Policy S4: Meeting Housing Needs

I am a retired FRICS and have some knowledge of Housing Matters. The need for more affordable/social housing is accepted by most people who want to see a settled and fair society. How this is achieved is the issue. The current proposals achieve nothing, mainly due to how the big builders manage to manipulate Government policy to suit themselves at the expense of local needs and in this locality create problems listed as follows.

1.Flooding. Increase in surface water drainage ends up in the water meadows and harbour AONB.
2.Pollution. Most surface water drainage is polluted and I draw attention to a recent hydrocarbon spillage in Fishbourne which gravitated as always into the Millpond Water Meadows and Harbour all of which are protected areas and home to endangered species including water vole.
3.Capacity issues at Appledram Sewage Works and others. A recent Freedom of Information Act enquiry confirmed the system cannot cope with the current volume of waste and now admitted by Southern Water. On site treatments are unreliable and failure in this locality could be catastrophic.
4.Traffic. More development of the type proposed will just exacerbate current well documented problems around the A27 and local roads.

There needs to be new thinking by both Central and Local Government on where to put extra housing and stop the obsession of building on green belt and creating urban sprawl.

1.Chichester centre. Online shopping is destroying secondary/tertiary retail areas. Grasp the nettle and use these areas for apartments. Stop the influx of Charity shops the usual death knell of shopping areas. Incentivise change of use to residential. Get the Housing Associations involved with Government support.
2.Put in required infrastructure especially sewage disposal before development. This is just plain common sense.
3.Remove the rules that favour developments of more than 100 units
4.Rein in the South Downs National Park Authority. Many communities in the South Downs would welcome small pockets of affordable housing so that younger people with families can remain and ensure the survival of local primary schools, village shop, real communities. Again get the Housing Associations involved with Government support and make it less of an attraction for 2nd home owners.

See attachment

Allocating 9,956 houses in the East-West Corridor and 1,933 houses on the Manhood Peninsula within the Plan period will significantly impact on Chichester Harbour AONB, Pagham Harbour and the coastal fringe.

Policy S3 (Development Strategy) sets out the Council's proposed approach to general development across the District through the Plan period. The first objective is to focus development around Chichester and the east-west corridor. Whilst is it accepted that this is the most sustainable location in the District, this strategy will result in a.) an excessive burden on an already challenged infrastructure network (the A27 and poor quality rail services) and b.) mean that other more remote areas across the District will not keep pace with the development of services and facilities in proportion with the amount focused in Chichester itself. Furthermore, it is commonly the case that the complexities around strategic allocations can result in delays to development which can have a consequential impact for housing delivery across the District and consequently the objectives of Policy S4 (Meeting Housing Needs). To address these issues the Council should give consideration to better dispersing development across the District on a higher number of smaller sites. These types of sites should be located towards the periphery of the District whereby settlements can sustain the prospective occupants of new developments. There are a number of benefits to this approach. In the first instance, smaller sites are more likely to come forwards early in the Plan period and ensure that Chichester can deliver the amount of housing required. Delays in land negotiations are less likely to affect the deliverability of sites of this type. Secondly, by locating those sites on the periphery of the District, a proportion of the residents would use local facilities on a daily basis thereby supporting the sustainability of these settlements. Furthermore, the use of local facilities would lessen any immediate burden on infrastructure in the vicinity of Chichester and allow time for it to be developed and improved over the longer term which would avoid compounding an existing problematic situation. Thirdly, the development of smaller sites at the edge of the District would better encourage more widespread infrastructure improvements across the District rather than focusing solely on Chichester. Finally, this approach is fundamentally more sustainable. The focus of a District's housing requirement in a central area will not lead to sustainable patterns of growth over the longer term.

With regard to Policy S4 (Meeting Housing Needs) the Plan is heavily reliant on Neighbourhood Plans delivering large-scale housing allocations which are considered to be disproportionate to the Neighbourhood Plan (NP) process. For example, the plan anticipates Southbourne NP accommodating 1,250 dwellings, Chidham and Hambrook NP accommodating 500, East Wittering NP 350 and Fishbourne 250. To ensure the Plan delivers in terms of its housing requirement, this will require Neighbourhood Planning Groups to have made significant progress on their respective Plan and Plan reviews by May 2019. This is a complex and time-consuming task and the timescales involved may result in a rushed NP process with the alternative of Chichester District Council taking back control and allocating sites contrary to an emerging NP. This is reflected in the minutes of the Chidham and Hambrook NP Group meeting minutes of November 2018 where it is minuted that one of five volunteer residents 'expressed surprise' at the 'tight timescale indicated for the (review) project'. In respect of Fishbourne NP, the Parish Council met on 15th January 2019 where the Groups response to the current consultation was discussed. The minutes are awaited and are likely to provide a steer on the NP groups views on the extent of development proposed within the NP area. Each of the NP groups involved are at various stages in the preparation and review process of their respective Plans making it difficult to predict how quickly each will progress. This will require Council Officers to allocate a significant proportion of their time to support NP groups which may delay work on other Policy work with a consequential impact on progress and delivery of sites across the District. Furthermore, whilst Southbourne NP group have identified land to accommodate their portion of housing development, it is a single site, north of the railway line and therefore, require a bridge. This level of infrastructure improvement is likely to render this scale of development undeliverable in the context of the NPPF. The improvements will be required to facilitate this scale of development and, as such, are likely to be unviable which again, conflicts with the NPPF.

