Policy S2: Settlement Hierarchy

For this hierarchy of centres to function for all users then there needs to be access by all sustainable meansot transport including a good cycling infrastructure,

In many places of the draft plan you rightly refer to various difficulties and issues but this policy does not acknowledge these difficulties. In particular the substantial traffic and other infrastructure issues in the Western Manhood Peninsula are already effecting Hunston, Birdham, Earnley, Bracklesham and the Witterings.
To set minimum house numbers is asking for wholesale developments. Even the minimums are way too many particulalry when added to the 400 plus new houses recently added or under construction

Policy S2.
This policy takes no account of practical numbers. The HELAA, your draft plan and this policy in particular takes no overall account of the inability of the Western Manhood Peninsula to support the scale of building proposed.
HELAA identifies over about 2,000 house building sites for the Western Manhood Peninsula. Is that sensible and practical? Further at the next round of Government "Requirements" could that stretch to 5,000 or more? The point is there must be a sensible maximum. The CDC have a duty of care to identify what that figure is.

Again not enough detail. Nice to have these ideas of schools etc but they are put in the plan and never built (ie Graylingwell) just to get the plan accepted. Great in theory but services have to be put in first otherwise more people have to travel to access schools , doctors etc. Forward planning has to be used and instigated to make communities work and cut unnecessary traffic journeys.again no inclusion of villages in the north around Goodwood.Biased plan

A review of the Settlement Boundaries for all sustainable villages should be undertaken, in order to provide more opportunities for windfall development. There is currently little scope for any windfall development to be delivered, and if it is the plans intention to use windfall to support housing numbers and housing delivery then more provision will need to be made as part of the plan review process.

I appreciate that the housing numbers proposed in the LPR have been imposed by central government, but for CDC to refer to the housing target numbers as minimums appears seriously flawed. This will surely encourage developers to submit plans for greater numbers than might otherwise be the case. It also makes it very difficult for local communities to resist further development when the "minimum" figure has been reached. The housing numbers imposed are already greater than the district can reasonably bear, so for CDC to set minimum targets is doing a great disservice on all counts, and particularly on environmental grounds.

Chichester district already suffers from insufficient road capacity and the plans for the A27 junctions and link road will not solve the problem. The junction changes will not solve the lack of road capacity for through and local traffic, and restricting right-hand turning at junctions will make local journeys more difficult. The proposed AL6 link road would direct more traffic off the A27 on to the A286, one of the most congested roads in the district, providing access to some of the most popular tourism destinations on the Manhood Peninsula. For this reason alone it should be resisted.

I am concerned that East Wittering/Bracklesham have been classed as a "settlement hub". The definition of a settlement hub should include good access to the main road network, the rail network, employment and secondary and higher education facilities. These villages do not have easy access to these services, being situated in a "cul-de-sac", on the congested A286. They are essentially rural, seaside communities which rely heavily on tourism for their economy and it is their rural nature which attracts so many visitors. The 350 minimum homes proposed for these two villages would have severe implications on all aspects of the local infrastructure, particularly the roads.

Living off Bell Lane in Somerley, I would like to draw your attention to the findings of the Peter Brett Transport Study for the LPR. It states that the forecast for the increase in road noise arising from a further 350 homes in East Wittering/Bracklesham along the length of Bracklesham Lane, the B2198, is "major". Bracklesham Lane leads into Bell Lane as it passes through the Somerley Conservation Area and it is vital that mitigation measures should be taken to reduce the effects of the additional traffic noise, preferably in the form of a speed limit reduction to 30mph. The accident rate on this road is already higher than average, including fatalities.

Selsey, another "settlement hub", has been badly affected by excessive suburban development in recent years with no improvement to its local infrastructure. The further extensive housing numbers proposed for this fishing and seaside village risk undermining its attraction to tourists. It is important that development of these seaside communities is carefully designed and limited in numbers to prevent over-suburbanisation. It should also be recognised that the geography of the peninsula means that access to and from the coast will always be restricted and subject to severe congestion. Additional housing on the Manhood Peninsula will only worsen this unresolvable situation and must be considered with caution to maintain its attractiveness to tourists who contribute so greatly to the economy of the Chichester district.

