Policy A21 Land east of Rolls Royce

Policy A21 The Estate supports the policy, providing the resultant development offers an equally high standard of building and landscape design, site density and use, an without harm or adverse impact on surrounding land and land uses and the local road network.

Suggests policy is improved and made clearer by replacing 'safeguard' with 'allocate' the land for employment development.

Rolls-Royce Motor Cars (R-RMC) is highly supportive of the inclusion of Land East of Rolls-Royce (Policy A21) as a site for R-RMC to deliver its vision for the strategic expansion of the existing headquarters of R-RMC at Goodwood (R-RMC Goodwood). R-RMC considers the policy is sound in principle, but one minor modification is suggested to provide greater clarity.

Justification for Policy A21

As a prestigious global manufacturer of luxury motor cars and a major employer within Chichester District, R-RMC’s proposed expansion would signify a considerable investment into the local, district and wider UK economy.

Since its arrival in 2003, the Goodwood facility has expanded incrementally and now fully utilises the capacity of the existing site for its manufacturing needs. As part of its continued operations, and to improve its logistics processes, R-RMC requires an increase in manufacturing space to meet manufacturing needs and remain responsive to an evolving market. The proposed expansion would potentially generate additional employment opportunities and further contribute to the local and wider economy, thus helping to strengthen Chichester’s economic outlook at a time of national economic uncertainty. R-RMC has made previous representations through the Local Plan process seeking recognition of the importance of this expansion and is pleased that the Council acknowledges these needs through the inclusion of draft Policy A21.

The National Planning Policy Framework (NPPF) has sustainable development at its heart, including economic components. Moreover, paragraph 81-85 make it clear that supporting economic growth and competitiveness is of great importance in the planning system.

As part of these representations, R-RMC has prepared a report demonstrating the suitability, availability and achievability of the proposed expansion site. The report highlights R-RMC’s commitment to delivering an expansion within the Plan period, with a suite of technical assessments already undertaken and progress being made towards submission of a planning application later this year. The report, which should be read in conjunction with these representations, demonstrates that the site is in a suitable and sustainable location for development and that there are no significant constraints that would preclude development. R-RMC is confident that, through its emerging proposals, there exists an opportunity to provide development sensitively and with an enhanced landscape setting to satisfy the requirements of the draft policy.

Notwithstanding the above, R-RMC suggest the Policy is improved and made clearer by replacing ‘safeguard’ with ‘allocate’ the land for employment development. It is acknowledged that, at earlier stages of the Local Plan process, there was more limited detail available regarding the scope, extent and timescales for delivering an expansion, and it was appropriate at the time to consider the site for safeguarding for future needs. However, as outlined above and in the submitted report, R-RMC is developing its emerging proposals, has undertaken a series of technical assessments and intends to submit a planning application in 2023 (and certainly prior to the adoption of the new Local Plan). The Council can therefore be satisfied that there is more certainty regarding the intention to progress with an expansion of R-RMC Goodwood, certainly within the next five years.

Based on this, we suggest that there is an opportunity to reflect this position through an amendment to draft Policy A21. It is understood that the employment development is ‘not included in the [Plan’s] employment figures as it relates specifically to future operational needs for Rolls-Royce rather than to the broader employment requirement identified in the HEDNA’. However, the site has been tested through the Local Plan process and is considered through the HELAA and the wider Local Plan evidence base (e.g., the SA the Chichester Transport Study). It has been tested the same as an allocation and it would provide greater clarity and consistency to describe it as such. Notwithstanding this, it is also recognised that the policy as set out does not prevent R-RMC coming forward with its proposals subject to meeting the stated criteria.

In summary R-RMC supports draft Policy A21 but suggests it is amended to ‘allocate’ the site to ensure that the policy is fully effective and sound.

For consistency, we would suggest that the policy includes an additional bullet point:

• Ensure that development avoids harm to protected species and existing important habitat features; facilitates the achievement of a minimum of 10% biodiversity net gain; and facilitates the creation of high levels of habitat connectivity within the site and to the wider green infrastructure network and identified strategic wildlife corridors. This includes the provision of appropriate buffers as necessary in relation to important habitats which are being retained and/or created.

See attached representation.

• 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’.

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.

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.

See attached.