The concentration of the house building predominantly on the existing east west corridor will exacerbate the problems of access to the city and transport around the city without recourse to 'rat running' through villages and all its attendant problems and impact on tourism.

Halnaker resident.
The numbers are fictitious drawn up to satisfy the developers.
The CDC has a very small area in which to build given the justifiable constraints of the Harbour and the South Downs. the SD should be taking more affordable housing if this can be demonstrated to be required

The South Downs National Park should take it's allocation of 41 dwellings per annum - without some low level development in the Park, particularly social housing, communities there will not thrive

The 'objectively assesses' housing need is flawed. The Government has recently published revised population estaimates which means that Chichester's inflated housing demand is incorrect. Even Government Inspectors admit this - take Guildford Borough Council for example. Their housing need numbers are being reassessed by their Planning Inspector (Jonathan Bore) in light of the latest figures and this could remove the need to find provision for up to 800 more homes. Chichester District Council, if it cared about the borough and its residents, should heed this and look to reduce the numbers.

This would remove the need to tarmac over the Loxwood area with 125 homes in what is a small rural village.

The allocations of 200 dwellings for Hunston and 50 dwellings for North Mundham are overdevelopment of these small villages. This will lead to an increase on the local roads around their parishes and inevitably into Donnington as their residents seek alternative routes to A27. Anecdotal evidence suggests that Hunston does not operate as a Service Village - facilities in Donnington are used instead. Donnington does not need an additional 100 homes - where is the evidence of local need?
The South Downs National Park should take its allocation of 41 dwellings per annum - without some low level development in the Park, particularly social housing, communities there will not thrive. (Policy S4, Policy S5, Policy S19).
The duty to co-operate is understood, however housing allocation was specifically front loaded during the current Local Plan period to allow for infrastructure developments across the district and it is unfair to ask the Manhood Peninsula/Donnington to take a number on this scale given its allocations under the new plan.

I wish to object to this plan, for the following reasons:
1. There has been no attempt to justify the increase in annual housing numbers from 435 in the Adopted Plan to 650. The Adopted Plan cited environmental and infrastructural constraints as a reason for using 435 as the annual figure. None of these constraints have changed, yet the housing figure has increased by nearly 50% without a word of justification. No houses should be accepted from the SDNP, and the housing figure should be reduced to reflect the 2016 ONS household projections. Chichester does not need 609 houses every year until 2035, and is under too much environmental pressure to accept houses from a vast National Park.
2. Using the figure of 650 houses per year, the plan calculates that 4400 houses are needed from strategic locations. It then lists the strategic locations, which adds up to a total 7985 houses. Considering that the total figure should be more like 550 houses pa, the figure of 4400 is itself too high, and should be more like 2900. This means an excess of 5000 houses has been allocated. I may be reading these figures incorrectly, but it seems to me that a large number (I would suggest at least 2500) be removed from the proposed sites. A large number of the houses proposed are more or less immediately adjacent to the Chichester Harbour AONB. I suggest removing those doing most harm to the AONB.
3. Far too much building has been proposed that damages the Chichester Harbour AONB. Especially Policy AL6 (Land South-West of Chichester, Apuldram and Donnington Parishes) which proposes a new link road which cuts the harbour off from the city, and a major commercial development within a few hundred metres of the AONB. Any plans for a link road should be abandoned, and the commercial site should be moved to the East of the city. Airfields usually provide a good hub for commercial sites, so close to Goodwood airfield would be a suitable place. The houses proposed for this site are not needed.
4. Environmental, and particularly infrastructural constraints were recognised when allocating housing on the Manhood Peninsula in the adopted Plan. Additionally, building on the Manhood Peninsula was front loaded because of capacity limitations at the Tangmere Water Works. The Manhood's requirement until 2029 has already been exceeded by a large margin. The environmental, and particularly infrastructural constraints remain completely unchanged, with the A27 improvements seemingly further than ever from resolution. The A286 is becoming busier and noisier, with complete gridlock on holiday weekends. As there is a huge oversupply of development sites, no housing should be allocated to Birdham, Bracklesham or West Wittering in this plan cycle, or until infrastructure improvements are complete.

