Policy A13 Southbourne Broad Location for Development

Plan should show details of sites proposed within BLD.

I have read the published documentation on the above subject as carefully as is possible, given the restrictions on cross-referencing whilst using a screen. My reaction is that the report is really about the immediate area of Chichester and that, where I live in Southbourne, is of less importance. Should this not be the case, perhaps you could tell me why, please, that so little space and detail is given to an area which is designated to take more than 10% of the housing requirements for the area?

Two paragraphs seem to sum up reasons why. I shall quote them below:
Southbourne and Tangmere will continue to grow and develop their role as settlement hubs by widening the range and improving the quality of public open space, leisure and community facilities for their respective local areas. For Southbourne, the aim is to take advantage of the village's good transport links and existing facilities to deliver significant new residential-led development within the broad location for development which will further enhance local facilities and offer opportunities to reinforce and supplement existing public transport, including bus routes.

Southbourne is a 'Settlement Hub' with a good range of services and facilities, and rail connectivity. As a sustainable settlement, Southbourne has been identified as a location suitable for a comprehensively masterplanned mixed use development of 1,050 dwellings, with local employment, education provision and appropriate community facilities. The Plan identifies a broad location for development (BLD) at Southbourne, which means that the development site boundary will be determined at a later stage, either through a site allocations development plan document or through the neighbourhood plan.

I guess that the definitions 'Settlement Hub' and 'BLD' - whatever they mean - give licence to the Council to 'balance their books' by dumping the excess housing needs over what other areas can take into Southbourne without definition of the 'where' such provision is expected to be met, especially given your claim that the are has been 'identified' for such purpose. This is not good enough! The plan should show detail of sites proposed. Anyway, the sheer number of houses is objectionable.

But, I do complement the Council for their humour. The suggestion that Southbourne enjoys good transport links is a real LOL moment! It also shows that the report's authors do not live in Southbourne, or have ever tried to get to appointments using either public transport or the local road system. Even allowing for the current disruptions caused by strikes, maintenance works, lack of staff, etc., the service provided on both rail and bus networks is very poor and unreliable. So much so that even we have been forced to return to use of the car where timing is important. And, then, of course, we meet the problem of the road system with its huge inadequacies and under provision. Not your finest moment.

I could go on but you have, probably, stopped reading by now as this is not the stuff you want to read.
• My overall verdict on the document is that it is poor.
• My overall verdict on the proposals is 'dream on'.
• My overall expectation on the outcome is that it matters not a jot what I (or anyone else when it comes to it!) says, as we shall be stuffed with whatever the Council decides, come what may. After all, it is financially rewarding the them (via the Council Tax levy) to build as many properties as possible and in areas where 'the take' is enhanced, like Southbourne.

Policy A13 should be limited to 300 houses.

Building 84% (8717 houses) of the allocated housing along the east-west corridor is not justifiable. There are no guaranteed upgrades to the sewage network or the strategic road network in this area. The areas proposed rely on wastewater treatment facilities which are already over capacity. The road network cannot cope and there are modelled peak time delays of 29 minutes to access the Fishbourne roundabout if this scale of development goes ahead. The Fishbourne roundabout has been over-capacity since 2014 and no measures have been taken to improve the situation. There is nothing guaranteed in the plan to address this.

In principle, the PC supports the proposed BLD at Southbourne. Southbourne village has been identified as a settlement hub due to the facilities it offers, even though a number of these are currently inadequate. Paragraph.6.89 of this Local Plan states that the proposed development provides the opportunity to make good the existing shortfalls (eg open space, para.6.85) and to provide well-serviced new development. This development must be achieved through comprehensive masterplanning. There has been, and continues to be, pressure for piecemeal proposals. These must be rejected to secure a properly planned expansion which maximises the provision of timely accompanying infrastructure.

Delete "16"

This specifically relates to point 1. An assessment of need for the Southbourne Parish Neighbourhood Plan demonstrated that considerably more than 16 serviced self/custom build plots are likely to be required in future. The requirement for 16 may have been sourced from the CDC current register which may be unreliable. The Southbourne housing allocation is not anticipated to come on stream until 2028/2029 (see Local Plan Appendix E – Housing Trajectory) therefore it is currently too early to be so specific about numbers.

At the end of the Policy include “….sustainable transport options (including ChEm route)”


Please note these comments relate specifically to A13 point 4.

There is no reference to the ChEm route - a route for cyclists linking Emsworth and Chichester. It is an initiative being gradually implemented, as opportunities arise, to provide a safe route alongside the A259 to encourage cycling as a sustainable means of travel. ChEm route will eventually form part of the local network of cycle routes to which the proposed new allocation will be connected. The Local Plan gives weight to sustainable forms of transport including new cycle networks (Policy T2c) and as this Policy A13 is site specific it would be appropriate to include this initiative by name.

Add into Policy A13.6 “…… community facilities, medical/health facilities, retail, employment and transport in accordance with ……….”

Ref A13 point 6. Infrastructure - its current shortfalls and poor quality - is another major issue locally. Education and medical services are overstretched and this was evident long before the pandemic. This site specific policy, not just the supporting text, should be clear about what type of facilities will be required and should include reference to medical/health services and retail. “Local employment opportunities” are mentioned in para. 10.52 but not in the policy, so has less weight. Work on the Neighbourhood Plan has shown potential for an enterprise hub with flexible working space.

An additional sentence at the end of clause 4 – “A pedestrian footbridge over the railway line will be required as part of the Green Ring and provision of a separate road bridge will be considered”.

Ref point 5. Wording of clauses 4 and 5 in Policy 13 is vague, and it is particularly hard to understand what is meant by clause 5. Delays created by the railway crossings in Southbourne are already a major issue. The Southbourne allocation will require at least the provision of a pedestrian footbridge over the railway line east of the station to facilitate the Green Ring access around the village (land has already been safeguarded at Priors Orchard, see Neighbourhood Plan, Policy SB13c). At best, a road bridge will be required to facilitate traffic movements from the proposed allocation.

Add into Policy A13.6 “…… community facilities, medical/health facilities, retail, employment and transport in accordance with ……….”

Ref point 16. Infrastructure - its current shortfalls and poor quality - is another major issue locally. Education and medical services are overstretched and this was evident long before the pandemic. This site specific policy, not just the supporting text, should be clear about what type of facilities will be required and should include reference to medical/health services and retail. “Local employment opportunities” are mentioned in para. 10.52 but not in the policy, so has less weight. Work on the Neighbourhood Plan has shown potential for an enterprise hub with flexible working space.

Additional sentence following “……….. countryside and surroundings. Currently there is a shortfall in Green Infrastructure available to existing local residents which needs to be addressed within the Broad Location for Development.”

Ref.point.16 Evidence shows that Green Infrastructure in Southbourne is currently well below the amount required, and the policy should refer to this to ensure that the new development provides for this to be made good as well as providing for the needs of those occupying the new development. LP PolicyP14, in particular subsections 1&2, sets out how the need for new Green Infrastructure should be incorporated into new allocations requiring that it “…. is integrated into the development design and meets the needs of the communities within and beyond the site boundaries” (i.e. those residents living outside the Southbourne BLD).

Ref.point.13 Provision of appropriate waste-water services is fundamental. Lack of capacity at ThornhamWWTW is the subject of considerable concern. Southern Water has been using storm-water discharges into Chichester Harbour to overcome capacity problems for years and this has contributed to the declining water quality. While the issue of nitrate discharge may be more difficult to resolve, it is not an excuse for allowing primary treated human waste to exacerbate the problem. Delivery of the proposed development at Southbourne is at least 6yrs away, and the PC will expect appropriate waste-water treatment to be available in good time to serve it.

Ref. Policy A13, paras. 7,10,11,12,14,15&16

Consistent with objectives and policies included in the Southbourne Submission NP which is currently at Regulation 16 consultation stage

Proposed allocations adjacent to the AONB and impacting on its setting, including views into and from the SDNP should be removed.

The proposed allocations within the East/West corridor, would not comply with this policy and would damage the visual relief to the built up areas and the views between the AONB and the SDNP.

We request that any future allocation requires a site survey for ancient woodland and ancient & veteran trees, and that appropriate buffers are applied, before the number and layout of dwellings is agreed.

The broad site allocation lacks specific detail on its environmental impact, therefore we are unable to either support or object at this stage. We welcome point 9 requiring habitat protection. We request that any future allocation requires a site survey for ancient woodland and ancient & veteran trees, and that appropriate buffers are applied, before the number and layout of dwellings is agreed.

We would need to have a clearer idea of housing location to comment in more depth however would wish to see a reduction in the allocation at this location.

