Policy A20 Land South of Bognor Road

Employment land provision should be achieved through the allocation of more, smaller, sites to improve the chances of delivery and to meet market demand which is immediate (as evidenced by the Housing and Economic Development Needs Assessment [April 2022] and the accompanying Flude Market Report [July 2022]).

These representations are specifically centred around Chapter 7: Employment and Economy – ‘Meeting Business and Employment Needs’ with particular focus on Policy E1, Map 10.10 and reliance on Chapter 10 Policy A20 (Land to the South of Bognor Road).

These representations are made in the light of a live planning application (22/02202/FUL) for Land North Of Drayton Waterside. The proposed development consists of the erection of employment space [flexible Class B2 (general industry), B8 (storage / distribution), Trade Counter, E(d) (indoor sport / recreation) and Class E(g) (office, research and development, light industry) uses], with associated parking and landscaping. The employment space is provided over 33 units totalling 5,706 sq. m.

These representations will also look in detail at the Countryside policy and compare the proposed single new site (Land to the South of Bognor Road) with a site which is currently subject to a pending planning application (22/02202/FUL) for land which is geographically comparable with the proposed single site only without the implementation issues listed in the proposed Local Plan, as well as being deliverable, achievable and focused on the market requirements for smaller units.

These representations bring into question the ‘tests of soundness’. In particular, the question as to whether it is ‘sound’ on the basis of being ‘positively prepared’, ‘justified’ and ‘effective’ in respect to employment land provision.

These representations seek to highlight that Chapter 7 has not been positively prepared, in so far as it does not provide [1.] “a strategy which, as a minimum, seeks to meet the area’s objectively assessed needs” see the details set out in the accompanying Flude Property Consultants Report together with the details set out below.

It is also considered that Chapter 7 is not justified as the employment strategy is [2.] is inappropriate as it relies on a single new site, with multiple issues some of which are in conflict with other parts of the local plan, plus the site does not appear to have been included in the previous Local Plan consultations.

Chapter 7 is also not justified with respect to its provisions do not [3.] take into account reasonable alternatives. And that the provision for a single site not previously seen in any Regulation 18 consultation, is not [4.] based on proportionate evidence.

With respect to whether Chapter 7 is effective is questionable in terms of soundness given that the proposed allocation highlights a number of issues with the site set out in more detail below.

It is considered on the basis of the other factors highlighted in these representations and the accompanying Flude Report that the proposed employment land provision is not ‘Consistent with national policy’ as the proposed provision does not enable the delivery of sustainable development. It is considered that the proposed plans are contrary to the NPPF paragraph 16a, 16b, 16c, 16d and paragraph 20a.

With respect of general employment allocations and provisions in Chichester there are a number of areas of concern raised below and in the accompanying Flude Property Consultants Report which looks in detail at the Chichester property market.
It is also relevant to note that the Flude Report (dated July 2022) not only assesses the supply and demand in the local market for employment land, it objectively assesses the most recent evidence set out by the Local Planning Authority within the April 2022 Chichester Housing and Economic Development Needs Assessment (HEDNA).
Both the HEDNA and Flude Report independently advise that there is a lack of suitable employment space supply in Chichester, particularly for starter units between 750 and 2000 sq. ft.
The Policy E1 table sets out a number of floorspace calculations. None of which are identified by their Use Class.
Land West of Chichester
This site is a reallocation of the current Local Plan Policy 15. The new policy is Policy A6. The original allocation was adopted in 2015 and this therefore raises concerns in respect of deliverability of the proposed employment floorspace.
Notwithstanding the concerns around deliverability, the uses identified in the ‘submission local plan’ Policy A6 states: “6 hectares of employment land (suitable for E(g)(i)/(ii) Business uses)” and therefore none of the suggested 22,000m2 allocation equates to light industrial, general industrial or storage and distribution (i.e. it does not include E(g)(iii), B2 or B8) and therefore does not meet any need for industrial or storage and distribution.


Kingsham Road - DPD Allocation
This site the current DPD allocation (Policy CC5). The allocation was adopted in 2019 and this therefore raises concerns in respect of deliverability of the proposed employment floorspace.
Kingsham Road is a DPD allocation for 7,200m2 is for office use, and therefore does not meet any need for industrial or storage and distribution.