Before MORE house are built I think the Council should carryout a comprehensive study of existing housing as to the current usage and occupancy. Some larger houses could become available if those larger houses were of single occupancy as elderly people move to a flat or bungalow. There are also houses that are unoccupied and appear abandoned by the owner.
Your own document talks about making effective use of existing infrastructure, facilities and services.
Any new housing that is found to be needed must contain a lot more 'affordable housing' than stated in current policy; and affordable must mean affordable to local residents with regard to local wages and general employment expectations in the Chichester area. During a new planning application for any new development, conditions can be put into place to ensure this happens.

I also feel the current infrastructure needs also to be improved. As you are already aware the A27 is already at saturation point every morning and afternoon and most of the daytime during the summer period being the main trunk route East to West to the Channel Ports and holiday destinations in the West Country. This is a good opportunity to consider sympathetically upgrading the existing route before building another road through our local countryside. I also understand that although improvements are on going to the foul sewer system this is designed only to cope with the new housing already approved. No further capacity has been allowed for for the additional housing proposed in this Local Plan Review

There is too much information here and it feels like it is an opportunity for CDC to put strategies in that will be missed by the general public.

No further development should occur in this area until the profound issues of the A27 are resolved - it is already an area that has become difficult to live in with each year that passes. It is no longer an attractive city to live in and squeezing resources further will exacerbate that.

I strongly object to AL6 which concerns the construction of a relief road from Fishbourne roundabout to the A286 - what benefits will this bring to the area ? It will destroy an area of natural beauty and habitat. It will add to the danger of this roundabout which already has significant accidents.

As for the Southern Gateway idea - it's completely ludicrous and a waste of tax payers money!

OVERALL
Whilst I commend the work put in I am dissapointed in the attitude to the South Downs National Park. Whils I acknowledge that they are their own planning authority the CDC has a major role in their area and are advised of planning being applied for. In this instance, the 2035 review I believe the CDC should have taken a much more decisive attitude and issue a requirement that they provide substantial land for both employment and domestic development. National directives do not prevent such an approach and I believe that many residents within the SDNP would support inner development to retain and expand accomodatio for those who wish to stay within its boundary to work and live. There is ample scope to develope within the SDNP.This approach would go a long way to allieviating the overdevelopment of the corridor along the A259.

POLICY SA6 Land to the South - West of Chichester.
Whilst the merits of development along the southern border of the A27 twix Fishbourne and Donnington can be seen I believe that building height restrictions would be needed to mitigate the impact views torardso and from the city and the AONB making this far less attractive. There is also a need to pay regard to possible improvements to the A27 ,a potential which can not be ignored. I believe this proposal should be shelved and held in reserve for a later plan.
The link road is a factor which in my view must be reconsidered with its impact on accessability to the already conjested Fishbourne roundabout., If it is to be recommended there must be mitigation by a flyover east - west at this junction, A27, with pre-agreement with Highways \aengland for this to go ahead.The level of the road is also a concern with views, noise and pollusion all a factor. It would seem preferable to divert traffic from the south, east of the southern development area as it is to join the A27 at the Bognor road crossing where there is more scope for a raised crossing.Highways England involvement is urgently needed here.

POLICY SA9 Fishbourne.
I can not see how the perceived view of Fishbourne can be uphed. The determination of its character appears at varience withother villages.
The structure of the village can not support a further 250 houses as there is no supporting facilities and no funding is available, nor raisable through this development, for educational, services or transport facilities . The infill of strategic gaps which is a policy of national and local government departments is being breached. The projected area is shown as preferred over an area to the east of the village which has previously been put forward for development because of the newly raised wildlife corridor and the same considerations should be applied to the preferred area taking it out of consideration..

In conclusion I must say that this plan can not be constructed in isolation and special representations should be made to The Government to delay further consideration until the A27 improvement stratagy is determined.

The Chichester Local Plan Review identifies a total housing requirement of at least 12,350 dwellings over the period 2016 to 2035. This equates to an average supply of 650dpa and relates solely to the area outside of the SDNP.

The proposed housing requirement is based upon a requirement of 609 dwellings, derived using the standard method identified in the PPG (para. 2.35, 2018 HEDNA). A further 41 dwellings are added to accommodate unmet need arising from the Chichester District part of the SDNP (para. 2.22, Local Plan Review).

Whilst it is agreed that the standard method should be used to identify the housing needs of the area, it is considered it has been incorrectly applied. Furthermore, the inclusion of 41 dwellings for the SDNP is not sufficient to meet the unmet needs from this area.
The PPG places a limit on the amount of increase in the minimum annual housing need figure an individual local authority can face. Where there is an up to date local plan, i.e. less than 5-years old, this is set at 40% above the average plan requirement. If there is no up to date local plan it is set at the higher of 40% above step 1 or the most recent plan requirement, whichever is the greater.
In terms of Chichester the extant local plan is less than 5-years old, being adopted in December 2016. This identified an average annual housing requirement of just 435 dwellings. The 2018 HEDNA utilises this requirement to identify a need for 609dpa over the period of the Local Plan Review, which has been capped at 40%.