The Chichester Harbour Trust objects to the allocation at A13 at Southbourne. This proposal represents major development adjacent to the Chichester Harbour AONB and is disproportionate to the size and facilities of the existing settlement. It is within the 5.6km zone of influence for Chichester Harbour SSSI. It is our observation that this allocation represents a conflict with the policies outlined in the Plan chapter 4 on the natural environment, which makes it hard to justify the soundness of the Plan, particularly: Policy NE2 Natural Landscape Policy NE3 Landscape Gaps between settlements Policy NE6 Chichester’s Internationally and Nationally Designated Habitats Policy NE7 Development and Disturbance of Birds in Chichester and Langstone Harbours, Pagham Harbour, Solent and Dorset Coast Special Protection Areas and Medmerry Compensatory Habitat Policy NE13 Chichester Harbour Area of Outstanding Natural Beauty Policy NE16 Water Management and Water Quality

It is difficult to make an assessment of the impact of housing development in the broad location without specific site allocation plans, which we understand would come through the neighbourhood plan process. However our general concerns about the allocation relate to: - the impact on the sensitive landscape setting of the AONB and loss of open views to the South Downs
- the over-reliance on developing greenfield sites, mostly on grade 1 & 2 agricultural land leading to concerns about unsustainable loss of countryside and impact on food production and food security
- the inadequate waste water treatment infrastructure at Thornham WWTW and lack of funded improvements in the timescales required
- the additional flood risk and ground water issues raised by construction on low lying coastal plain sites
- the impact on biodiversity and species that rely on the interconnectivity between the protected landscapes
- the additional recreational pressure within the SSSI zone of influence
- the inevitable increase in air, noise, and soil pollution

Overall, we feel that the allocation does not reflect emerging government rhetoric (which may soon translate to policy through the NPPF) about overdevelopment of countryside in the South East of England, and that the timescale is not compatible with the NPPF review which may lead to an alternative method of determining housing allocations in the district. For this reason we find the plan to be unsound.

Policy A13 should include the following “Due to the circumstances which require a BLD to be proposed for Southbourne, the provisions of the Council’s ‘Interim Position Statement for Housing April 2022’ will not be applied in Southbourne parish”. A similar statement needs to be added to the “Interim Position Statement for Housing” for consistency.

The HEELA 2021 shows the District Council’s assessment of the potential for housing in Southbourne to be well over 4000 dwellings. However, the parish is not capable of accommodating an unlimited amount of housing.

The parish is under great pressure and this was acknowledged by the reduction of the strategic allocation from 1250 to 1050 in the Council’s letter dated 26th November 2020. The District Council reduced the strategic allocation to take account of an appeal which allowed 199 dwellings on a site in Cooks Lane, Southbourne on 2nd March 2020. (199 dwellings App. No. 18/03/03145/OUT). A letter from the District Council to the Parish Council dated 26th November 2020 stated “… the revised distribution we are testing includes a proposed level of development of 1,250 dwellings for your parish. The working assumption therefore is that your parish council will bring forward a neighbourhood plan identifying sites (of five or more dwellings) to deliver this level of development for the period 2019-2037. Typically, any sites or schemes which already have planning permission, allocated in the existing Local Plan or a “made” Neighbourhood Plan as at 1 April 2020 would not count towards this figure. Nor would development on sites of less than five dwellings, as they count towards the “windfall” figure for the Local Plan Review and so cannot be double counted. The exception to this is the 199 dwellings which have planning permission on the Cook’s Lane site, which I can confirm are envisaged will count towards the 1,250 total.” It appears that, quite rightly, the District Council made this exception because it was recognised that more than 1250 dwellings could not be sustained in the parish.

This pressure continues. There are currently four large applications pending in Southbourne. Those at Penny Lane (23/00024/OUT – 84 dwellings), and Four Acre Nursery (22/01903/OUT – 40 dwellings) lie within the BLD. Hopefully these will be refused as approval would prejudice the intention of Policy A13. A third lies outside the BLD at Gosden Green Nursery (21/02238/FULEIA – 29 dwellings) and the outcome of an appeal is awaited. The fourth (21/01910/OUT – 63 dwellings) lies outside the BLD and close to Hambrook. “The Interim Position Statement for Housing” has been invoked in three of these applications. If approved, these “piecemeal and unplanned” applications as submitted will chip away at the strategic allocation figure and the proposed masterplanning without providing the infrastructure so badly needed in the parish. The Interim Position Statement has weight as Supplementary Planning Guidance and the Local Plan Review also has weight having reached its Regulation 19 stage, it is not clear which has precedence.

The period of greatest pressure is likely to be experienced before the approval of the Local Plan and therefore the "Chichester Interim Position Statement for Housing" should be amended to exclude Southbourne parish now.

(Please note the uploaded document "Chichester Interim Position Statement for Housing" is dated 2020 as the 2022 version does not appear to be on the CDC website)

The draft policy wording predetermines how the emerging Neighbourhood Plan or future Site Allocations DPD should distribute the identified local housing need and associated development. The draft policy is not consistent with the strategic objective of the emerging Plan to meet the local housing needs of the District and apply the ‘presumption in favour of sustainable development’ (ref. Paragraph 11, NPPF).

We welcome the identification of Southbourne as a ‘Strategic Development Location’. This recognises the range of key services and facilities located within Southbourne such as those referred to in the supporting text. Notwithstanding the above we wish to draw the Council’s attention to the potential conflict in the draft policy wording with the ability of the emerging Plan to meet the local housing needs of the District and apply the ‘presumption in favour of sustainable development’ (ref. Paragraph 11, NPPF). Whilst we support the draft policy objective to deliver housing, employment, retail, social and community facilities at Southbourne, the policy wording predetermines how the emerging Neighbourhood Plan or future Site Allocations DPD should distribute the identified local housing need and associated development. The requirement in the wording for development to address all 16 criteria within the BLD assumes a single site will come forward, as opposed to a number of sites which collectively could meet the 16 requirements, if planned for in advance. Proposals for sustainable urban extensions where land is ‘available’ and ‘achievable’ in Settlement Hubs such as Southbourne, are a sustainable way to meet the local housing need in the early years of the Plan period and support the long-term vitality of existing communities. A number of smaller sites can collectively bring the benefits of a single major large-scale development, with the added benefit of early delivery, provided a strategic approach to infrastructure delivery is taken and coordinated through the emerging Plan and Infrastructure Delivery Plan. This is recognised in Paragraph 69 of the NPPF where by the important contributions of small and medium sized sites can make in meeting the housing requirements of an area and are often built-out relatively quickly. The ‘Land at Cooks Lane’ is identified in consecutive versions of the Chichester SHLAAs and HELAAs as ‘available’, ‘achievable’ and ‘suitable’ during years 0-5 of the Plan period. The site is located outside of the AONB and could collectively contribute to Community, Blue and Green Infrastructure and recreation opportunities, such as the ‘Green Ring’ initiative being carried forward through the Neighbourhood Plan process. It also has the added benefit from proximity to Southbourne Railway Station providing connections to Chichester, Portsmouth/Southampton and the wider region and formal support from Network Rail in relation to the Southbourne level-crossing. In order to meet the housing needs of Southbourne over the Plan period and provide sufficient flexibility to achieve early delivery, should other sites and / or allocations be delayed, the policy wording would also allow development to be dispersed around the settlement to allow the phasing of well-integrated high quality sustainable urban extensions providing good access to facilities and sustainable forms of transport. Through the implementation of the IDP all development proposals would be required make proportionate contributions towards the delivery of the necessary infrastructure in a timely manner. The current wording and approach to the BLD would not achieve this. With regard to the extent of the BLD the entire area shown on the Key Diagram is not considered to offer a suitable location for development within the context of the NPPF. The land to the north of Southbourne and within the landscape gap with Hermitage to the west does not present a suitable location for a single major residential-led development. Such a large scale development in this location would be more likely to lead to coalescence of the two settlements and have a greater impact on the setting of the AONB and National Park than a development to the east, or a series of smaller sites delivering incremental growth and new infrastructure to the urban area.

We welcome the identification of Southbourne as a ‘Strategic Development Location’. This recognises the range of key services and facilities located within Southbourne such as those referred to in the supporting text.

Notwithstanding the above we wish to draw the Council’s attention to the potential conflict in the draft policy wording with the ability of the emerging Plan to meet the local housing needs of the District and apply the ‘presumption in favour of sustainable development’ (ref. Paragraph 11, NPPF).

Whilst we support the draft policy objective to deliver housing, employment, retail, social and community facilities at Southbourne, the policy wording predetermines how the emerging Neighbourhood Plan or future Site Allocations DPD should distribute the identified local housing need and associated development. The requirement in the wording for development to address all 16 criteria within the BLD assumes a single site will come forward, as opposed to a number of sites which collectively could meet the 16 requirements, if planned for in advance.

Proposals for sustainable urban extensions where land is ‘available’ and ‘achievable’ in Settlement Hubs such as Southbourne, are a sustainable way to meet the local housing need in the early years of the Plan period and support the long-term vitality of existing communities. A number of smaller sites can collectively bring the benefits of a single major large-scale development, with the added benefit of early delivery, provided a strategic approach to infrastructure delivery is taken and coordinated through the emerging Plan and Infrastructure Delivery Plan. This is recognised in Paragraph 69 of the NPPF where by the important contributions of small and medium sized sites can make in meeting the housing requirements of an area and are often built-out relatively quickly.

The ‘Land at Cooks Lane’ is identified in consecutive versions of the Chichester SHLAAs and HELAAs as ‘available’, ‘achievable’ and ‘suitable’ during years 0-5 of the Plan period. The site is located outside of the AONB and could collectively contribute to Community, Blue and Green Infrastructure and recreation opportunities, such as the ‘Green Ring’ initiative being carried forward through the Neighbourhood Plan process. It also has the added benefit from proximity to Southbourne Railway Station providing connections to Chichester, Portsmouth/Southampton and the wider region and formal support from Network Rail in relation to the Southbourne level-crossing.