Please note that as a Non-Ministerial Government Department, we provide no opinion supporting or objecting to planning applications or local plans including their soundness or legal compliance.

Rather we are including advice and information that we advise the Council consider to ensure their pre-submission local plan avoids potential impacts and promote enhancements/expansion as part of the proposed local plan regarding trees and woodland, including ancient woodland. We acknowledge that the purpose of Regulation 19 consultations does not usually extend to making substantial changes which are not related to soundness so we offer our advice as helpful guidance to ensure the local plan takes every opportunity to secure the protection, enhancement and expansion of Chichester’s valuable trees and woodlands to comply with planning policy, good practice and to make the most of the many benefits they provide to the environment, local economy and community.

Overall Comments
Ancient woodlands, veteran and ancient trees are irreplaceable habitats, and it is essential that they are considered appropriately to avoid any direct or indirect effects that could cause their loss or deterioration, in line with Government Standing Advice. Ancient Woodland has very high potential ecological value and should act as integral focal points, alongside other locally and nationally designated sites, as part of delivering landscape scale nature recovery.

Any development or plan that include these irreplaceable habitats on or near to the site should aim to deliver high standards of net gains and ecological connectivity that supports wider ecological networks, in line with good practice. This will also be a requirement as part of the local nature recovery strategies being driven by the Environment Act 2021 and we advise that plans should anticipate this to maximise environmental benefits to contribute to reversing the national trend of ecological decline as part of broader nature recovery networks. The Local Plan should be considered as a crucial and timely opportunity to secure significant and strategic, plan-led environmental gains due to their scope and scale, particularly given the timescales of development being influenced that coincide with UK Government commitments regarding halving emissions and protecting 30% of nature by 2030, towards a net-zero carbon and nature positive economy.

The development strategy should prioritise the protection of trees and woodlands with the highest priority being given to ancient woodland, ancient and veteran trees as individual habitats and as part of wider ecological networks.

Site Allocation comments:

Policy A7 Land at Shopwyke (Oving Parish)
Site specific considerations could recognise the existing trees, hedgerows and woodland and prioritise their protection, enhancement and expansion as part of biodiversity net gains. Acoustic screening referred to could also use trees to make the most of multi-functional benefits they bring.

Policy A8 Land East of Chichester
We welcome efforts to bolster the existing woodland and the proposed strategic wildlife corridor to the East and the enhancements that development could bring.

Policy A11 Highgrove Farm, Bosham
Bolster planting to North, South and East is welcome. This policy could be improved by requiring bolster planting to the West as well, where there appears to be an existing line of trees, making it well placed to further contribute to wider connectivity with existing and additional planting.

Policy A12 Chidham and Hambrook and Policy A13 Southbourne Broad Location for Development
We note that more detailed proposals will emerge as part of a Neighbourhood plans. We would like to highlight that this area contains some parcels of ancient woodland which is an irreplaceable and high priority habitat according to the NPPF and Government Policy (see attached Annex and below for more guidance on this). The policy could be improved by highlighting its importance and high priority as part of efforts to protect, enhance, expand and connect habitats as part of a wider ecological network and the strategic wildlife corridor. Developments within this area could contribute pockets of woodland and linear planting to help connect existing trees and woodland as part of a mosaic of habitats throughout the wildlife corridor and wider area. The requirement to ensure development does not have an adverse impact on the strategic wildlife corridor is also welcome but could be strengthened by requiring developments to significantly contribute to its enhancement, expansion and connectivity including with green infrastructure provided by development

Policy A14 Land West of Tangmere
The requirement for significant levels of green infrastructure is welcome. This policy could be strengthened by requiring development to retain and bolster existing hedgerows and trees wherever possible.

Policy A16 Goodwood Motor Circuit and Airfield and Policy A17 Development within the vicinity of Goodwood Motor Circuit and Airfield
This policy could be improved by recognising the significant amount of ancient woodland and non-ancient woodland to North of the area. We would encourage any development in the area to protect, enhance and expand the woodland in the area as part of delivering net gains.

Policy A21 Land east of Rolls Royce
This area contains areas of existing trees, hedgerow and woodland which are not currently mentioned by the policy. We would encourage any development to be sensitive to this and provide additional planting where possible.

