced or developed and as such considered unlikely to be practical and enforceable at most locations used by bus routes in the City. More developed proposals for additional bus priority, improvements to bus passenger facilities or testing of specific locations for bus-only access would be welcomed as part of developing a costed sustainable transport mitigation package.

Park and Ride

The discussion of possible park and ride facilities for the City at paragraphs 6.2.9 to 6.2.16 of the main transport study should also acknowledge. An important part of making park and ride well used by motorists is increasing the price of city centre parking to provide a financial incentive to take up significantly cheaper park and ride charges for parking and travel. However, if park and ride sites are not provided accessible to all major approach routes to the city, such a charging strategy would not be seen to be equitable, whereas only a single site is proposed in the District Council’s emerging parking strategy and the report acknowledges at 6.2.11 that “locations for potential park and ride sites are also deemed to be limited”. The bullet at 6.2.15 “Cost of schemes compared to benefit are likely to be initially lower than highway schemes” may have been incorrectly worded given that this is listed as an issue rather than a benefit. The text may have been intended to say that the ratio of benefit to cost for park and ride schemes may be lower than for conventional highway schemes?

A286 New Park Road / A286 St Pancras Road (Junction 7)
This junction scheme includes pedestrian crossing facilities which are welcomed and also includes a length of advisory cycle lane starting in the middle of the junction for cyclists remaining on St Pancras. However, the approach to the junction on St Pancras from Eastgate Square remains intimidating to cyclists, so further measures would need to be added to make the layout cycle-friendly or the cycle facility is likely to be of limited benefit. This could include decreasing traffic speeds. Until this is done the conclusion at 8.4.4 of the main transport study; “The mitigation scheme includes improvements for pedestrians and cyclists which will lead to increased use of active travel modes and reduce the need for physical mitigation here” is only supported for pedestrians, not for cyclists.

A259 Via Ravenna / A259 Cathedral Way Roundabout (Junction 8)
It is stated at 7.3.8 of the main transport study that “the mitigation may be required to avoid queuing back towards the A27, as well as for capacity issues”. In light of this potential safety issue for the previous junction on Cathedral Way and for the A27 Fishbourne junction, the proposal at 7.3.6 that the scheme delivery should be tied to the monitor and manage regime to see if and when it is required is accepted. This is different to the approach for other junctions in the City because of the potential safety issue. This monitoring approach would be likely to follow after the A259 Cathedral Way / Fishbourne Road East / Terminus Road (as diverted) (Junction 10) improvement, which is to be brought forward as an integral part of the A27 Fishbourne roundabout mitigation scheme, but may allow for increased eastbound flows on Cathedral Way.

A286 Northgate Gyratory
An additional mitigation scheme is proposed at paragraph 7.3.134 of the main transport study for the A286 Northgate Gyratory along its southern arm from Oaklands Way to Orchard Street. The proposal to add traffic signals is welcomed in concept as it can help to control traffic speeds making the junction more friendly for cyclists and pedestrians. However, the layout shown at figure 7-8 does not maximise the opportunity to improve convenience and safety for pedestrians by providing a priority link to reach the central island, which contains employment space and the fire station, nor to assist crossing the exit towards Orchard Street. The scheme would benefit from further development to prioritise active travel movements and should also be fitted with transponders for bus priority.

Fishbourne Road West / Appledram Lane South (Junction 11)
At paragraphs 7.4.1 to 7.4.2 of the main transport study, the junction of Fishbourne Road West / Appledram Lane South (Junction 11) is considered. The proposal to mitigate impacts at this junction through delivery of the Stockbridge Link Road scheme is not considered deliverable, so the approach at this location requires re-thinking. The County Council would not support measures to increase capacity for through traffic on Appledram Lane South, the approach should be to reduce severance and improve safety and comfort for active travel on Appledram Lane by reducing vehicle speeds and as far as possible volume. This should consider the needs of pedestrians and cyclists both for local access and for users of the Salterns Way leisure cycling route.