In order to meet the housing needs of Southbourne over the Plan period and provide sufficient flexibility to achieve early delivery, should other sites and / or allocations be delayed, the policy wording would also allow development to be dispersed around the settlement to allow the phasing of well-integrated high quality sustainable urban extensions providing good access to facilities and sustainable forms of transport. Through the implementation of the IDP all development proposals would be required make proportionate contributions towards the delivery of the necessary infrastructure in a timely manner. The current wording and approach to the BLD would not achieve this.

With regard to the extent of the BLD the entire area shown on the Key Diagram is not considered to offer a suitable location for development within the context of the NPPF. The land to the north of Southbourne and within the landscape gap with Hermitage to the west does not present a suitable location for a single major residential-led development. Such a large scale development in this location would be more likely to lead to coalescence of the two settlements and have a greater impact on the setting of the AONB and National Park than a development to the east, or a series of smaller sites delivering incremental growth and new infrastructure to the urban area.

We strongly support an amendment to be made to Policy H2 to allow for the provision of circa (or a minimum of) 1,250 dwellings at Southbourne';
Propose removal of need for contributions to CIL and undertake direct commitment to ensure infrastructure improvements to Southbourne.

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

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

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

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

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

Revise approach toward BLD and pursue strategy of allowing some limited dispersal of development in suitable locations as the most sustainable strategy for the distribution of housing in Southbourne Parish over plan period.

The draft policy wording would result in a conflict between meeting the local housing needs of the District and the ‘presumption in favour of sustainable development’ (ref. Paragraph 11, NPPF).

We welcome the identification of Southbourne as a ‘Strategic Development Location’. This recognises the range of key services and facilities located within Southbourne such as those referred to in the supporting text. Our client represents the freehold owners of the Land North of Penny Lane, Hermitage (c 5.4 ha), which has been identified as a ‘deliverable’ site within consecutive versions of the Chichester Housing and Employment Land Availability Assessment (HELAA). Our client welcomes the inclusion of this site within the Broad Location of Development (BLD) and has recently submitted a planning application on the site for up to 84 dwellings (CDC ref. SB/23/00024/OUT).

Notwithstanding the above we wish to draw the Council’s attention to the potential conflict in the draft policy wording with the ability of the emerging Plan to meet the local housing needs of the District and apply the ‘presumption in favour of sustainable development’ (ref. Paragraph 11, NPPF).

Whilst we support the draft policy objective to deliver housing, employment, retail, social and community facilities at Southbourne, the policy wording predetermines how the emerging Neighbourhood Plan or future Site Allocations DPD should distribute the identified local housing need and associated development. The requirement in the wording for development to address all 16 criteria within the BLD assumes a single site will come forward, as opposed to a number of sites which collectively could meet the 16 requirements, if planned for in advance.

Proposals for sustainable urban extensions where land is ‘available’ and ‘achievable’ in Settlement Hubs such as Southbourne, are a sustainable way to meet the local housing need in the early years of the Plan period and support the long-term vitality of existing communities.

Notwithstanding the benefits of a single eastern extension in the mid to later years of the Plan period, as supported in previous drafts of the Southbourne Neighbourhood Plan, a number of smaller sites can collectively bring the benefits of a single major large-scale development. This approach would have the added benefit of early delivery, provided a strategic approach to infrastructure delivery is taken and coordinated through the emerging Plan and Infrastructure Delivery Plan. This is recognised in Paragraph 69 of the NPPF where by the important contributions of small and medium sized sites can make in meeting the housing requirements of an area and are often built-out relatively quickly.

Smaller sites can also play an important role in sustaining key services and facilities within Hermitage, Southbourne and Emsworth, which have been in decline in recent years due to changing shopping habits and community displacement from increasing affordably gaps, in part due to constrained housing supply. In allowing such sites to come forward the Parish could also be facilitating new community infrastructure through the IDP and funded through CIL and / or S106 Legal Agreements.

We therefore encourage the Council to revise the approach toward the BLD and pursue a strategy of allowing some limited dispersal of development in suitable locations as the most sustainable strategy for the distribution of housing in Southbourne Parish over the Plan period.

With regard to the extent of the BLD the entire area shown on the Key Diagram is not considered to offer a suitable location for development within the context of the NPPF. The land to the north of Southbourne and within the landscape gap with Hermitage to the west does not present a suitable location for a single major residential-led development. Such a large scale development in this location would be more likely to lead to coalescence of the two settlements and have a greater impact on the setting of the AONB and National Park than a development to the east, or a series of smaller sites delivering incremental growth and new infrastructure to the urban area.

As the specific site is not allocated, we are supportive of policy requirement 12 that allocations take a sequential approach to flood risk.

As for all site allocations, we are supportive of the policy requirement for suitable phasing to ensure adequate wastewater treatment capacity is available (requirement 13).

Until there is greater clarity as to the impact of the allocation on the AONB, the Conservancy must Object.

Chichester Harbour Conservancy is seriously concerned about this allocation. The NPPF states "The scale and extent of development within all these designated areas should be limited, while development within their setting should be sensitively located and designed to avoid or minimise adverse impacts on the designated areas." To further urbanise the boundary would have a disastrous impact on the AONB designation. The Conservancy cannot support Policy A13 without knowing further details about the location of the development, the mitigation measures, etc. Furthermore, as with A11 and A12, the Policy may conflict with other draft Policies in the Local Plan.

Amend policy to acknowledge the addition of BNG to ensure the policy is consistent with national policy, 179b NPPF 2021:

9) Demonstrate that development would not have an adverse impact on the nature conservation interest of identified sites and habitats including the strategic wildlife corridors;. Deliver biodiversity net gain that
facilitates habitat connectivity.

See attached representation.

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

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

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

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

Deliverability of Key Infrastructure

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

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

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

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

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

Sustainable Transport Infrastructure & Measures

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

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

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

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

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

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

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

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

Southbourne Broad Location for Development

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

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

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

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

1) Education

Land West of Chichester

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

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

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

Policy A8 Land East of Chichester

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

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

2) Minerals and Waste

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

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

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

3) Older Person Housing

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

4) Highways and Transport

Public Transport Priority Infrastructure

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

Park and Ride

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

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

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

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

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

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

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

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

5) Public Rights of Way (PRoW)

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

It is recommended wording of policy should be updated to reflect key diagram: "Provision will be made for a mixed use development within the broad location for development to the west and east of Southbourne, as shown on the Key Diagram."
A new criteria is proposed to be included in the wording of Policy A13: "(17) To identify land for early delivery on small to medium scale sites which are not constrained by the need for a new railway crossing."

Propose land to north of Gosden Green should either be allocated in Local Plan as medium scale site or should be a key component of BLD.

1 Introduction
1.1 These Representations have been prepared on behalf of Hallam Land Management Limited (hereafter ‘Hallam’), in response to the Chichester Local Plan Review Proposed Submission Plan consultation.

1.2 Hallam is a strategic land promotion company operating throughout England, Wales and Scotland delivering land for new employment and commercial premises, housing, including specialist elderly housing, and mixed-use developments. Hallam has been acquiring, promoting, developing and trading in land since 1990. During that time, the company has established an outstanding record in resolving complex planning and associated technical problems in order to secure planning permissions for a whole range of different land uses to facilitate the delivery of new development.

1.3 Hallam control land to the west of Southbourne, to the north of the A259 and south of the railway line. Development of this land for new housing including specialist elderly accommodation, as shown in the accompanying Vision Document, would be consistent with the established Spatial Strategy; which is rightly retained in the consultation document. Similarly, development would contribute towards meeting the future housing needs of the District within the proposed Broad Location for Development (BLD) at Southbourne.

1.4 These Representations set out our support for the BLD drawn on the key diagram to the west and east of Southbourne. However, Hallam are seeking amendments to Policies S1, H1, H2, H8 and A13 to ensure that: the overall housing needs are met across the District, including early delivery and specialist accommodation; the flexibility sought early in the Submission Plan, at Policy S2 and H1, is carried through to the strategic allocations and locations; and, the BLD is distributed to the west and east of Southbourne.

1.5 Moreover, Hallam are proposing the allocation of small and medium scale sites at Southbourne within the Local Plan, to enable early delivery of housing and infrastructure, with the land under their control a suitable site for this allocation. Should the Council not allocate these sites, then the strategic allocations/locations policies need to be updated to reflect the requirement for the delivery of small and medium scale parcels which could form part of the larger sites.

1.6 In the context of the above, it is instructive to note that Chichester District has an older population than national average, which has been predicted to increase by 42% between 2021- 2039. The increasing need for specialist accommodation should be addressed through specific allocations within the Local Plan, rather than the proposed approach of Policy H8.

1.7 Our response is focused on the following matters:

• The Spatial Strategy, settlement hierarchy and the distribution of development across the District;
• The overall amount of new housing required within the new plan period;
• The need for specialist accommodation;
• The status of Southbourne and the role and function it plays; and
• The strategic allocation proposed at Southbourne in Policy AL13.