Land South of Bognor Road
The Land South of Bognor Road, the single proposed new allocation, not previously set out in the previous Local Plan consultations is looked at in greater detail in the following section of these representations.


Planning Permissions to Date
Chichester Council Planning Policy team have kindly provided a copy of the employment planning permissions to date which make up the 53,655 figure within the employment floorspace Policy E1. From a review of these sites it is apparent that a large number are for specific end users (e.g. Rolls Royce) or for change of use and not for the open market which will not meet the employment floorspace demand locally, particularly for starter units for SME’s.


Summary
In summary, Policy E1 is heavily reliant on adding up floor spaces which either may not occur or are not for an employment use which meets the needs for industrial use or storage and distribution use needs.

There are several fundamental issues with the proposed site allocation known as Land to South of Bognor Road (Policy A20), these include:
- The site is new to the Local Plan production process in respect of entering in at Regulation 19 and has therefore not been through any of the previous rounds of consultation.
- The he land is Grade 1 agricultural land which is (a) in active use, (b) forms part of wider farmland which is proposed to be separated from the farm buildings therefore potentially limiting the effectiveness of the remainder of the farmland, (c) it conflicts with other parts of the local plan which promote protection of the best agricultural land and food production. (details below)
- There are several site constraints to delivery to the allocation (details below).
- The Policy also seeks to provide plots for Gypsy and Travelling Showpeople the allocations do not require to be part of the same site however they have been placed under the same site policy which implies that the provision for both types of use are in short supply and that the way in which the Local Plan has been produced seeks to address the Gypsy and Traveller sites shortfall on the same allocation as part of the solitary site for employment.
- The size of the site in terms with respect to Natural England’s Guide to assessing development proposals on agricultural land (2021).

The Land South of Bognor Road site is both grade 1 agricultural land (the best value) and in active food production. Development on this site would raise conflict with other Local Plan approaches and policies as follows.
The proposed Local Plan at Paragraph 4.8 states that: The council will seek to protect the best and most versatile agricultural land from large scale, inappropriate or unsustainable non-agricultural development proposals that are not in accordance with the Development Plan. For proposals not in accordance with the Development Plan, that will result in the loss or likely cumulative loss of 20 hectares or more of best and most versatile agricultural land, the council will consult with Natural England and have regard to “Natural England’s Guide to assessing development proposals on agricultural land (2021)” and any subsequent guidance.

It is noteworthy to mention that the site is 19.5ha and, as with neighbouring land, is owned by West Sussex County Council (WSCC). The outline of the site allocation is odd and appears to sever the remainder of the WSCC land to the south from the WSCC owned land. This both impacts the opportunity to farm the remaining land and raises the question of whether there is an approach to avoid Natural England’s 20ha threshold and therefore is the current site area a salami slice of an extended future land promotion.

Land south of Bognor Road - Policy A20 – Site Constraints impacting Delivery


Flood Risk
Policy A20 supporting text paragraph 10.87 outlines that parts of the site are at risk of surface and ground water flooding which would need careful management.
Landscape Impact
The large scale of the site will create a landscape impact that could be considered harmful to the current landscape character and separation between the main conurbation of Chichester and the built form around the Bognor Road/Drayton Lane roundabout. This is further discussed in the Countryside policy assessment below.
Highways
To facilitate development of Policy A20 the supporting text paragraph 10.87 identifies the need for realignment of Vinnetrow Road and works to the Bognor Road roundabout as part of a package of A27 improvements. It is understood that Highways England have pulled funding for these improvements and that they are to be delivered through a tariff on strategic sites. Therefore, the delivery of this site is reliant on the delivery of other strategic sites and raises concerns around timescales and deliverability.

A planning application (22/02202/FUL) for the construction of business park with associated parking and landscaping is currently pending determination for land north of Drayton Waterside A259 Eastbound Merston Oving. The application is pending further highway research but is supported by no objections from all other consultees including support from the economic development officer and the Oving Parish Council.