However, the extant Local Plan did not provide for the full need of 505dpa due to several constraints including infrastructure capacity and the quantification of need within the SDNP (para. 7.9). The Plan states that 'For this reason the Council will review the Local Plan within five years to aim to ensure that OAN is me' (para. 7.9).

However, the PPG is clear that the cap is applied 'to help ensure that the minimum local housing need figure calculated using the standard method is as deliverable as possible. The cap reduces the minimum number generated by the standard method, but does not reduce housing need itself. Therefore strategic policies adopted with a cap applied may require an early review and updating to ensure that any housing need above the capped level is planned for as soon as is reasonably possible'. (PPG ID 2a-007).

Given that the Council is already not meeting its previously identified needs it appears contrary to the ethos of the NPPF and PPG to use the artificially low annual housing requirement of 435 dpa as the base figure and then final capped figure of 609 dpa to limit future need. There is also further unmet need in the neighbouring South Downs National Park. Therefore, it is proposed that the Council review their Housing Need figures.

The document reads if it has been produced in order to respect a Government diktat to plan for X houses, even though many of important factors are unknown (eg A27), because if no plan update is supplied funding will be lost. Houses are just spread around the area (50 in a field here, 200 tacked on to that village) without aiming for a coherent plan that takes account of major development (WHF) or changes to the city (Southern Gateway)

"Chidham and Hambrook" was also described in your plan as "Hambrook/Nutbourne". The plan should be consistent.

Policy S4 there is no mention of housing allocation in the area North of Chichester and South of the SDNP. This needs to be allocated as a strategic site in the plan. This site should be adopted as a strategic employment site.

There are several allocations on your sustainability appraisal which satisfy the need far more in line with your aims than the one you have settled on. Bosham in particular has a train station close to a potential site (old French Gardens) which would allow for up to 200 houses. Bosham Train station, unlile Nutbourne or Southbourne, has a ticket office and thus ability to become a more utilised facility if demand required it to be. In this area, there are several convenience stores, two different buses (one has just had it's route extended), Drs surgery and two seperate primary schools approximately 1 mile away in either direction. It therefore seems untenable and simply wrong to place further burden elsewhere. Utilising the partially brownfield site at the French Gardens also has no detriment to landscape quality and outside the AONB. Furthermore it has better transport and access than the Highgtove site which has already been allocated 50 houses, thus setting precedent for houses in the adjacent area. It is also less prone to flooding and helps retain the settlement's character without sprawling towards Fishbourne.

There is no mention of housing allocation in the area North of Chichester and South of the SDNP. This needs to be allocated as a strategic site in the plan. This site should be adopted as a strategic employment site.

Having trawled through the CDC Local Plan, which I have to say at the outset is the least user friendly document I have had the misfortune to read in a long time. The sceptic amongst me , would claim that CDC has deliberately done its best to make it as inaccessible as possible and these points go to explain my reasons for coming to that conclusion.

:- It was released just before Christmas, when CDC knows that people are busy.
:- It was released with very little advertising and only now has there been a little more effort but still not enough..
:- Very few public exhibitions have been put on or advertised , many actually put on by local communities horrified at what has been included.
:- Only available really to those who have access to the internet as there is a charge of £15 for a paper copy so excluding many of the older generation who do not have access to the internet.
:- the fact that the software being used only allows one response from an email address. Any others are not acknowledged.

I would like these issued raised and acknowledged. For such an important Consultation to be conducted in this matter is harmful and actually against a democratic process.

I have commented electronically but because of the constraint of 100 words this makes commenting properly very restrictive , I am therefore submitting this email as well and insist that both my electronic comments/objections are taken together and that neither is excluded.
I welcome a need for a Local Plan to safe guard the uniqueness and sustainability of our beautiful city, but this plan is wholly unfit for purpose. In places it is so biased and contradictory , it has actually made me laugh ! This is a Local Plan so why has there only been development in the South , East and West. For some reason Goodwood and the North has either been included and then removed or excluded completely. This is not a LOCAL PLAN, this is a biased and incomplete plan because of this exclusion.

The Southern and western areas that border Chichester Harbour AONB have been repeatedly included in the plan for significant development despite having the a same or greater criteria for exclusion than Goodwood and the area to the south SDNP which have been excluded. This invalidates the Plan as it contradicts all the criteria used and makes a mockery of the Plans integrity.