1.8 In preparing the Local Plan Review, the Council will need to ensure that it complies with paragraph 35 of the National Planning Policy Framework (NPPF) (2021) which sets out four tests to ensure the plan is ‘sound’. These are as follows:

• Positively prepared – providing a strategy which, as a minimum, seeks to meet the area’s objectively assessed needs, and is informed by agreements with other authorities, so that unmet needs from neighbouring areas are accommodated where it is practical to do so and is consistent with achieving sustainable development;
• Justified – an appropriate strategy, taking into account the reasonable alternatives, and based on proportionate evidence;
• Effective – deliverable over the plan period, and based on effective joint working on cross- boundary strategic matters that have been dealt with rather than deferred, as evidenced by statements of common ground; and
• Consistent with national policy – enabling the delivery of sustainable development in accordance with the policies in this Framework.

1.9 We are mindful that the Government has recently published a consultation concerning potential amendments to the NPPF. Paragraph 1 of that consultation document indicates that the government is committed to “building more homes” whilst Paragraph 6 explains that the government “remains committed to delivering 300,000 homes a year by the mid-2020s”.

1.10 In the proposed revisions, paragraph 1 makes clear that the NPPF provides “a framework within which locally-prepared plans can provide for sufficient housing and other development in a sustainable manner.” At paragraph 60 the overall aim of a Local Plan is identified as meet[ing] as much housing need as possible with an appropriate mix of housing types to meet the needs of communities.

1.11 It is clear therefore that the potential amendments to the NPPF firmly intend that Local Plans, including this one, continue to provide a sufficient supply of housing land to meet identified needs.

2 Objectives and Spatial Strategy

Objectives of the Local Plan
2.1 The Submission Plan has identified key challenges and opportunities that influence future planning, across the three areas of the District, and how it aims to address these through planning policies and proposals.

2.2 Within the consultation document, the strategic objectives presented by the Council are structured into specific categories, ensuring housing and neighbourhood objectives are clearly set out for the plan period.

2.3 Amongst these is the objective to increase housing supply; increase provision of affordable housing; and promote the development of mixed, balanced and well-integrated communities. These are consistent with the NPPF’s policy objective to significantly boost the supply of housing in paragraph 60. In this context, it is right that the Local Plan’s development strategy is founded on this objective, ensuring sustainable development which responds to social, economic and environmental considerations that meets the needs of the plan area.

2.4 These objectives frame the policies and proposals for future development across the plan area to create sustainable neighbourhoods; this demonstrates, as a matter of principle, that the Local Plan intends to be positively prepared and justified, albeit there are limitations on how this is achieved in practice when the policies and proposals are considered.

2.5 The NPPF states at paragraph 22 that strategic policies should look ahead over a minimum 15 year period from the date of the Plan’s adoption. The Local Plan aims to cover the period of 2021- 2039, which is 18 years. However, this plan has not been adopted yet and it is considered unlikely that this Local Plan will be adopted before 2024-25. Therefore, the Plan may not cover the required plan period of 15 years and the Council should extend the plan period to at least 2040 to ensure this requirement is met.
Policy S1: Spatial Strategy
2.6 The Spatial Strategy is accompanied by the Key Diagram (Map 3.1), identifying the distribution of development and infrastructure provision across the plan area.

2.7 The strategy aims to build on the existing Local Plan, focusing growth at Chichester city, as the main sub-regional centre, and at two settlement hubs along the east-west corridor at Tangmere and Southbourne.

2.8 Policy S1 specifically identifies the broad approach to providing sustainable development, in accordance with the Local Plan Objectives, ensuring development is focused principally along the east-west corridor. It aims to distribute development in line with the settlement hierarchy, ensuring development is located in the larger and more sustainable settlements.

2.9 This accords with paragraph 20 of the NPPF which requires strategic policies to set out an overall strategy for the pattern, scale and quality of development, and make sufficient provision for housing, infrastructure, community facilities along with policies that seek to conserve and enhance the environment.

2.10 Paragraph 105 of the NPPF states that the planning system should actively manage patterns of growth in support of these objectives. With significant development being focused on locations which are or can be made sustainable, through limiting the need to travel and offering a genuine choice of transport modes.

2.11 Paragraph 69 of the NPPF sets out how small and medium scale sites can make an important contribution to meeting the housing requirement. Part d) identifies how working with developers to encourage the sub division of large sites could help to speed up the delivery of homes.

2.12 In this context, Policy S1 (6) outlines how non-strategic provision is made for small scale housing developments consistent with the indicative housing numbers set out in Policy H3, however this does not identify an approach to medium scale sites. Consequently, the Local Plan should allocate small and medium scale sites for residential development.

2.13 Should the Local Plan not allocate these scale sites, then there should be parcels within the BLDs identified as medium scale sites for early delivery in the plan period without prejudicing the BLDs. Policy S1 should be amended to include medium scale sites and to require flexibility to the housing target. This is discussed further in respect of Policy A13.

2.14 Policy S1 (7) states that strategic allocations and locations will be made through either this emerging Local Plan, the extant Site Allocation Development Plan 2014-2019 (or subsequent Site Allocation Development Plan Document (DPD)) and through Neighbourhood Plans. Notwithstanding the allocations in the emerging Local Plan, the most appropriate future mechanism is the Site Allocations DPD, which has to meet the ‘tests of soundness’ rather than ‘basic conditions’. This more rigorous approach to plan making is better able to address the site selection process and assessment of delivery requirements that a strategic allocation will need to demonstrate, particularly when taking account of the scale of growth proposed at Southbourne.

2.15 Lastly, the final paragraph of Policy S1 states that to ensure that the Plan’s housing requirement is delivered, “the distribution of development may need to be flexibly applied, within the overall context of seeking to ensure that the majority of new housing is developed in accordance with this Strategy”. The wording of this should be amended to state flexibility will be needed rather than may be needed, to ensure there is the ability to mitigate delays on allocations being brought forward by alternative proposals in order to meet the housing requirement over the plan period.

2.16 The use of the Authority Monitoring Report to control this is considered an acceptable approach, and policies A6 to A15 should reflect this requirement for flexibility. In practical terms, the LPA will need to consider performance in bringing forward and delivering large-scale development and enable alternative solutions where the required outcomes are not being achieved. This is discussed later in relation to Policy A13 specifically.
Policy S2: Settlement Hierarchy
2.17 The consultation document sets out a Settlement Hierarchy which is to serve as the framework for the Council to achieve its vision for the plan area, meet the scale of development required and enhance the quality of the built natural, historic, social and cultural environments, whilst sustaining the vitality of communities. This hierarchy seeks to deliver sustainable development that will support the role and function of different places within the plan area.

2.18 In this regard, Policy S2 is consistent with the NPPF acknowledging how “significant development should be focused on locations which are or can be made sustainable, through limiting the need to travel and offering a genuine choice of transport modes. This can help to reduce congestion and emissions, improve air quality and public health.” (paragraph 105 refers). The Settlement Hierarchy ensures that new development is located in areas where residents have access to facilities and services and a range of public transport networks.

2.19 Chichester city is identified as the Sub-Regional Centre, with four Settlement Hubs being identified at East Wittering/Bracklesham; Selsey; Southbourne and Tangmere. This is a continuation of the existing spatial strategy in the Adopted Local Plan and consistent with the principle of locating new development at the most sustainable locations.

2.20 Southbourne is rightly identified as a Settlement Hub due to its range of local services and facilities, key public transport connections and employment/educational opportunities accessible via non vehicular methods of travel. The approach to Southbourne is discussed later at Section 4 and at Policy A13.

2.21 Accordingly, this strategic policy is positively prepared and justified, and is consistent with national policy promoting sustainable patterns of development.

3 Overall amount of Housing

Policy H1 Meeting Housing Needs
Housing Need

3.1 Paragraphs 60 and 61 of the NPPF state that to determine the minimum number of homes needed, strategic policies should be informed by a local housing need assessment, conducted using the standard method in national planning guidance.

3.2 Only in exceptional circumstances could an alternative approach be justified. But even then, that alternative approach will also need to reflect current and future demographic trends and market signals.

3.3 Policy H1 identifies the need for the Plan to make provision for at least 10,350 dwellings within the plan period, amounting to 575dpa.

3.4 This is lower than both a. the standard method figure of 638 dpa; and, b. the Preferred Approach figure in the previous consultation, of 650 dpa which included accommodating some unmet need arising from the South Downs National Park (SDNP) area. This shortfall will amount to over 1,100 dwellings across the plan period. Without any Statements of Common Ground being published by the Council or evidence of the shortfall being accommodated elsewhere, this remains unaddressed.

3.5 It is highly germane that the current Local Plan adopted a lower housing figure than the identified need of 505dpa, proposing instead to deliver 435dpa.

Affordability in Chichester

3.6 The affordability ratios have risen from 12.38 in 2015, when the current Local Plan was adopted, to 14.61 in 2021 for Chichester, which is significantly higher than the current 9.1 national average, increasing the need for affordable housing within Chichester.

3.7 Between the 2011 and 2021 census, the number of people ages 50 to 64 years rose by over 3,100 (an increase of 13.4%), while the number of residents between 35 and 49 years fell by approximately 1,900 (8.5% decrease).