The Economic Development Officer comment on the Planning Application is as follows:
‘The application site sits directly adjacent to a current business site and will provide units of the size and use class type that are highly sought after in the district. B2 and B8 uses are especially sought after and the amount of available space in this area has dropped from 316,000 sqft in 2017 to 97,500 sqft n 2022 (Source: SHW Industrial Focus 2022) which is a drop of almost 70% in five years.’
Both the HEDNA (April 2022) and Flude Report (July 2022) independently advise that there is a lack of suitable employment space supply in Chichester, particularly for starter units between 750 and 2000 sqft. The proposed development at Drayton Waterside provides this type of employment space and given the current planning application status could provide this floorspace immediately.
In the Housing and Employment Land Availability Assessment (HELAA) 2021, Drayton Waterside and the proposed allocation, Land to the South of Bognor Road, are both considered ‘developable’ but it is noteworthy to mention that Drayton Waterside (HELAA ID HOV00011) is considered to be able to come forward sooner than the land South of Bognor Road (HELAA ID HNM0017a).

Development in the Countryside Policy (Policy NE10)

Following review of the Drayton Waterside site above a key consideration is its location within the countryside – draft Local Plan Policy NE10. These representations do not directly object to this policy or its wording but some text is included to comment on how the Drayton Waterside site is better aligned with the countryside policy than the proposed land south of Bognor Road allocation (Policy A20).
The first consideration is paragraph 4.51 within the supporting text to Policy NE10 which outlines the role and value of the countryside and why it should be considered for protection subject to a planning balance. These points of consideration are as follows:
1. The countryside is important for food production.
• The land south of Bognor Road is currently farmed and is large enough to support food production. The land south of Bognor Road is also Grade 1 agricultural land.
• The Drayton Waterside site however is too small to support viable food production and is enclosed by uses which are not within agricultural use and as such could not form part of an adjacent agricultural use unlike the Policy A20 site.

2. Countryside is important for landscape character.
• Both sites are not located in either the South Downs National Park or Areas of Outstanding Natural Beauty which cover a large part of the Chichester district.
• The Drayton Waterside site sits adjacent to existing built form currently used for employment use and is partly a brownfield site. The site is also smaller than the Bognor Road South and whilst providing 5,706 sq m compared to the 28,000 sq m provided by the land south of
Bognor Road, it should be the Council’s priority to look for delivering employment on multiple smaller sites which combined have a lesser landscape impact than that of a single large site.
3. Countryside is important for recreation:
• This role for countryside in respect of both sites is not necessarily relevant but it is noteworthy to mention that the Drayton Waterside site is private land and therefore not open to the public.

4. Countryside is important for biodiversity.
• Whilst the policy requirement for the delivery of the land south of Bognor Road would include a biodiversity enhancement this is yet to be evidenced as no application has been submitted for this site.
• The Drayton Waterside site, by contrast, has a live planning application and a Biodiversity Net Gains Assessment has been undertaken, and demonstrates that proposed development would result in calculated net gain of +12.73% Habitat Units and net gain of +13.45% Hedgerow Units. The Drayton Waterside site therefore demonstrates a substantial increase in biodiversity.

5. Countryside is important for stopping an urbanizing impact.
• The large scale of the land south of Bognor Road would create a noticeable urbanizing impact and whilst it is closer to the main conurbation of Chichester it would remove the separation between the current built form around the roundabout with Drayton Lane and Bognor Road whereas the Drayton Waterside site would neatly fit in within that existing built form and not diminish the gap between Chichester and this existing built form.

The wording of Policy NE10 outlines that sustainable development in the countryside would be permitted if the following considerations were achieved:
• There are sustainable transport links.
• The scale and design is appropriate to the location and not harmful to the rural setting.
• The proposed development preserves and enhances key countryside landscape features and does not impact any designations (Areas of Outstanding Natural Beauty or the South Downs National Park).
• The proposed development relates to an existing group of buildings.
• The proposed development does not prejudice countryside operations e.g., farming.

The Drayton Waterside site is considered to align with the requirements in this policy by:
• having strong sustainable transport links along the Bognor Road, to Chichester, including cycle routes and bus stops.
• The proposed development is of a scale where it would not harm the rural setting due to its relationship with an existing building group and being a relatively small site particularly when compared to the land south of Bognor Road.
• The proposed development is not considered to impact any designations or key features within the current countryside make up in this location and would not impact the current farming operations in the locality.