TRANSPORT

The transport study done by Peter Brett Assoc (PBA) is completely unfit for purpose. The study has only explored short term transport infrastructure which is completely unacceptable for this Plan which specifically states that is should be looking at short, medium and long term transport models especially the considering the Plan is supposed to last until 2035. It has included a link road in AL6 which was roundly opposed in the democratic Highways England (HE) consultation of 2016 along with hybrids of Options 2 and 3 also rejected, so it should not have been included unless all other options including the preferred Mitigated Northern route had also been included.

There has been no detail of how these large housing developments (over 2000 homes) along the A259 are going to access the A27 which is already at full capacity at the Fishbourne Roundabout. There is also no evidence that the required consultations between CDC, PBA and HE have taken place so any inclusion of link roads and junction upgrades are invalidate and should be removed and if not adequately addressed in future iterations of this plan , I will raise it with the examiner at the appropriate time .The PBA actually claims that there will not be an increase in air/noise/pollution by the building of a link road. REALLY ! You are proposing to build an elevated road (due to it being on a floodplain 3 zone !) which would have to be 4 metres high in an open flat topography, bordering the highly sensitive Chichester Harbour AONB with dark skies and noise/air pollution protection and restricting right turns only, necessitating Stockbridge and Whyke roundanabout traffic to travel twice as far and the report states that there would be no increase in air pollution.Absolutely ridiculous and totally unrealistic.They also state that there will be no further increase in air pollution despite traffic volume increasing year on year. Chichester, especially Stockbridge Roundabout has frequently breached air quality limits in recent years and continues to do so. So this part of the report is just nonsense.(DM24/SP28)
There is also no mention of any realistic funding. Again you cannot include junction upgrades which come under the jurisdiction of HE and for which no consultation evidence has been shown in the report. CDC Local Plan should not include any upgrades that they do not have confirmed funding for when the plan is produced. Anyone can produce a plan with a nice wish list but this does not make a professional /viable document .
CDC said itself that "any highways improvements should mitigate congestion on the A27"....the limited detail in this plan actually adds to the congestion it does not mitigate it and it again hugely disadvantages local traffic.

All the proposed developments along the A259, at Chidham/Hambrook, Bosham, Southbourne and Fishbourne all claim that they are sustainable because they have good transport links in the form of bus and rail links. They do not and these transport link viabilty and frequency cannot be influenced by CDC as they are run by independent companies. At present the bus service is fairly frequent at peak times but other times is not so cannot be relied upon. It is also not a very cheap option for many people. Rail links have been cut significantly in recent years with timetable rearrangements and places like Bosham and Southbourne have one train stopping once an hour at peak times, to and from Chichester. Not what I would call good links. and again is expensive..£2.80 for a single from Fishbourne...a journey of 5 minutes !! So these developments would realistically rely on cars again so increasing the burden on the Fishbourne of Emsworth junctions that are already running at full capacity.

Unless these issues are adequately addressed in future iterations of this plan, i will raise it with the examiner at the appropriate time.

HOUSING

( including 3.17,S3,S5,S19,4.3 )

Why is CDC not insisting that SDNP take back responsibility for the allocation of 41 houses a year . It would remove the need for CDC to find areas for another 200+ houses within their local plan and SDNP should be promoting small scale house building within the Park in order to sustain local services such as schools and local services which will die if more families are not encouraged.

Why has the north of Chichester ,been removed from the plan...houses along the A259 amount to well over 2000 houses with the same environmental sensitivities and yet houses south of the SDNP to Chichester NONE. There is no justification for this as there is suitable land around Goodwood airfield and Rolls Royce that could be used and was originally included in the plan but again was removed for no justifiable reason. Why can large villages like Lavant and Boxgrove not have any housing allocation ? They are classed as local service hubs as they have shops and schools and yet are excluded. Unless this is adequately addressed in future iterations of the plan, I will raise this with the examiner at the appropriate time.

New housing need to be smaller less intrusive developments so that they don't overwhelm and swamp existing residential areas. They also need to be a majority of affordable housing for people with local connections. These local connections should actually mean people born in the city or whose parents have lived in the area for the majority of their lives. Local young adults don't stand a hope of buying or even renting in Chichester as the prices are so high compared to wages of most ordinary people.There should be a ban on second homes and but if they do slip though and are rented out, then rents should be capped to make it less attractive to landlords.

New developments should not include 'executive' 4 and 5 bedroomed houses. There are enough of these in Chichester and so developments should consist of 1, 2 and 3 bedroomed properties only with a few 4 bedroomed houses to satisfy housing association demand.

Why are brownfield sites like the one bordering Swanfield Drive / Portfield near Sainsburys not being used for housing if demand is so crucial. We do not need anymore out of town entertainment which is killing the town centre.It should be reclassified for housing , as it would have less impact, is within walking distance of services and already borders residential areas..

Unless these issues are adequately addressed in future iterations of the plan, I will raise it with examiner at the appropriate time.