TEMPro Background Traffic Growth Comparisons
At section 10.2 of the main transport study a comparison is made of the TEMPro 7.2 growth rates used in the study for external traffic with new TEMPro 8.0 growth rates since released by the Department for Transport, which notes that the TEMPro 8.0 rates are significantly lower, if these rates were used then the level of transport impacts could be lower. Unfortunately, a number of highways authorities in the Transport for the South East (TfSE) area including the County Council and Hampshire County Council have concerns that the planning assumptions used in TEMPro v8 core growth scenario underestimate the numbers of additional households forecasted compared to targets in adopted Local Plans for delivering new dwellings. TfSE are currently raising these collective concerns with DfT with a view to obtaining an early update to TEMPro 8 planning assumptions. Although for the purposes of this study TEMPro is not applied to trips produced in Chichester District, from the County Council’s analysis TEMPRo v8 core underestimates the increase in households per year in Arun District by over 50% and in Horsham District by 30% when compared with adopted development plans. On this basis it may be useful to instead compare TEMPro 7.2 with TEMPro 8.0 high growth scenario.

North of District Spatial Scenarios Testing
For the Northern Spatial Scenarios Test provided as an appendix to the main transport study, this had not been updated for the final preferred spatial strategy or in light of the County Council’s previous comments on the March 2022 issue to the District Council. The spatial strategy now is similar but not identical to the Scenario 4: Significant Growth 1 option in the reported tests, totalling 370 dwellings across the four northern parishes, compared to 410 in the test. In both cases the largest allocation is at Loxwood; 220 dwellings were proposed in the Scenario 4 as compared to 200 in this test. Some other tests proposed higher numbers.
The testing in the northern part of the district had used the same trip generation rates per dwelling as in the South of the District, but the County Council considers that in practice private motor vehicle trip generation per dwelling is likely to be higher due to the rural nature of the area, including a lack of local facilities and shops within walking distance of development, a very low level of public transport services and lack of surfaced cycle routes.
The level of development proposed is not at the level capable of delivering transformative transport improvements to match the trip making patterns around Chichester and the A259 corridor to Bosham and Southbourne. This may be offset in part by the lower total amount of development compared to the tested scenario 4. Nonetheless, it would be helpful to adjust the scenario for the spatial strategy now proposed and to provide information on additional traffic movements per peak hour from these parishes using the A272 at junctions at Wisborough Green and reaching the A272/A29 junction at Billingshurst and the A272/A283 junction at the north of Petworth.

Neutral Month and Summer Month Comparison Technical Note
The Neutral Month and Summer Month Comparison Technical Note in the main transport study treats July as a neutral month rather than a summer month. Paragraph 1.3.1 states “The flows were analysed by looking at traffic data for August 2019 this being considered to represent summer traffic. This was compared against traffic data from the neutral months of June, July, September and October also from 2019.” The County Council does not accept this methodology as school summer holidays start part way through July and education traffic is also affected by the formal exam period, whilst there is typically a high level of seasonal leisure traffic including summer outdoor events in this month. It is acceptable to use August alone as the summer comparator month. However, July traffic should be removed from the neutral months analysis and should be substituted with May traffic data from the same year of 2019, provided that sufficient data is available from that month.

5) Public Rights of Way (PRoW)

It is a positive step to see PRoW acknowledged as valued by communities and as part of the area’s green infrastructure. Whilst Policy P14 (Green Infrastructure) states that development proposals should not be detrimental to the network of public rights of way and bridleways (please note bridleways are Public Rights of Way), a more proactively positive approach that seeks enhancements to the network as mitigation, would be welcomed. The improvement, upgrading of existing PRoW and creation of new PRoW where possible, to allow for a greater number of users to access the network would be beneficial. This is somewhat addressed in Policy T1 which refers only to routes identified in the Local Transport Plan, Local Cycling and Walking Infrastructure Plan (LCWIP) and the Infrastructure Delivery Plan. Opportunities to these, should not be limited if they arise elsewhere.
It is surprising to see there is no mention of PRoW within Chapter 8 under Active Travel – Walking and Cycling. The PRoW network provides extensive walking and cycling opportunities, often off-road, and important links between places and non-PRoW routes.

The proposed per dwelling contribution to improvements to the A27 infrastructure has not been properly justified when the responsibility for trunk road infrastructure rests with National Highways. The policy should be deleted.

See attached representation.

Park and Ride; 20 mph limit in city centre; public transport hub at railway station

See attachment.