The Manhood Peninsula is also one of the last remaining rural hinterlands on the south coast plain. It contains several internationally designated habitat sites which are among the most important wildlife areas in the Chichester district. CDC should consider strengthening the ICZM to recognise the international importance of the peninsula, further safeguarding its environment and associated green tourism. The provision of wildlife corridors are probably more important here than anywhere else in the district. In addition, the AL6 proposed link road and commercial development would be adjacent to internationally designated habitat sites, cross two flood zones, and impair significant views of the cathedral and the Downs, contrary to CDC's ICZM policy. This proposed road appears to fail on all counts.

In conclusion, therefore, I would ask CDC to abandon proposals for the AL6 link road and junction changes on the A27, which are a waste of money, and instead urge the government to invest in a long-term, sustainable solution for the A27 so that the district is more able to accommodate the increased housing numbers being imposed on it. I would also like to see the minimum housing target numbers changed to maximum and remove East Wittering/Bracklesham as a settlement hub for the reasons set out above.

Policy S2: Settlement Heirarchy
Service Villages Plaistow / Ifold

The current CDC CLPKP defines Plaistow and Ifold villages as a combined 'Service Village', the definition is as follows:
"Service Villages (local centre for services providing for villages and parishes): Villages that either provide a reasonable range of basic facilities (e.g. primary school, convenience store and post office) to meet the everyday needs of local residents, or villages that provide fewer of these facilities but that have reasonable access to them in nearby settlements." (CLPKP)
The settlement of Ifold is defined by a Settlement Boundary.

In the Settlement of Ifold there is no shop, pub, school, medical facilities or recreational facilities to meet the everyday needs of local residents, other than a village hall and a Scout & Girl Guide Hut both run by and reliant on volunteers.

Plaistow village is outside a settlement boundary, and therefore in the countryside (or "Rest of Plan Area" as defined in the current CLPKP Policy 2 - Development and Settlement Hierarchy).

In Plaistow village there is a primary school; village shop; Church; pub; village hall with youth club (with its own multi-use outdoor games area) and preschool (with its own dedicated outdoor play area); weekly Royal Mail Post Office outreach service; village green; outdoor, fenced children's playground; cricket pitch with practice nets and pavilion; and a football field with pavilion.

The service village notation in the Local Plan CLPKP revolves around reasonable access to services and facilities. In the case of Ifold 'reasonable access' can only be achieved by the use of a car or taxi service, whereas for Plaistow, village services and facilities may be accessed by residents on foot. Within the Service Village notation all potential housing sites are therefore not equal in terms of access to facilities and services.

Out of all the villages in the North of the District area, Plaistow village does not have a Settlement Boundary, yet it is a village that has the most number of facilities and services. All other villages have sustained considerable levels of new housing development over the past 15-20 years yet Plaistow village has not absorbed any of that housing.

The planning consultancy AECOM, appointed by Locality a partner organization of the Ministry of Housing, Communities and Local Government (MHCLG), conducted a Site Options and Assessment (August 2016) of the proposed housing sites to be considered for inclusion in the Plaistow and Ifold Parish Neighbourhood Plan. Their study concluded that the CDC Site Allocations DPD site had a high probability of being considered less sustainable in terms of national planning policy at Examination, than the alternative sites in Plaistow, given that the Ifold settlement currently has no services and few facilities - following the closure of its village store.
In the AECOM report (dated August 2016), under conclusions and recommendations (page 25) the following comments are drawn to the attention of Chichester District Council planning department:
'Ifold is fundamentally a less sustainable location than Plaistow.'
'The NPPF...would not support any further residential development at Ifold due to the lack of services and facilities within walking distance.'
'It would be virtually impossible for any party, including for CDC, to argue that development at Ifold would be justified for as long as there is no shop, school or pub in the village but there is a range of suitable and available sites at nearby Plaistow.'
* Importantly, this conclusion should be used in the case against the current allocation of Site 4 (Land to the North of Little Springfield Farm by CDC in their current Site Allocations Development Plan Document (SA DPD).
* The second bullet point on page 26 of the AECOM Report (August 2016) sets out that:
"The approach to sustainable development in the English planning system as set out in the NPPF and reiterated in both Chichester's adopted Local Plan and in the Little Springfield Farm appeal decision means that Plaistow is effectively the only settlement in the Parish that could be considered suitable for new housing development."
Plaistow village should have a defined settlement boundary that takes into its conservation area and with consideration of the many other housing development sites brought forward by Plaistow landowners. They are sites that were not discounted by the Parish Council in its neighbourhood planning activities but not brought forward as the housing allocation in the previous Local Plan had been accounted for in a suitable site Land opposite the village green, Common House Road, Plaistow. Defining a settlement boundary in Plaistow would manage any housing development to be brought forward by those landowners.