3.8 Chichester’s worsening affordability ratios and aging population, which typically occurs in line with house price increases, demonstrate the clear need to increase the housing delivery to meet current and future needs (in line with the NPPF), and maximise the potential for housing in this District. The current strategy to supress housing provision will only exacerbate these problems.

3.9 With the Submission Plan proposing to not meet the identified need, this once again will be an issue which moves onto the next Local Plan, failing to tackle key issues across the District such as affordability and lack of housing land supply. These issues cannot simply be moved onto the next Local Plan, they should be addressed now.

Constraints for development

3.10 The lower figure of 575dpa reflects both the infrastructure constraints along the A27 and at the


Waste Water Treatment Works, but also no longer accommodating unmet need from SDNP.

3.11 The Transport Study (January 2023) assesses the capacity levels, with particular focus on the A27. Although the Council state that 535dpa is the highest level of development per year achievable, the conclusions of this latest Study state, at paragraphs 5.6.5 and 11.2.3, that development of 700 dpa could be accommodated (in the southern plan area) through the mitigation proposed in the previous scenario of 535dpa with some additional mitigation at the Portfield and Oving roundabout.

3.12 This Transport Study (2023) was published following the preparation of the Sustainability Appraisal which refers to the 2018 study, therefore the latest evidence on highways matters has not be considered within the preparation of this Local Plan.

3.13 This is fundamental to the Plan’s approach – increasing the housing requirement could assist with funding those additional highway improvements, in line with the recommendations of the Transport Study at Section 9.3 to prioritise junctions to avoid delays to housing delivery. This should be further reviewed by the Council to ensure the District’s need is not being understated. It is recommended the housing need figure is reviewed in line with this evidence and the need to meet the minimum of the standard method figure of 638dpa, and aim to return to the 650dpa previously proposed.

Duty to Co-Operate

3.14 Paragraph 24 of the NPPF outlines the need for co-operation between local planning authorities on strategic matters that cross administrative boundaries.

3.15 The East Hampshire Local Plan Review has identified 100dpa for the SDNP area of the District, below the identified need of 112dpa for the District’s area and the overall requirement of 447dpa for the SDNP (Housing and Economic Development Needs Assessment 2017). In effect, in combination with Chichester, the National Park is needing to accommodate some 30 more dwellings per annum without any assessment as yet as to whether this can be achieved given the statutory protection that is afforded to it.

3.16 Whilst a Statement of Common Ground is referred to, it has not been published and therefore it is not possible to determine whether the decision not to make a provision for the National Park area is soundly based.

3.17 Previous evidence for the Preferred Approach demonstrated how the figure of 650dpa was achievable and necessary to help with the worsening affordability ratios across Chichester and the neighbouring authorities. Having removed provision for unmet need it is considered this plan has not been positively prepared.

Summary

3.18 Policy H1 clearly sets out how the majority of housing is to be delivered along the east-west corridor, with 535dpa in the southern plan area and 40dpa in the northern plan area. This is consistent with the Spatial Strategy and the Settlement Hierarchy, Policies S1 and S2, and the overarching objective of locating new housing at the most sustainable locations in the plan area.

3.19 By limiting the amount of housing there will be fewer schemes contributing to the required infrastructure improvements. Without developer contributions to fund wholescale upgrades to this infrastructure there is a risk of pushing the problem down the line for the next Local Plan to address, whilst problems with affordability and an aging population are further exacerbated.

3.20 All future schemes will be required to mitigate their impact on infrastructure including highways and utilities, and there is an opportunity for small to medium scale sites to be delivered in the short term whilst the larger allocations and/or the majority of the larger allocations await the upgrading of these works.

3.21 Currently, the proposal to reduce the overall housing supply for the new plan period is not supported, and the Council should review the Transport Study with the intention of meeting the assessed level of local housing need in full. Without the identified housing requirement being met in full the problem of the younger population being unable to afford to remain in Chichester will continue, further growing the gap in workforce and an increasingly aging population.

3.22 Therefore, this policy is not positively prepared, justified or consistent with the NPPF.

Policy H2 Strategic Locations/Allocations 2021-2039
3.23 The wording of ‘at least’ within Policy H1 provides flexibility on the ability to achieve the minimum amount of housing considered necessary by the Council, in line with Policy S2. Although this quantum is not agreed, the approach using ‘at least’ is considered a sensible approach to allow the achievement rather than under delivery of much needed open and market housing.

3.24 The strategic locations/allocations set out in Policy H2 do not reflect this flexible approach. Instead, the sites are fixed as exact number of dwellings for those locations.

3.25 Paragraph 119 of the NPPF requires planning policies to promote an effective use of land in meeting the need for homes, while safeguarding and improving the environment and ensuring safe and healthy living conditions.

3.26 Policy A13 is a BLD and is fixed at 1,050 dwellings within Policy H2, this does not allow for the masterplanning approach to further assess the actual capacity and the best use of this land.

3.27 As such flexibility should embedded into the wording of Policy H2 to ensure that the intention of Policy S2 is achieved; the housing target of at least 10,350 dwellings across the plan period (Policy H1) is met; and the land identified for development is most effectively used.

3.28 Therefore, it is suggested that Policy H2 includes the wording “at least” before the quantum of development for any strategic location or allocation. For example, Policy A13 would instead state “at least”.
Policy H8 Specialist accommodation for older people and those with specialised needs
3.29 National Planning Practice Guidance for Housing for Older and Disabled People states how plan- making authorities should set clear policies to address the housing needs for groups with particular needs such as older and disabled people.

3.30 The Housing and Economic Development Needs Assessment (HEDNA) (April 2022) assesses the period between 2021-2039 for older people and those with a disability.

3.31 This concludes that there will be a 42% increase in the population above 65 years old, amounting to 67% of the total population growth.

3.32 The HEDNA sets out how the East-West Corridor has a higher percentage of over 65 year olds (24.7%) compared to both Chichester City (24.2%) and the Plan Area North area (23.4%).

3.33 The needs arising from this, amounts to between 2,131 and 2,872 additional dwellings with support or care, and a need for 429-800 additional nursing and residential care bedspaces. This equates to approximately 17-24% of all homes needing to be some form of specialist accommodation for older people.

3.34 In this context, the HEDNA makes an important recommendation that the Council allocate specific sites for housing with care to ensure the identified needs are met. In contrast Policy H8 is a criteria based policy that seeks specialist accommodation for older people on housing sites over 200 units based on evidence of local need.

3.35 As written, there is no confirmation on the quantum of specialist accommodation that this policy or other site allocations will secure and how the specific need for each application is calculated. Policy H8 fails to address the identified overall need clearly, as required by National guidance. Therefore, it is recommended the Local Plan allocates sites to deliver this type of accommodation as intended by the HEDNA.

3.36 This approach risks the land on these sites being unable to deliver both the expected market/affordable housing and the specialist accommodation on site.

3.37 The land under Hallam’s control would be a suitable site for this type of accommodation, which is situated along the east-west corridor in a sustainable location on the edge of Southbourne.

4 Southbourne

4.1 Southbourne is a key area in the District, in terms of existing development, its status as a Settlement Hub and its potential to accommodate future development.
Role of Southbourne
4.2 Southbourne is identified as a Settlement Hub within Policy S2.

4.3 Southbourne is located within the east-west corridor with a range of existing facilities, good transport links, and employment opportunities both to the east and the west.

4.4 As set out in the Submission Plan, Southbourne has good access to educational facilities serving the residents, including primary schools, junior schools and secondary schools. There are a number of convenience stores and other community services and facilities such as a GP practice, pharmacy and places of worship.

4.5 The Bourne Community Leisure Centre provides local residents with access to community sports facilities. Access to public open space is also good through connections to Southbourne Recreation Ground. There is potential for more open space to be provided for local residents within the Local Plan Review and the strategic allocation proposed and this approach is embedded within our own Vision Document.

4.6 A key focus of the Sustainability Appraisal and the Submission Plan is for schemes to promote a modal shift in transportation. The strong public transport links within Southbourne to the wider surrounding area allows access to employment opportunities within the east-west corridor. Southbourne has strong public transport connections to the local and wider area, through bus and train services, to areas including: Chichester, Portsmouth, Havant, Littlehampton, Brighton, Southampton and London.

4.7 For these reasons, Southbourne is rightly designated as a Settlement Hub and is eminently suitable to serve as a BLD.

4.8 The Southbourne Level Crossing Report May 2021 analyses the options for delivering the railway crossing at Southbourne. It concludes that circa 750 dwellings can be delivered north of the railway line before triggering the requirement for a new crossing. The report highlights how sites south of the rail line are not likely to impact on the level crossing and can therefore be delivered earlier than await the railway line improvements.

4.9 Therefore, in this context it would be appropriate to allocate small and medium scale sites to the south of the railway, which is less constrained by the capacity restriction on the railway crossing.