SCHOOLS/SERVICE INFRASTRUCTURES

(including 4.85)

Although there is lip service paid to providing schools, it is all very vague. If you are building developments of 250 + then you are going to need school provision. Most schools in places like Bosham are already at full capacity from local children so expansion or new schools need to be built very early on in any development. The threshold should be very low , for example when the 50th house of 250 is built, that way the services will already be in place before the houses are occupied. Most primary schools within Chichester city and surrounding villages are now already at full capacity necessitating parents to have to travel in cars to get their children to less local schools. The schools like Parklands Primary that have been expanded recently to take two form entry have suffered from substandard design and building. Stairs out of action for months. Disabled toilet out of use and worst of all classrooms too hot in summer due to lack of air conditioning which meant children had to be sent home for several days. This particular issue has still not been addressed so will occur next year when the temperature rises.

Although the Free School has recently been completed( but because of its site requires most children to access by car at least some if not all of the way,) relieving pressures on primary and secondary school places, no provision has been made for future developments around the southern peninsula of Witterings/ Bracklesham etc which necessitates huge transport movement twice a day as there is no secondary school provision within a 6 mile radius.

Funding for such new schools are not funded by CDC and therefore these should have been properly costed and funded before they could be legitimately included in the Local Plan...again a fictitious wish list !!

No mention of where people are going to find other services such as doctors and dentist, many of which are already running at full or near full capacity.If there are no services available locally then people will be forced to travel. No mention of increased travel because of this and lack of local school places in the Local Plan.

Unless these issues are adequately addressed in future iterations of this plan, I will raise it with the examiner at the appropriate time.

AIR QUALITY

DM24/SP28 There is no acknowledgement of the fact that the air quality levels especially at Stockbridge Roundabout exceeds quite substantially acceptable levels set by the Government. Such an omission is significant and has a huge influence on future planned developments and unless it is adequately addressed in future iterations of the plan, I will raise this with examiner at the appropriate time

AL6.

Well where do I start on such an utter inaccurate piece of wilful destruction and vandalism. AL6 contradicts everything that the Local plan states .
It does not protect the biodiversity of the area...It DESTROYS it
It does not protect the historic views of the only Cathedral visible from the sea...It DESTROYS it.
It does not enhance the natural environment (S26)... It DESTROYS it
It does has an adverse impact on the openness of views in and around the coast. (S26)..It DESTROYS them.
It does not have regard to flood and erosion policy (S27)...It WILL increase the likelyhood of flooding and contamination of Chichester Harbour water.
It does not protect the area from light/air/noise pollution(DM23/24 etc)....it would DESTROY the dark skies policy and hugely increase air pollution.

I could continue. AL6 should be removed completely. The Plan itself states that no proper study has been done into the impact of AL6 and so that very admission should have been enough to exclude it from the plan.How can you include a destructive option like this without doing any sort of environmental study or impact study first. Unprofessional and disgraceful AL6 comes within 100 metres of Chichester Harbour which has AONB status which holds the same protection as the SDNP but does not have the same 5km exclusion that the SDNP has been given....strange that !! Unfortunately Chichester Harbour does not have a landed Estate as its neighbour !!

AL6 is on a category 3 Floodplain , which under Governments own rational means that it should not be developed for housing or industry at all because of the unacceptable flood risk and only then developed if ALL other less risky sites have been developed first and only then for suitable light use. Land to the south of the SDNP has been removed due to it being under risk of flooding and yet it is mainly classed as Flood zone 2 , a lesser risk. So why was it removed for this reason and AL6 left in place ?
INCONSISTENCY and BIAS. REMOVE AL6.

Under CDC own data, a link road would need to be elevated to 4 metres in order to be safe from flooding.How on earth are you going to mitigate a road that high which is on a flat topography with historic views of Chichester and the Cathedral ? .This would then contravene Government policy on pollution and housing , as the toxic fumes from the road would reach higher into the air.REMOVE AL6.

This link road and Options 2/3 were hugely unpopular in the 2016 Highways England Democratic Consultation and were emphatically rejected by the vast majority of Chichester residents as they knew it would be short term and ineffectual and that along with the no right turns at junctions would hugely hinder the movement of local traffic. CDC were seen to accept that and Cllr Dignum said that "any Highways improvement should mitigate congestion on the A27". Clearly this scheme would not and so why is the link road included. If you want an unbiased complete Plan then surely the mitigated Northern route should have been included in this plan as the criteria are the same...no funding and no HE acceptance, or exclude both proposals. Again double standards to the detriment of the south.No roads should have been included as they do not come under CDC remit or funding and the protection under Para 3 AL6 is unachievable. Total betrayal under Cllr Dignum leadership.REMOVE AL6