Overarching comments
We would welcome the consideration of incorporating large and small pockets of multi-functional woodland as part of green infrastructure provision for development, particularly given the relatively low proportion of woodland found throughout the District, and the benefits this can have as ‘stepping stones’ between habitats as part of the Local Plan’s welcome vision of strategic wildlife corridors.

We also encourage the Council to appraise the plan against the following advice to maximise the benefits from protection, enhancement and expansion of woodlands, trees and connectivity throughout the District:

Additional improvements to consider

• Tree/hedgerow removal is considered as a last resort but where it is justified, we advise that developments can aim to deliver no net deforestation to help encourage development that provides an overall environmental gain. Ie where trees are required to be removed, additional tree planting will be made to compensate for this loss and we would advise that additional planting should be made to help compensate for the loss of habitat in the time it takes for new trees to mature.
• Long term management and maintenance of planted trees and woodland creation to give them every chance to becoming established and where trees do fail, they are replaced
• A minimum standard for tree canopy cover for new developments (e.g. for large-scale developments) as it provides a targetable level of green infrastructure in relation to trees for the numerous ecosystem services they provide.
• Precautions should be incorporated into any woodland design and tree planting to ensure that habitat creation is established successfully and that potential impacts from deer are managed on site and in the surrounding area as appropriate. See here for further guidance that should be followed for managing impacts from deer as part of woodland creation and tree planting: https://www.gov.uk/government/publications/woodland-creation-and-mitigating-the-impacts-of-deer/woodland-creation-and-mitigating-the-impacts-of-deer Some good practice advice is also provided in Appendix 1 of this letter.
• We advise that any tree planting should meet the following:
o Trees should be healthy and good practice biosecurity should be followed to prevent the risk of spreading pests and disease, in line with Government advice: https://www.gov.uk/government/collections/tree-pests-and-diseases. More information on the plant healthy can be found at: Welcome to Plant Healthy - Plant Healthy
o Created or restored habitat should be managed in perpetuity in line with a robust management plan that follows good practice to ensure assumed benefits of created habitats are delivered in practice (see Standing Advice referred to on page 1). We recommend meeting the UK Forestry Standard to demonstrate this.
• To help mitigate climate and support local economy would urge council to develop local plan policy that makes use of locally sourced timber. This has multiple benefits as it can help store carbon within development, reduce impact from transportation, reduce embodied carbon from alternative materials and support local economies and communities.
• Where developments incorporate District Heating, consider locally and sustainably sourced wood-fuels for the benefits this can have for renewable energy and towards a local, circular economy
• Use tree planting as part of nature based solutions for managing flood risk as well as other multi-functional benefits from green infrastructure as part of any development (e.g. Trees and woodlands provide £400 million of value in flood protection)
• We encourage the Council to refine their strategy to trees and woodlands using the recently launched ‘Trees and Woodland Strategy Toolkit’ available here: https://treecouncil.org.uk/what-we-do/science-and-research/tree-strategies/ to design and deliver a local tree strategy to harness the long-term benefits that trees can bring to local communities. The local plan should be developed with tree/woodlands in mind as an integral part, alongside other supplementary strategies for the environment including biodiversity, green infrastructure, nature recovery and climate change.

Key guidance regarding trees, woodland and development

Ancient woodlands, ancient trees and veteran trees are irreplaceable habitats. Paragraph 180(c) of the NPPF sets out that development resulting in the loss or deterioration of irreplaceable habitats should be refused unless there are wholly exceptional reasons and a suitable compensation strategy exists. In considering the impacts of the development on Ancient Woodland, Ancient and Veteran trees, the planning authority should consider direct and indirect impacts resulting from both construction and operational phases.

Please refer to Natural England and Forestry Commission joint Standing Advice for Ancient Woodland and Ancient and Veteran Trees, updated in January 2022. The Standing Advice can be a material consideration for planning decisions, and contains advice and guidance on assessing the effects of development, and how to avoid and mitigate impacts. It also includes an Assessment Guide which can help planners assess the impact of the proposed development on ancient woodland or ancient and veteran trees in line with the NPPF.

Existing trees should be retained wherever possible, and opportunities should be taken to incorporate trees into development. Trees and woodlands provide multiple benefits to society such as storing carbon, regulating temperatures, strengthening flood resilience and reducing noise and air pollution.[1] Paragraph 131 of the NPPF seeks to ensure new streets are tree lined, that opportunities should be taken to incorporate trees elsewhere in developments, and that existing trees are retained wherever possible. Appropriate measures should be in place to secure the long-term maintenance of newly planted trees. The Forestry Commission may be able to give further support in developing appropriate conditions in relation to woodland creation, management or mitigation.