SUMMARY
The Chichester Draft Local Plan is considered to be unsound in the respect of employment land provision as it is heavily reliant on the sites which have strong valid delivery concerns. This includes:
• Existing permissions that are not likely to be forthcoming.
• Allocations carried over from previous Local Plan documents which have not been delivered since they were allocated in the Development Plan Document Site Allocation in 2019 or worse the previous Local Plan in 2015.
• One new large strategic site allocation (Land South of Bognor Road – Policy A20) that has significant site constraints including works to the A27 where funding has recently been withdrawn by National Highways / Secretary of State for Transport.
Employment land provision should be achieved through the allocation of more, smaller, sites to improve the chances of delivery and to meet market demand which is immediate (as evidenced by the Housing and Economic Development Needs Assessment [April 2022] and the accompanying Flude Market Report [July 2022]).
The market demand set out be the Local Plan evidence base and the Flude Market Report highlights that, whilst there is an employment floorspace need generally, there is a specific need for starter units between 750 and 2000 sqft.
Application reference 22/02202/FUL for the Construction of Business Park with associated parking and landscaping at Land North Of Drayton Waterside A259 Eastbound Merston Oving is considered to be a perfect example of a site that could meet the current market demand for employment floorspace, providing starter units, and not result in a harmful impact to the countryside which Land to the South of Bognor Road (Policy allocation A20) would create due to the scale of the strategic allocation.
Drayton Investments Limited strongly implore Chichester Planning Policy team to reconsidered the proposed Local Plan employment floorspace provision and allocate more, smaller, sites which, such as Land North of Drayton Waterside, can achieve immediate delivery of employment market floorspace demand.

Section 10.83: Chichester Gravel Pits and Leythorne Meadow is referenced as an SNCI. This needs to be amended to LWS (Local Wildlife Site).

Bullet point 7 in policy references Chichester Gravel Pits and Leythorne Meadow as a Local Nature Reserve - should also state that site is a Local Wildlife Site.

See attached representation.

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.

More flexibility to be written into policy:
Provide up to 5 no. plots, with need to be determined at time of submission of planning application and dependent on land required to satisfy biodiversity net gain and/or drainage requirements associated with commercial development;
More flexibility for amount of storage area associated with travelling showpeople plots. Flexibility and requirement for an assessment in accordance with Policy H13 should be included in policy wording;
A timescale for marketing of travelling showpeople plots following which it should revert to part of the commercial site.
Request more precise wording is included in criteria 10 and 11 so that expectations are clear.

See attachments.

“Before first occupation, infrastructure must be provided to provide
• continuous, direct, safe, attractive, comfortable walking and cycle routes between this development, railway station, residential parts of the city
• The bridge over the A27 does not follow the desire line, people walking and cycling need to double back on themselves to gain height, therefore add a ramp following the desire line direct into this developmement
• bus lanes reallocating road space between the railway station this development and along the A259 to Bognor Regis to improve bus reliability and journey times for connecting with trains and for journeys from Bognor Regis to facilitate increases of bus frequency and reduce car traffic.
• Subject to traffic flow analysis consider sharing the bus lanes with Larger Goods Vehicles on the A27 and A259 to ensure reliability of goods vehicles servicing this site, the remaining lanes for small vehicles could then be narrowed. Ensure design builds in bus priority at junctions, including roundabouts and where crossing the small vehicle lanes to gain access to the city residential areas and the railway station”

See attached.

More flexibility to be written into policy: Provide up to 5 no. plots, with need to be determined at time of submission of planning application and dependent on land required to satisfy biodiversity net gain and/or drainage requirements associated with commercial development; More flexibility for amount of storage area associated with travelling showpeople plots. Flexibility and requirement for an assessment in accordance with Policy H13 should be included in policy wording; A timescale for marketing of travelling showpeople plots following which it should revert to part of the commercial site. Request more precise wording is included in criteria 10 and 11 so that expectations are clear.

See attachments.