4.10 The land under Hallam’s control is to the south of the railway line, would help facilitate a future new railway crossing to the north of the site, and would be of a medium scale to deliver housing early in the period plan.
Strategic Allocation A13
4.11 The Key Diagram appears to suggest that new development is to be located to the west and east of Southbourne, remedying the previously unsuccessful approach of focusing development only to the east. Similarly, the Key Diagram acknowledges the need for development to the south of the railway line, facilitating development north of the railway line. It is recommended the wording of the policy should be updated to reflect this diagram, as suggested below:

Provision will be made for a mixed use development within the broad location for development to the west and east of Southbourne, as shown on the Key Diagram.
4.12 Previously, the Preferred Approach consultation document set out at Policy AL13 a minimum of 1,250 dwellings at Southbourne and to be identified in the revised Southborne Neighbourhood Plan. (emphasis added)

4.13 The Submission Plan now allocates Policy A13 for 1,050 dwellings and will be established through the making of allocation(s) in the future Site Allocation DPD or the revised Southbourne NP. This strategic allocation is to act as a mixed use extension to the existing settlement.

4.14 It is acknowledged that the land north of Cooks Lane (Application number: 22/00157/REM) received Reserved Matters approval in August 2022 for 199 dwellings, with the reduction in quantum of development for the BLD reflecting this committed development. A practical effect of this is that this consent will not contribute to the wider infrastructure requirements associated with a larger scale of development.

4.15 It is disappointing to see the phrase “a minimum of” has been removed. This conflicts with the flexibility set out earlier in the consultation document, and also reduces the potential of making effective use of the land for housing that will assist in meeting the overall need of the District.

4.16 Policy A13 prescribes a number of requirements that must be met (criterion 1 – 16). These are considerations that reflect principles of place making and sustainable development and provide a sound framework for the preparation of the allocation through either mechanism.

4.17 One of these requirements states that future development “Provide[s] any required mitigation to ensure there is no adverse impact on the safety of existing or planned railway crossings.” The existing Southbourne Neighbourhood Plan, at Objective 9, outlines the issues relating to the railway crossing and the plans for addressing this challenge in the future.

4.18 Related to this is the need for the provision of “suitable means of access to the site(s), securing necessary off-site improvements (including highways) … to promote sustainable transport options.”

4.19 The combination of the requirements relating to the railway crossing and the provision of a suitable means of access show the importance of accessibility to the A27, A259 and the east-west railway line, which are the principal public transport corridors for Southbourne.

4.20 Development will be well connected to Southbourne via footway and cycle connections to the east and offers the opportunity to help realise the construction of a new strategic road and bridge link over the West Coastway Rail Line through provision of land and proportionate contributions to this scheme.

4.21 Criteria 13 ensures there will be sufficient capacity within the relevant wastewater infrastructure before the delivery of development, which addresses (for Southbourne) the identified constraints for the District in relation to housing delivery.

4.22 The remaining requirements of Policy A13 cover the quality and range of development, the provision of education, community and transport facilities, provision of public open space and green infrastructure, and the impact of development on the landscape. These are each appropriate considerations for the Site Allocations DPD.

4.23 Having regard to the above, the allocation of 1,050 dwellings for Southbourne is, in part, appropriate.

4.24 However, this policy should allow for the delivery of small or medium scale parcels of land, in accordance with the NPPF at an early stage of delivery of the wider allocation to enable prompt and timely housing at Southbourne whilst infrastructure upgrades are commenced. The Local Plan should identify and allocate these smaller scale sites to ensure these can come forward early in the plan period.

4.25 A new criteria is proposed to be included in the wording of Policy A13, stating:

(17) To identify land for early delivery on small to medium scale sites which are not constrained by the need for a new railway crossing.
4.26 Therefore, the principle of a strategic allocation for mixed use housing is considered appropriate but amendments should be made to the wording of the policy to reflect the approach to flexibility, the inclusion of small and medium scale sites, and the dispersion of development to both the west and east of Southbourne.
Southbourne Neighbourhood Plan
4.27 As set out in the paragraph 10.56 of the Submission Plan, development phasing is a key issue to address through the allocation of development sites for this BLD.

4.28 Paragraph 70 of the NPPF states that “Neighbourhood planning groups should also consider the opportunities for allocating small and medium-sized sites suitable for housing in their area.” Southbourne Parish Council should be aware of this when allocating the strategic sites, to ensure that there are a mix of housing sites, that could come forward sooner than the principal element of the larger strategic site.

4.29 Through the preparation of the Neighbourhood Plan, the Parish Council should take into account the allocation of smaller sites, which could come forward as part of and alongside the larger strategic site. This will ensure that there is not a delay in the provision of housing within Southbourne and the plan area.

4.30 As set out previously, the most suitable mechanism for progressing the Southbourne BLD would be the Site Allocation DPD. Whether the sites are allocated through the Site Allocations DPD or the NP, there is a requirement to identify small and medium scale site.
Land to the north of Gosden Green
4.31 The land under Hallam’s control to the north of Gosden Green, should either be allocated in the Local Plan as a medium scale site or should be a key component of the BLD. The site can deliver both market/affordable residential units and specialist elderly accommodation. The site will create flexibility in achieving the housing requirement of the plan area early on in the plan period.

4.32 The accompanying Vision Document demonstrates how as an early development parcel for the wider BLD, a series of key benefits in accordance with the 13 criteria of Policy A13 will be achieved.

4.33 The Proposed Submission Plan at Policy H8 identifies the need for specialist accommodation for older people and those with specialist needs. Although not set out in the Vision Document, this site can deliver, early in the plan period, much needed specialist elderly accommodation.

4.34 Figure 3 of the Vision Document presents the scheme’s ability to connect into a wider masterplan for the strategic development, as it comes forward in the future. However, at the same time has the ability to come forward at an earlier rate being physically unconstrained and a well contained parcel of land.

4.35 Figure 9 provides context on connectivity, and the modal shift this scheme aims to achieve. The ability to walk to a range of services and facilities, including the train station further demonstrates the ability for the early delivery of this parcel of the BLD.

4.36 The impact of the highways network has been assessed for both a full residential scheme and specialist elderly housing, highlighting how the residential scheme will introduce approximately 55 new vehicles to the network at peak times, resulting in less than 1 car per minute in the peak hour. Either scheme will have a negligible impact on the highway network and would have a negligible impact on A27.

4.37 The site is to the south of the railway line, as previously mentioned, and would be unconstrained by the capacity constraint of the existing railway crossing.

4.38 For these reasons, the land under Hallam’s control should be allocated within the Local Plan.

5 Conclusion
5.1 These representations are submitted on behalf of Hallam Land Management Limited.

5.2 In the context of national, local and neighbourhood planning policies, the Local Plan has an important role in providing policies and proposals for residential development to meet future needs.

5.3 The proposed objectively assessed need for housing across the plan area is not agreed, and the Council should review the latest transport evidence which currently do not demonstrate how there are exception circumstances, in accordance with paragraph 62 of the NPPF. The Council should also extend the plan period to ensure it meets the requirements of a minimum of 15 years in the NPPF.

5.4 Consistent with the established strategy to focus development in the District’s east-west corridor, the Broad Location for Development to Southbourne as a Settlement Hub is, as a matter of principle, a sound proposition. Importantly the Key Diagram identifies the broad location for this development to the west and east of the settlement.

5.5 As discussed, there should be flexibility embedded into all strategic allocations, in particular those which are Broad Locations for Development through the use of the wording “at least”. This will ensure that the “at least” quantum of housing delivery is met and affords flexibility to all housing sites coming forward.

5.6 The responsibility for allocating additional development land to meet this requirement has been given to either the Parish Council through the preparation of a new Neighbourhood Plan or through the Council reviewing the Site Allocations DPD. It is recommended that for the larger strategic allocations and locations the Site Allocations DPD is the more suitable mechanism for identifying land given the need to ensure that proposals are sound.

5.7 Whilst the scale of development proposed is strategic in nature, it is entirely appropriate to consider how different development parcels might contribute towards that and in particular early opportunities that facilitate larger scale development later in the plan period.

5.8 To this end, land to the west of Southbourne and south of the railway line could be allocated as the first phase of the strategic site allocation, as a medium size site, so that this southern section of the new link road is built to enable access to land to the north. This will reduce the pressure placed on the centre of Southbourne, the highway capacity on the A27, and the existing railway crossing.

5.9 By allocating small to medium scale sites in the Local Plan, this will bring forward development at a quicker pace and ensure that the objectively assessed needs for housing across the plan area are met each year. These can be delivered without prejudice to the larger strategic allocations and locations.

5.10 Currently, the Submission Plan fails to address the increasing need for specialist accommodation, with Policy H8 failing to secure specific delivery of such housing, instead moving this matter into major development schemes with no mechanism for assessing need at that stage. It is recommended that the Local Plan allocates sites for specialist accommodation.

5.11 Hallam control land to the west of Southbourne, which adjoins the land at Gosden Green which has already been built. The land controlled by Hallam could be: allocated as a medium scale site within the Local Plan; included as part of the western strategic allocation of Broad Location for Development at Southbourne; or could be allocated for specialist elderly accommodation, ensuring land is readily available for development early in the plan period to address identified needs.

5.12 This would be consistent with the development strategy for the Plan and positively contribute towards meeting future development needs of the plan area.

5.13 These representations have demonstrated that in part the Submission Plan has been positively prepared and justified, however the key recommendations in these Representations should be followed to ensure the plan preparation accords with Paragraph 35 of the NPPF.