Further evidence in support of this is set out as follows:
* Ifold is approximately 2.4km from the centre of Plaistow village, which has the most facilities and services: a school, shop, Church, hall, post office services, village green, children's playground, other recreational facilities and a pub;
* Facilities and services in Ifold are limited to a village hall and a Scout Girl Guide HQ (which rely on volunteers);
* There are no public open spaces or a children's playground in Ifold;
* Plaistow Road, Ifold is a 40 mph speed zone up to the boundary and then becomes a 60 mph speed zone up to Plaistow village. There are no pavements. pedestrian crossings or street lighting to permit safe pedestrian access to the limited Ifold facilities or the facilities in Plaistow.
* The Local Education Authority (West Sussex County Council) 'Home to School and College Transport Policy' applied walking distances are: 3.218688 kilometres (two miles) in relation to a child who is under the age of eight; and 4.828032 kilometres (three miles) in relation to a child who has attained the age of eight. However, in approximately 1997/1998 West Sussex County Council made arrangements for the provision of bus transport for Ifold school children to and from Plaistow and Kirdford Primary School. This is because the Plaistow Road route is regarded by the County Council as too hazardous for a child to walk. The County Council were going to withdraw the free service that had been provided for a number years or withdraw the service entirely as they were not required to provide a bus. The only grounds to have a free service retained was safety, which the Parish Council proved and the County Council agreed.

4.18 Service Villages:
The current CDC CLPKP defines Plaistow and Ifold villages as a combined 'Service Village', the definition is as follows:
"Service Villages (local centre for services providing for villages and parishes): Villages that either provide a reasonable range of basic facilities (e.g. primary school, convenience store and post office) to meet the everyday needs of local residents, or villages that provide fewer of these facilities but that have reasonable access to them in nearby settlements." (CLPKP)
The settlement of Ifold is defined by a Settlement Boundary.

In the Settlement of Ifold there is no shop, pub, school, medical facilities or recreational facilities to meet the everyday needs of local residents, other than a village hall and a Scout & Girl Guide Hut both run by and reliant on volunteers.

Plaistow village is outside a settlement boundary, and therefore in the countryside (or "Rest of Plan Area" as defined in the current CLPKP Policy 2 - Development and Settlement Hierarchy).

In Plaistow village there is a primary school; village shop; Church; pub; village hall with youth club (with its own multi-use outdoor games area) and preschool (with its own dedicated outdoor play area); weekly Royal Mail Post Office outreach service; village green; outdoor, fenced children's playground; cricket pitch with practice nets and pavilion; and a football field with pavilion.

The service village notation in the Local Plan CLPKP revolves around reasonable access to services and facilities. In the case of Ifold 'reasonable access' can only be achieved by the use of a car or taxi service, whereas for Plaistow, village services and facilities may be accessed by residents on foot. Within the Service Village notation all potential housing sites are therefore not equal in terms of access to facilities and services.

Out of all the villages in the North of the District area, Plaistow village does not have a Settlement Boundary, yet it is a village that has the most number of facilities and services. All other villages have sustained considerable levels of new housing development over the past 15-20 years yet Plaistow village has not absorbed any of that housing.