In order to instigate a link road , junction upgrades are also mentioned...(but not funded by CDC and no consultation evidence with HE in the Local Plan S23 and PBA report) Each junction is estimated to take a minimum of 3 yrs to complete, that's 15 years of gridlock, air pollution and misery. Seriously. Chichester city and tourist industry would be destroyed. REMOVE AL6

There is no mention of only a 100 metre border with the Chichester Harbour AONB and yet frequent reference is made to the SDNP 1km border. Double standards and inconsistency again.REMOVE AL6

There is no mention that the land earmarked in AL6 is floodplain 3 category. Frequent reference to SDNP/Goodwood being in Flood zone 2 and a small amount in Flood plain 3. Again double standards and inconsistency. REMOVE AL6

No mention to the destruction of the views and yet time and again SDNP/Goodwood views of the Cathedral are mentioned and pushed. The views from SDNP/Goodwood are far less prominent and actually are invisible because of the topography of the land in many places. Not the case for views in AL6 where uninterrupted views of the Cathedral can be seen from the coast in almost any position looking north. Double standards and inconsistency again.REMOVE AL6

No amount of mitigation could protect Chichester Harbours unique ecology. It has status as an AONB, SPA,SAC,SSSI and is a Ramsar site. There is no detail of how a successful buffer zone would be applied.There appears to be no room for a proper successful wildlife buffer zone, with proposed building up to 100 meters of the harbour.There would be significant adverse ecological damage done, from light, noise and especially air pollution,which already breaches Government and EU safe levels. There is no mention of waste water management and the capacity for any further waste water to be processed at Apuldram Water Treatment plant is not an option as it has reached capacity so the risk of polluted water entering Chichester Harbour is incredibly high and an unacceptable risk.(Policy S18) REMOVE AL6

There are other much more suitable areas already identified around Goodwood Airfield and Rolls Royce which meet the criteria set out in the plan for housing and light industrial employment and already have suitable infrastructure but have been unjustifiably removed. These should be reinstated and AL6 REMOVED.

Any development of AL6 would necessitate movement by car due to its proximity to the A27 .This is against CDC Local plan policy of encouraging any new developments to either be well served with public transport or sustainable transport ie cycling and walking. The position of this site will not meet this criteria. REMOVE AL6.

There is no mention of the fact that this site is part of the River Lavant floodplain. Those of us who remember the 1990's , remember the hugely damaging flooding that affected Chichester partly because the water courses and natural drainage had been allowed to deteriorate. AL6 covers a significant part of the River Lavant natural drainage basin. It would be insane to build on this land. It could well result in renewed flooding in the city centre as we get wetter winters and the rain water has no where to go.REMOVE AL6.

The plan is totally inconsistent as to numbers in the development. How can we possibly comment on a plan that in one place states there would be 100 houses and industrial units in AL6 and yet elsewhere it says 200 + homes and industrial units. Ridiculous inconsistency and very unprofessional. REMOVE AL6.

Unless all these issues are adequately addressed in future iterations of the plan, I will raise these with the examiner at the appropriate time.

In summary, The CDC Local Plan in its form at present should be rejected and rewritten with the inconsistency and bias removed. Any development site should only be include when a proper and realistic viability study has been commissioned by independent consultants who will have been given a complete and unbiased brief (unlike the PBA study which is incomplete ,short term and does not reach the brief that was supposedly set). This is hugely important to the Chichester area and its residents. We want and deserve a fair ,complete and transparent plan and this version is not.

CDC along with WSCC should go to central Government and insist that until proper funding is put in places to sort the transport/A27 and services (Schools etc) infrastructure out then although the Plan can be written, no housing will be built until funding has been secured and work started on this vital infrastructure. We cannot sustain this level of development without serious investment on infrastructure and the addressing of dangerous pollution levels because of the lack of it.

Until this Plan has been fairly and properly amended so it provides a properly informed, fair and complete document it should not be adopted and should then be rewritten and only then reissued for full public consultation again. Unless this is adequately addressed in future iterations, I will raise it with the examiner at the appropriate time.

Policy S23 is not acceptable as this is similar to the Highways England Option 2 which was comprehensively rejected by the public. If S23 were to be implemented according to the Peter Brett consultation then The South Downs National Park (SDNP) should have to take more housing and trade development to relieve the pressure that would be put on the Manhood Peninsula.
The Manhood cannot cope with any more development without having a complete upgrade of the A27, not the Peter Brett S23 option.
The SDNP (Policy S3, Policy S5 and Policy S19) should share some of the development or have a northern route around Chichester.
Site AL6 Land South West of Chichester (Apuldram and Donnington Parishes) is within a flood plain with the River Lavant running directly through the middle of the area.
This area should remain a strategic gap between the two parishes and efforts concentrated on the area being more gainfully used as a green wildlife corridor.
This area should be removed and use the alternative land near Goodwood; Policy AL6, S15, S16.