Policy NE4 should state which plans confirm the boundaries of the Wildlife Corridors. Local Plan Map 4a needs amending to show a larger area for the Nutbourne to Hambrook Wildlife Corridor.

See representations attached.

H11, H13, H14 - It has not been possible to consult the community in Southbourne to obtain a view on these policies in the time allotted. This places the Parish Council in a difficult position. However, 12 new pitches and 12 new plots is a considerable number to accommodate in addition to those already occupied within the parish and therefore it is considered appropriate to raise objection unless the District Council can provide sufficient assurances about the location and proposed management of these sites.
H12 – The site identified as Sunrise in the Local Plan is already fully occupied. This includes the controversial encroachment, reinforced by two meter high boundary fencing, over a significant length of a Public Right of Way (Footpath 212), which now follows an unpleasant confined route adjacent to the correct route. In addition, an unauthorised park home dwelling has been recently located over the original route of the Public Right of Way. There is no room for a further pitch. It appears that the District Council is attempting to use this proposal to regularise unauthorised development, which is not acceptable. It is strongly recommended that the Inspector visits this site and that the proposal at Sunrise is deleted from the Local Plan.

See representations attached.

SUMMARY Para. 2.4 is correct, but para. 2.5 states that the number has “been reduced to 1050 dwellings to reflect the proportionate reduction in housing numbers across the parishes in the east west corridor as a consequence of the limit on numbers in the southern plan area.” This should be amended to read “…………..been reduced to 1050 dwellings due to an exception made by the District Council to take account of a planning permission for 199 dwellings at Cooks Lane granted in 2020.”

See representations attached.

It is strongly recommended that the Inspector visits the site at Sunrise in Southbourne and that the proposal at Sunrise is deleted from the Local Plan (see response to Policy H12).

See representations attached.

We have reviewed the publicly available Local Plan documents and provided comments in the attached letter, in relation to the transport implications of the plan for the safety and operation of the SRN.
Our comments include issues to resolve, comments, requests for further information and recommendations. A brief summary of our main comments are:
- the reliance on the delivery of the A27 Chichester bypass improvements project.
- the requirements for new, additional, and adapted processes and assessments, especially in assessing Transport Assessments, mandating Travel Plans and monitoring traffic associated with new developments.
- collaborative working between agencies in combination with a robust monitor and manage policy.
We hope our comments assist.
To date National Highways have worked collaboratively with Chichester District Council (the Council) and West Sussex County Council (WSCC) and we will continue to work with the Council and other key stakeholders. We look forward to continuing to participate in future consultations and discussions.
Once you have had the opportunity to digest all the representations received, we would welcome a meeting to run through all the transport related matters and agree how to progress any required evidence gathering or other work.

Background

National Highways has been appointed by the Secretary of State for Transport as strategic highway company under the provisions of the Infrastructure Act 2015 and is the highway authority, traffic authority and street authority for the strategic road network (SRN).

National Highways is responsible for operating, maintaining, and improving the Strategic Road Network (SRN) i.e., the Trunk Road and Motorway Network in England, as laid down in Department for Transport (DfT) Circular 01/2022 (Strategic Road Network and the delivery of sustainable development).

The SRN is a critical national asset and as such we work to ensure that it operates and is managed in the public interest, both in respect of current activities and needs as well as in providing effective stewardship of its long-term operation and integrity.

Our responses to Local Plan consultations are guided by relevant policy and guidance including the National Planning Policy Framework (2021) (NPPF):

• Transport issues should be considered from the earliest stages of plan-making and development proposals so that the potential impact of development on transport networks can be addressed (para 104).

• The planning system should actively manage patterns of growth such that significant development is focused on locations which are or can be made sustainable, through limiting the need to travel and offering a genuine choice of transport modes. (para 105).

• Planning policies should be prepared with the active involvement of highways authorities and other transport infrastructure providers so that strategies and investments for supporting sustainable transport and development patterns are aligned. (para 106).

• In terms of identifying the necessity of transport infrastructure, NPPF confirms that development should only be prevented or refused on highways grounds if there would be an unacceptable impact on highway safety, or the residual cumulative impacts on the road network would be severe. (para 111).

• Planning policies and decisions should support development that makes efficient use of land, taking into account the availability and capacity of infrastructure and services – both existing and proposed – as well as their potential for further improvement and the scope to promote sustainable travel modes that limit future car use. (para 124).

In relation to the tests of soundness set out at paragraph 35 of the NPPF, in the context of transport, these are interpreted as meaning:

a) Positively prepared - has the transport strategy been prepared with the active involvement of the highway authorities, other transport infrastructure providers and operators and neighbouring councils?
b) Justified – Is the transport strategy based on a robust evidence base prepared with the agreement in partnership, or with the support of the highway authorities?
c) Effective – Does the transport strategy and policy satisfy the transport needs of the plan and is it deliverable at a pace which provides for and accommodates the proposed progress and implementation of the plan?
d) Consistent with national policy – Does the transport strategy support the economic, social, and environmental objectives of the Plan and the NPPF/NPPG?

We will be concerned with proposals that have the potential to impact on the safe and efficient operation of the SRN; in this case, the A27 trunk road (Chichester Bypass and its junctions) which is the main access route in the Chichester area. We have particular interest in any allocation, policy or proposals which could have implications for the A27 and the wider SRN network. We are interested as to whether there would be any adverse road safety or operational implications for the SRN. The latter would include a material increase in queueing or delay or reduction in journey time reliability during the construction or operation of the development set out in the plan.

National Highways is a key delivery partner for sustainable development promoted through the plan-led system, and as a statutory consultee we have a duty to cooperate with local authorities to support the preparation and implementation of development plan documents.

In accordance with national planning and transport policy and our operating licence, we are entirely neutral on the principle of development as it is for the local planning authority to determine whether development should be allocated or permitted; albeit it must comply with national policy on locating development in locations that are or can be made sustainable. Therefore, while always seeking early and fulsome engagement with local plans and/or developers, we will simply be assessing the transport and related implications of plans or proposals and agreeing any necessary transport improvements and relevant development management policy.

In progressing Local Plans, we will seek to agree the following:
• Assessment tools and methodology
• Baseline Assessment i.e., to demonstrate that the assessment tool accurately reflects current transport conditions
• Comparator case assessment i.e., to forecast the transport conditions that would occur in the absence of the plan
• Forecast modelling i.e., to forecast the transport conditions that would arise with the plan in place, this will include an assessment at the end of the Plan period; and, if required, at full build out if that occurs after the end of the Plan period
• Outputs and outcomes of modelling, demonstrating, as appropriate, what transport infrastructure is necessary to support the plan o It should be noted that a suite of transport modelling tools may be required. This includes strategic modelling covering an area at least one major junction beyond the district boundary, localised network modelling where several links/junctions are close together and/or individual junction modelling
o A DMRB (Design Manual for Roads and Bridges) compliancy assessment may also be required for certain highway features, such as
Merge/Diverge assessment at Grade separated junctions, link capacity assessments, and others.
• The design of any necessary transport infrastructure, to an extent suitable for establishing deliverability during the plan period at the time that it becomes necessary for the purpose of ensuring that unacceptable road safety impacts or severe operational impacts do not arise as a result of development. This may be to at least General Arrangement design stage or preliminary design stage. Whichever degree of detail is agreed, the products must be in full compliance with the DMRB.
• Industry standard transport intervention costings.
• The delivery/funding mechanisms for necessary transport interventions. It should not be assumed that National Highways will have any responsibility to identify or deliver necessary transport interventions.
• If considered appropriate, a “Monitor & Manage” (M&M) framework, aimed at managing the pace of development in line with the pace of funding and delivery of necessary highway interventions in a manner which responds to the realworld impacts of development may be agreed for inclusion in the plan subject to the adequacy of risk control measures included therein. This can include the move from a ‘predict & provide’ style of delivery to ‘a vision & validate’ style. o Any M&M framework must be based on a “worst case scenario” whereby necessary mitigation is understood, as well as setting out the desired alternative scenario. It must set out details of responsibility, funding and governance of the framework together with the methodology for determining the timing for any mitigation delivery while remaining clear on the fallback position where identified mitigation or desired alternatives are not ultimately achievable. It must be translated into development management plan policy and policy relating to development allocations.

Further detail on the above can be provided by National Highways.

While ideally all the above should be agreed prior to the Submission of the Local Plan for examination, we recognise that this is not always possible. However, all parties should work towards all matters being agreed and reflected in a Statement of Common Ground (SoCG) by the start of the Local Plan Examination at the latest. Ideally the SoCG between the Council and National Highways would be prepared well in advance of plan submission in order to guide resource input and to track progress towards final agreement on all relevant matters starting from the earliest plan iterations until the final version is agreed.

It is acknowledged that Government policy places much emphasis on housing delivery as a means for ensuring economic growth and addressing the current national shortage of housing. The NPPF is very clear that:
“Strategic policy-making authorities should establish a housing requirement figure for their whole area, which shows the extent to which their identified housing need (and any needs that cannot be met within neighbouring areas) can be met over the plan period.”