The planning consultancy AECOM, appointed by Locality a partner organization of the Ministry of Housing, Communities and Local Government (MHCLG), conducted a Site Options and Assessment (August 2016) of the proposed housing sites to be considered for inclusion in the Plaistow and Ifold Parish Neighbourhood Plan. Their study concluded that the CDC Site Allocations DPD site had a high probability of being considered less sustainable in terms of national planning policy at Examination, than the alternative sites in Plaistow, given that the Ifold settlement currently has no services and few facilities - following the closure of its village store.
In the AECOM report (dated August 2016), under conclusions and recommendations (page 25) the following comments are drawn to the attention of Chichester District Council planning department:
'Ifold is fundamentally a less sustainable location than Plaistow.'
'The NPPF...would not support any further residential development at Ifold due to the lack of services and facilities within walking distance.'
'It would be virtually impossible for any party, including for CDC, to argue that development at Ifold would be justified for as long as there is no shop, school or pub in the village but there is a range of suitable and available sites at nearby Plaistow.'
* Importantly, this conclusion should be used in the case against the current allocation of Site 4 (Land to the North of Little Springfield Farm by CDC in their current Site Allocations Development Plan Document (SA DPD).
* The second bullet point on page 26 of the AECOM Report (August 2016) sets out that:
"The approach to sustainable development in the English planning system as set out in the NPPF and reiterated in both Chichester's adopted Local Plan and in the Little Springfield Farm appeal decision means that Plaistow is effectively the only settlement in the Parish that could be considered suitable for new housing development."
Plaistow village should have a defined settlement boundary that takes into its conservation area and with consideration of the many other housing development sites brought forward by Plaistow landowners. They are sites that were not discounted by the Parish Council in its neighbourhood planning activities but not brought forward as the housing allocation in the previous Local Plan had been accounted for in a suitable site Land opposite the village green, Common House Road, Plaistow. Defining a settlement boundary in Plaistow would manage any housing development to be brought forward by those landowners.

Further evidence in support of this is set out as follows:
* Ifold is approximately 2.4km from the centre of Plaistow village, which has the most facilities and services: a school, shop, Church, hall, post office services, village green, children's playground, other recreational facilities and a pub;
* Facilities and services in Ifold are limited to a village hall and a Scout Girl Guide HQ (which rely on volunteers);
* There are no public open spaces or a children's playground in Ifold;
* Plaistow Road, Ifold is a 40 mph speed zone up to the boundary and then becomes a 60 mph speed zone up to Plaistow village. There are no pavements. pedestrian crossings or street lighting to permit safe pedestrian access to the limited Ifold facilities or the facilities in Plaistow.
* The Local Education Authority (West Sussex County Council) 'Home to School and College Transport Policy' applied walking distances are: 3.218688 kilometres (two miles) in relation to a child who is under the age of eight; and 4.828032 kilometres (three miles) in relation to a child who has attained the age of eight. However, in approximately 1997/1998 West Sussex County Council made arrangements for the provision of bus transport for Ifold school children to and from Plaistow and Kirdford Primary School. This is because the Plaistow Road route is regarded by the County Council as too hazardous for a child to walk. The County Council were going to withdraw the free service that had been provided for a number years or withdraw the service entirely as they were not required to provide a bus. The only grounds to have a free service retained was safety, which the Parish Council proved and the County Council agreed.

Resident od West Wittering
The following statement should have been submitted at an earlier stage of the consultation.

Comparing the ONS Population Data with GL Hearn OAN there is no correlation. It is also noted that GL Hearn stated an OAN for the District of 775. Take off the SDNP OAN of 125 (of which 81 have been adopted) this leaves the Plan Area at 650. There is no capping.

The Policy should also refer to the role of Neighbourhood Plans in meeting the development requirements of the sub regional centre, settlement hubs and service villages.

We support the proposed settlement hierarchy and the designation of Southbourne as a 'Settlement Hub'. The settlement provides a range of existing facilities and services. It is also very well served by existing public transport which provides connections to larger centres such as Portsmouth, Southampton and Brighton.