Biodiversity Net Gain (BNG): Paragraph 174(d) of the NPPF sets out that planning (policies and) decisions should minimise impacts on and provide net gains for biodiversity. Paragraph 180(d) encourages development design to integrate opportunities to improve biodiversity, especially where this can secure net gains for biodiversity. A requirement for most development to deliver a minimum of 10% BNG is expected to become mandatory from November 2023. The planning authority should consider the wide range of benefits trees, hedgerows and woodlands provide as part of delivering good practice biodiversity net gain requirements. Losses of irreplaceable or very high distinctiveness habitat cannot adequately be accounted for through BNG.

Rolls-Royce Motor Cars (R-RMC) is highly supportive of the inclusion of Land East of Rolls-Royce (Policy A21) as a site for R-RMC to deliver its vision for the strategic expansion of the existing headquarters of R-RMC at Goodwood (R-RMC Goodwood). R-RMC considers the policy is sound in principle, but one minor modification is suggested to provide greater clarity.

Justification for Policy A21

As a prestigious global manufacturer of luxury motor cars and a major employer within Chichester District, R-RMC’s proposed expansion would signify a considerable investment into the local, district and wider UK economy.

Since its arrival in 2003, the Goodwood facility has expanded incrementally and now fully utilises the capacity of the existing site for its manufacturing needs. As part of its continued operations, and to improve its logistics processes, R-RMC requires an increase in manufacturing space to meet manufacturing needs and remain responsive to an evolving market. The proposed expansion would potentially generate additional employment opportunities and further contribute to the local and wider economy, thus helping to strengthen Chichester’s economic outlook at a time of national economic uncertainty. R-RMC has made previous representations through the Local Plan process seeking recognition of the importance of this expansion and is pleased that the Council acknowledges these needs through the inclusion of draft Policy A21.

The National Planning Policy Framework (NPPF) has sustainable development at its heart, including economic components. Moreover, paragraph 81-85 make it clear that supporting economic growth and competitiveness is of great importance in the planning system.

As part of these representations, R-RMC has prepared a report demonstrating the suitability, availability and achievability of the proposed expansion site. The report highlights R-RMC’s commitment to delivering an expansion within the Plan period, with a suite of technical assessments already undertaken and progress being made towards submission of a planning application later this year. The report, which should be read in conjunction with these representations, demonstrates that the site is in a suitable and sustainable location for development and that there are no significant constraints that would preclude development. R-RMC is confident that, through its emerging proposals, there exists an opportunity to provide development sensitively and with an enhanced landscape setting to satisfy the requirements of the draft policy.

Notwithstanding the above, R-RMC suggest the Policy is improved and made clearer by replacing ‘safeguard’ with ‘allocate’ the land for employment development. It is acknowledged that, at earlier stages of the Local Plan process, there was more limited detail available regarding the scope, extent and timescales for delivering an expansion, and it was appropriate at the time to consider the site for safeguarding for future needs. However, as outlined above and in the submitted report, R-RMC is developing its emerging proposals, has undertaken a series of technical assessments and intends to submit a planning application in 2023 (and certainly prior to the adoption of the new Local Plan). The Council can therefore be satisfied that there is more certainty regarding the intention to progress with an expansion of R-RMC Goodwood, certainly within the next five years.

Based on this, we suggest that there is an opportunity to reflect this position through an amendment to draft Policy A21. It is understood that the employment development is ‘not included in the [Plan’s] employment figures as it relates specifically to future operational needs for Rolls-Royce rather than to the broader employment requirement identified in the HEDNA’. However, the site has been tested through the Local Plan process and is considered through the HELAA and the wider Local Plan evidence base (e.g., the SA the Chichester Transport Study). It has been tested the same as an allocation and it would provide greater clarity and consistency to describe it as such. Notwithstanding this, it is also recognised that the policy as set out does not prevent R-RMC coming forward with its proposals subject to meeting the stated criteria.

In summary R-RMC supports draft Policy A21 but suggests it is amended to ‘allocate’ the site to ensure that the policy is fully effective and sound.