However, new DfT C1/22 and the NPPF are equally clear that any development, including housing delivery, must be tempered by the requirement to ensure that the associated transport demand can be accommodated without unacceptable impacts on the safety of the SRN or severe impacts on the operation of the SRN including reliability and congestion. Therefore, as necessary and appropriate, any plan and/or development must be accompanied by suitable mitigation in the right places at the right time, that is to the required design standards and is deliverable in terms of land availability, constructability and funding.

We would also draw your attention to the then Highways England document ‘The Strategic Road Network, Planning for the Future: A guide to working with National
Highways on planning matters’ (September 2015). This document sets out how National Highways intends to work with local planning authorities and developers to support the preparation of sound documents which enable the delivery of sustainable development. https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachmen t_data/file/461023/N150227_-_Highways_England_Planning_Document_FINAL-lo.pdf

Responses to Local Plan consultations are also guided by National Planning Policy Framework (NPPF) revised on 20 July 2021 which sets out the government’s planning policies for England and how these are expected to be applied.

Updated Circular (01/2022)
It should be noted that since the start of the Local Plan consultation process, on the 23 December 2022, the Department for Transport released a new circular on the ‘Strategic road network and the delivery of sustainable development’ (Circular 01/2022), which replaces all of the policies in Circular 02/2013 of the same name. These representations take account of the new circular and the requirements in terms of the Local Plan evidence base and process.

We request that the Local Plan is prepared in line with all aspects of the new circular. Particularly, the principles of sustainable development (paragraphs 11 to 17), new connections and capacity enhancements (paragraphs 18 to 25), and engagement with plan-making (paragraphs 26 to 38).

Regulation 18 submission
In our Regulation 18 submission we noted several matters including:
• The need to mitigate the adverse impacts of strategic development traffic to the A27 Chichester Bypass and its junctions at Portfield Roundabout, Bognor Road Roundabout, Whyke Roundabout, Stockbridge Roundabout and Fishbourne Roundabout and Oving junction.
• The need to identify a mechanism to calculate contributions towards the delivery of the previously agreed Local Plan A27 improvements
• The need to confirm the number of dwellings needed within the plan period
• The need to establish National Highways acceptance of the traffic model reference and future case scenarios
• The need to confirm costs, viability, and funding associated with mitigating the safety and congestion impacts of the development included within the plan.

Local Plan context
This Local Plan (Chichester Local Plan 2021 – 2039), prepared by the Local Planning Authority (LPA) Chichester District Council, sets out the vision for future development in the district and will be used to help decide on planning applications and other planning related decisions including shaping infrastructure investments.

The draft sets out how the district should be developed over the next 18-years to 2039 including for the full Plan period (1 April 2021 to 31 March 2039) the total supply of
- 10,359 dwellings
- 114,652 net additional sqm new floorspace
Minus the completions this is equivalent to around 530 dwellings and 6,150 sqm of floorspace a year.

National Highways Representations
To date National Highways have worked collaboratively with Chichester District Council (the Council) and West Sussex County Council (WSCC) and we will continue to work with the Council and other key stakeholders.

We have undertaken a review of the Chichester Local Plan 2021-2039 proposed submission version and accompanying evidence documents, our comments are set out in the tables below (following pages). [see table within attachment]

Summary

We have reviewed the publicly available Local Plan documents and provided comments above in relation to the transport implications of the plan for the safety and operation of the SRN. We understand that other technical information is available, but this was not presented as part of this consultation.
Chichester, and the A27, are already heavily congested, infrastructure in the existing Local Plan remains undelivered and the growth set out in the new Plan will further increase travel demand.
As presented, satisfying the transport needs of the plan is clearly reliant on the delivery of the A27 Chichester bypass improvements project. The A27 Chichester bypass improvements project is one of 32 pipeline schemes being considered for possible inclusion in National Highways third Road Investment Strategy (RIS3) covering 1 April 2025 to 31 March 2030.
On 9 March 2023 the UK Transport Secretary ensured record funding would be invested in the country’s transport network, sustainably driving growth across the country while managing the pressures of inflation. The announcement cited the A27 Arundel Bypass as being deferred from RIS2 to RIS 3 (covering 2025-2030). The transport secretary also identified a number of challenges to the delivery of the road investment strategy and cited the benefit of allowing extra time to ensure schemes are better planned and efficient schemes can be deployed more effectively.
At present, there is no commitment by DfT to carry out the A27 Chichester bypass improvements project. Until the A27 Chichester bypass improvements project is published in the RIS3, consented and a decision to invest is made it cannot be assumed to be a committed project.
We note that the Plan does not address any uncertainty of delivery of the A27 Chichester bypass improvements project and we strongly recommend that there is either no reliance placed on RIS3 to realise capacity for growth in the Plan or that contingency measures are included to cover the eventuality that RIS3 funding is not forthcoming within the plan period. It is not clear that the potential impact of development on transport networks can be addressed in the absence of the A27 Chichester bypass improvements project.
Achieving net zero, reducing emissions reduction, acting on climate, and supporting thousands of new homes and new employment developments will be problematic with existing processes. New, additional, and adapted processes and assessments will likely be required, especially in assessing Transport Assessments, mandating Travel Plans and monitoring traffic associated with new developments. We acknowledge that change is complex, expensive, and time-consuming, especially for smaller district level Councils. But the hard work will deliver benefits for the Council and residents in the longer-term.
National Highways seeks to continue working with the Council and WSCC to progress coordinated and deliverable packages of interim mitigation measures and alternative transport solutions while a long-term strategic solution is considered by government. This must however be in combination with a robust monitor and manage policy that appropriately manages the risk of unacceptable road impacts resulting from new housing
and other development over the Plan period.

We have been in discussion with Chichester District Council regarding their proposed Monitor and Manage Strategy. At present, we do not consider the current strategy to be robust and we seek further information and detail especially on who, when and when monitoring and management will be undertaken. Developments in the right places and served by the right sustainable infrastructure delivered alongside or ahead of occupancy must be a key consideration when planning for growth in all local authority areas. Any M&M framework must be based on a “worst case scenario” whereby necessary transport mitigation is understood, as well as setting out the desired alternative scenario. It must set out details of responsibility, funding and governance of the framework together with the methodology for determining the timing for any mitigation delivery while remaining clear on the fallback position where identified mitigation or desired alternatives are not ultimately achievable. The M&M framework must set out that the alternative to mitigation not being delivered is that development does not proceed where that development would give rise to unacceptable road safety risk or severe cumulative impacts on the road network in the absence of that mitigation. The M&M framework must be translated into development management plan policy and policy relating to development allocations.
As we have reiterated throughout our comments, we welcome the opportunity to work with you to address these outstanding matters and we will continue to liaise over submitted Transport Assessment, Travel Plan policy and Monitor and Manage Policy to help to work towards a viable plan.
We hope our comments assist.
We look forward to continuing to participate in future consultations and discussions. Please do continue to consult us as the Plan progresses so that we can remain aware of, and comment as required on, its contents.
Once you have had the opportunity to digest all the representations received, we would welcome a meeting to run through all the transport related matters and agree how to progress any required evidence gathering or other work.

We consider that the council should be less reliant on major strategic allocations and look to allocate a range of additional small, medium, and large sites to provide a more flexible, responsive, and deliverable range of allocations. As recognised above, such an approach is encouraged at Paragraph 69 of the National Planning Policy Framework which acknowledges that small and medium sized sites can make an important contribution to meeting the housing requirement of an area and are often built-out relatively quickly.

By allocating more sites for housing development, the Council will bolster their housing land supply. Through the allocation of more sustainable sites in service villages, the Council will provide support for the rural, northern area of the district. We therefore encourage the Council to review their site allocations in line with their spatial strategy and together with the policy requirements of Policy H3 to ensure they are planning for the right homes in the right places over the plan period and beyond.

Summary

Southern Planning Practice Ltd are instructed by the landowner to submit representations to the Proposed Submission version of the Chichester Local Plan 2021- 2039, published in February 2023. Shorewood Homes, a local developer, have an interest in land at Champions Farm, Wisborough Green and are currently working collaboratively with the landowner.

The site is located to the south of Newpound Lane and to the north of Billingshurst Road (A272) in Wisborough Green. The site is located within the northern area of the district and is closely related to the main urban area of Billingshurst, which is located in the neighbouring authority Horsham District Council.

It is understood that the site has not been previously promoted through the Local Plan process. We can confirm on behalf of our client that the site is now available for development.

In order for the Proposed Submission Local Plan to meet the ‘positively prepared’ test of soundness as required by paragraph 35 a) of the National Planning Policy Framework (NPPF), the Local Plan Review must:

“provide (ing) a strategy which, as a minimum, seeks to meet the area’s objectively assessed needs; and is informed by agreements with other authorities, so that unmet need from neighbouring areas is accommodated where it is practical to do so and is consistent with achieving sustainable development”.

Whilst the constraints of the northern area of the district are appreciated, there are several sustainable sites, outside of the National Park and other constrained landscapes, which would assist Chichester to meet their identified housing needs. One such site is the land at Champions Farm in Wisborough Green. The western section of the site could be delivered in the short-medium term and the eastern section could be delivered in the longer term which would contribute to Chichester’s future housing supply.

Any new residential development on land at Champions Farm would contribute to the achievement of the 7 strategic objectives of the Local Plan and would also help to boost the housing supply in the short-medium term.

Executive Summary

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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