Policy S2: Settlement Hierarchy

The proposed settlement hierarchy is supported. A concern of the Estate for many years has been the lack of opportunity within smaller rural settlements to provide new housing. Restrictive policies over many have had the consequence of any development opportunity arising in such a location, being utilised for speculative purposes and developments that are out of the reach of most local people in need. The recognition in paragraph 4.20 of the benefits of appropriate development is therefore supported. Although the Estate has little land beyond Westhampnett which could be so promoted, the plan should make provision for new housing developments in smaller rural settlements, where development can demonstrate meeting the specific social and economic needs of individual community (for example, new smaller dwellings to allow downsizing of existing residents, local needs housing - potentially promoted through neighbourhood plans, encouraged more strongly through paragraph 4.25 and or Community Land Trusts) as well as meeting the wider district need.

Within Policy S2 (Settlement Hierarchy) Bracklesham is identified in the Council's Settlement Hierarchy Paper (December 2018) as a Settlement Hub where there is a range of service and facilities with a reasonable size population base to support them. Bracklesham is one of only four identified Settlement Hubs identified as being secondary service centres after only Chichester itself. The Council therefore, acknowledges that Bracklesham is a sustainable location. Whilst my clients site lies in Earnley Parish, it lies on the eastern edge of the Bracklesham / East Wittering built up area and is therefore, closely related to this settlement in terms of the general pattern of development. The western boundary of the site abuts the eastern edge of the Bracklesham / East Wittering settlement as proposed to be extended through the Plan. The site is therefore, a logical addition to development in this area which will support the continued viability of existing services and facilities in Bracklesham and East Wittering whilst also being close enough to Earnley to equally support its services. The allocation of the site for development would represent a sustainable pattern of growth regardless of administrative boundaries and the current hierarchy reflects this principle.

I don't think that devising a "settlement hierarchy" serves any real purpose. This just tries to give areas extra labels. Things aren't as simple as that. We already have settlement descriptions and they are villages, towns and cities. Anyway, no mention of Lavant; not all of it is in the SDNP.

This mentions settlement hubs and the aspiration for development around these settlement hubs. No linkage is evident that consideration is made for improvements in infrastructure and public transport links to these settlement hubs that are already at breaking point. This linkage and consideration needs to be included in the local plan to adequately address current issues let alone compounding problems from further development. An example is children from Bracklesham having to travel up the Manhood peninsula to Stockbridge and then back down the peninsula to Selsey to attend secondary school. Double the journey distance and time from school provision in Chichester. This is work that should already be being undertaken and not to mitigate further development. Unless this is adequately addressed in future iterations of the plan I will wish to raise this with the examiner at the appropriate juncture.

To describe Fishbourne as a Service Village is blatantly wrong. It has very few facilities, no surgery and only one shop. It has a Primary school that is always at full capacity with waiting lists. The community centre provides a wide range of facilities that are already very successful and which attract customers from a wide region and does not rely solely on Fishbourne to sustain itself. Yet proposals suggest that Fishbourne can accommodate the same increase in housing numbers as, for example, Bosham who have shops, hotels, takeaways, pubs, and a GP surgery, and accommodate more additional houses than Hunston, who have many more facilities than Fishbourne.

Your policies state that 'to protect the landscape, character, quality and tranquillity of the countryside it is essential to prevent inappropriate development'. Development of this scale in Fishbourne is inappropriate and does not meet this policy. As a result of the late introduction to a wildlife corridor to the East of Fishbourne, proposed land availability in the village has been halved and the village no longer has the capacity for 250 new houses without destroying its rural character. The allocated number of 250 homes in Fishbourne should be reduced to account for the removal of potential land available for development. Due to the introduction of the wildlife corridor, the remaining large site identified for housing in Fishbourne is land on Bethwines Farm. I believe it is fundamentally wrong to promote building on a viable arable farm when many suitable brownfield sites are still available within the District. Losing Bethwines Farm to development would not only impact on local jobs but would also destroy the village landscape and character.
Although a wildlife corridor is proposed between Fishbourne and the new development currently under construction on Clay Lane, there doesn't appear to have been any consideration given to the wildlife on the West side of Fishbourne. Kites, foxes, buzzards, badgers, water voles, geese, and bats are all frequently observed on and around the Bethwines Farm area, raising the question that perhaps it would also be appropriate to designate the West of Fishbourne as a wildlife corridor too? Building on the West side of Fishbourne will have a significant negative impact on our wildlife.

If additional housing is required in Chichester District, we should be first looking to regenerate existing brown field sites and also to do more to develop our coastal area and enable our tourism industry to grow. Many other towns and villages along the coast of Britain already take advantage of their location to improve their economy without detriment to the environment, for example along the Jurassic Coast in Dorset. I would like to see increased numbers of homes and businesses in the area south of the A27 to Selsey, giving more opportunity for water sports and marine based tourism to grow.

In summary, the additional housing proposed for Fishbourne should be reduced from 250 to recognise there is limited land available in the village especially since the introduction of the East wildlife corridor. Your own policies are now acting to promote the destruction of one of the areas viable farms by building in a strategic gap between villages and, judging by previous withdrawn Planning Applications on Bethwines Farm, leaving the door open for the future construction of 100's of more houses in the future. How can this be in keeping with your countryside policy? Rather than destroying the rural character of the District's villages, we should be concentrating on fully developing Brownfield sites and doing all we can to encourage our tourism industry by providing greater opportunity to take advantage of the coast around the Manhood Peninsula. The current proposals as they stand do not give this adequate consideration.

RESPONSE TO PROPOSED DEVELOPMENT FOR CHIDHAM AND HAMBROOK (POLICY AL10 AND PREAMBLE).

1) Chidham and Hambrook is designated as a 'Service Village' with no explanation as to what, this is. What exactly are we, as residents, servicing? Most residents, I am sure, regard the village as their home and where they build their lives, not as simply a dormitory which they inhabit in order to 'service' local employment opportunities. As such, what happens to the place where they have chosen to live their lives is of some importance to them.

2) i)The reference to possible relocation and expansion of Chidham Primary School is simply wrong. The relocation of Bosham Primary School will make it completely infeasible for any replacement school in Chidham and children will have to make their way along the A259 to Bosham. The proposed development of a minimum 500 homes in the revised Neighbourhood Plan will, therefore, not include a two form entry primary school
ii)The number of houses allocated to the designated sites is in excess of CDC's own guidelines on houses per hectare, and seems to unquestionably accept what developers would like to build - i.e. as many as they can squeeze onto the given sites.
iii) There is no specific mention of social housing in the types of residential accommodation cited. The reliance on what private developers want to build will mean yet more cramped estates of largely three and four bedroom houses that will not meet the needs of the full range of those desperately needing affordable housing.

3) The "provision of high quality development ...... as a sustainable extension of the existing settlements" gives little indication of what 'sustainable' means other than "sustainable forms of transport" with no further explanation. There is a reference in point 3 to 'off-site improvements (including highways)' again to "promote sustainable transport options". It would seem, from this, that 'sustainability' is taken to mean nothing more than the use of private cars. The A259 is already a heavily used transport route for all types of conveyance, including large numbers of heavy lorries and commercial vehicles. Another 500 plus houses (not to mention the 1,250 intended for Soutbourne) will, of course, dramatically increase this already congested route since there is no nearby access to the A27. The local train service from Nutbourne is infrequent and unreliable, and the bus service, whilst frequent and fairly reliable, is prohibitively expensive for commuters and, especially, families. There appear to be no plans to address the obvious need for proper integrated public transport systems, including safe cycle routes. In fact, in relation to both housing development and transport, 'sustainability', whilst stated more than once, is, in practice, ignored. This myopic view of 'sustainability' will seriously diminish the quality of life in this area.
4) There is absolutely no doubt that the building of 500 houses in Chidham, in addition to the 1,750 houses earmarked for Bosham, Fishbourne and Southbourne, will have an irreparably damaging impact on all aspects of the Chichester Harbour AONB. Views of, and from, the water to the South Downs will be irretrievably lost. The water quality will be diminished, threatening the SSSI status of the Harbour, and the distinctive nature of the villages of Bosham, Chidham and Southbourne will be destroyed.
5) The infrastructure of the whole area is already under enormous strain, and there are no serious proposals to mitigate the damaging effects of this excessive and poorly planned development. The whole process appears to be driven by both government diktat and CDC's uncritical acceptance of developer's requirements. The need for more housing is clear. But such development must be focused on the needs of the most vulnerable as well as the financially advantaged. Most importantly, it must be genuinely sustainable in terms of infrastructure, the environment and the special status of areas bordering AONB's and SSSI's. The proposed development fails these needs in every respect.

Having read the Local Plan - Preferred Approach we are extremely concerned that the powers that be do not fully comprehend the geography and economic importance of the Manhood Peninsular. We therefore set out our comments below.
There is only one road (A286) linking the Witterings/Bracklesham to the A.27 which is one of the most congested roads in the area and it has proved difficult on occasions for the emergency services to reach accidents etc. It also makes travel to and from these villages, including by buses, extremely difficult. The proposed AL6 link road will not solve the problem and nor will the junction changes which will result in local journeys becoming longer and more difficult. The housing targets will also impact greatly on the road capacity. There needs to be a long term solution to the A27. Indeed, the A286 which links the Witterings/Bracklesham to Chichester is so frequently gridlocked that St Richards hospital recommends that its senior staff do not live in the area because they cannot guarantee that they will be able to reach the hospital within a necessary time limit.
The proposed provision of a commercial development site and a raised link road will be on a flood plain and is adjacent to an internationally important habitat site. This would suggest that such a site for the development would be unsuitable. The impact of a raised road on the Apuldram/Donnington area would also be substantial on the local community.
Consideration has apparently not been given to the impact of the changes at the Hunston junction. There is now a large secondary school near to the junction which has resulted in an increase in the amount traffic at the junction of as the considerable number of children have to be taken to/from school by car due to the lack of public transport particularly from the Witterings areas.
For the reasons stated above we do not think the proposed AL6 link road or the provision of a commercial development site is a sensible or economic solution.
In the Section "S2 - 4.14 Development Strategy it states "consideration has been given to other factors in determining whether a settlement is a suitable location for additional housing growth, including infrastructure capacity". However, these factors do not appear to have been fully taken into account and we would like to comment as follows.
The minimum housing target of 350 set for the Bracklesham/East Wittering area will have a significant impact on the villages and the A286 and suggests that a higher housing target could be reached. Even a maximum of 350 would excessive, in view of the increase in housing that has already taken place and is currently under construction in the area (including Birdham). There is no easy access to the rail networks, employment, secondary schools and higher education. There is no secondary school in the Witterings/Bracklesham area and there is very limited employment in the Manhood Peninsula, which means people have to commute to access employment, schooling and rail networks. One has to assume that it is most likely that each property is likely to use two cars. All traffic from these villages has to travel along the frequently congested A286. The schools are already almost at capacity as is the medical centre which already finds it necessary to divert some patients in need of medical attention to other practices outside of the villages. These village communities rely heavily on tourism for employment and their economy. If the road becomes even more congested this will inevitably lead to tourists avoiding the area, which would also have an adverse effect on the contribution the Peninsular makes to the Chichester district.
We live in Somerley in a conservation area. We have already been impacted by the increase in noise levels from traffic passing along Bell Lane/Bracklesham Lane. According to a Transport Study for the LPR by Peter Brett it forecasts that the further increase in housing will raise the level of noise to "major". We suggest that consideration should be given to reducing, not increasing, the level of noise.
In view of the above we object to East Wittering/Bracklesham being considered as a settlement hub and it should be removed.

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

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

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

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

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

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

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

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

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

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

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

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

In addition, paragraph 189 of the Framework states;

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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


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

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





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

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

We support the creation of an integrated and sustainable transport plan for the District, or at the very least for the area west of Chichester. This plan should draw upon the ongoing work of the ChEmRoute group's investigations and proposals and be coordinated with WSCC with the goal of introducing high quality and separated cycle links between the villages along the A259 and Chichester.

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





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

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

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

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

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

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




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


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

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