The allocation of 500 homes in the Chidham and Hambrook area is excessive and is not supported by the Council's Sustainability Appraisal.

I object because:
1. The Local Plan promotes the joining of settlements between Chichester to Emsworth, which will adversely impact the special and unique character of these villages. This is in line with the Parish Council's response to Policy S2 Settlement Hierarchy.
2. The Local Plan Review has failed to make a proper distribution of housing in the Parish. The so-called comprehensive selection process undertaken by the planners in their Strategic Site Allocation exercise, and subsequently approval by the District Councillors, is woeful, as it is simply based upon developers' estimates, which have not followed the density benchmarks as per Policy DM3, and also have not been moderated for locations adjacent to sensitive locations. (as Parish Council's response to Policy S2 Settlement Hierarchy.)
3. The Infrastructure Delivery Plan -http://www.chichester.gov.uk/CHttpHandler.ashx?id=31025 (Pages 106-111 for our Parish) which supports the Local Plan is not fit for purpose. It does not adequately address the transportation, educational, medical and general amenities needs of the area that will take a long time to put in place, and not in time for a community which is expected to grow by over 50% in the plan period. This also includes the ongoing debacle about plans for the future of the A27, while in the meantime the A259 takes an ever increasing volume of local traffic. See Parish Council's response AL10/SA10 S23.
4. The Spatial Vision and Strategic Objectives (section 3.6 of the Local Plan) and the Sustainability Appraisal in relation to Chidham and Hambrook are contradictory. See Parish Council's response Policy S26/DM19 Natural Environment. If the latter prevails we will see the loss of key landscape views, the loss of high quality grade 1 and 2 farmland, a further deterioration in water quality, and further increased disruption to internally important migrating birds.

Whilst everyone in the parish fully acknowledges it has a responsibility to contribute to the need for more new housing in the District, there is no justification for the 500 homes slated for Chidham & Hambrook, a number which is excessive and not supported by any documentation.

Most importantly, it is also at odds with the standard method for assessing local housing need, based on the recently reduced ONS estimates of local housing requirements which, In September 2018, revised down its previous 2014 estimate of 210,000 new households per year to 159,000 per year in England, a huge reduction of 25%

It is also highly likely that there are reduced affordability ratios in the Chidham and Hambrook area compared to Bosham and Fishbourne which are closer to Chichester (this area is likely closer to the Havant figure of a 9.2 price to earnings ratio rather than the Chichester one of 13.5)

Adjustment factor equation to take account of affordability

There is also no account taken of the release of properties from landlords for sales in the area. As the affordability factor on new houses is 9.7, and existing houses 7.6, there should be a focused campaign on driving landlords to sell more houses already in the area, rather than building new ones.

For all the reasons given above the allocated number of houses it was stated should be significantly reduced by at least 50%, to 250 houses
Maximum

Finally, dealing with two specific local proposals by landowners:
1. Orchard Farm, Drift Lane - this campsite and caravan site has been offered for development. This single track road is already blocked by construction traffic for a single house currently being built. It is not conceivable that access for any construction traffic would be practicable to build any future house in Drift Lane.
2. Baileys fields - Pallant homes. Based on all of the considerations given above, this development is too large altogether at 500 homes.

Developer viability assessments

It is also notable that, when houses are built, developers do not make the most of the land that they own. Many housebuilders hide behind the viability assessment in not building a suitable number of affordable homes. The government has said that "this assessment should only be used when circumstances have made the council's requirements literally impossible." In all case developers trying to hide behind viability assessment should be made to publish their reasoning so that the local public can scrutinize it and, if the developers refuse to do this, their plans should also be refused.

I write to express my comments on The Local Plan - Preferred Approach

I have lived in West Wittering on the Manhood Peninsula for the last 19 years.
The Manhood Peninsula is a unique area which relies heavily on tourism, agriculture and horticulture; within its boundaries lie the Chichester Harbour Area of Outstanding Beauty (ANOB) and the Pagham Harbour Local Nature Reserve (LNR).
It has only 2 main access roads leading to the A.27.

While I have huge sympathy for the CDC being dictated to by the Government in relation to how many houses, retail units and commercial development they wish to see built, they do not take into consideration the countryside they want it built on.

Therefore I cannot support your view of the way forward (up to the year 2035) as being manageable or workable.

The one massive sticking point is the A.27 itself. I believe there is a considered view that the A.27 in its present form and the proposed northern route round Chichester (2016) is unworkable and unaffordable - the present southern route being unworkable and the northern route unaffordable.
The proposed spur road AL6 (which is Option 3 from the 2016 consultation which was dismissed as it was admitted the road would have to be upgraded to a dual carriage way within 12 years to cope with the increased traffic) from the Tesco's roundabout to link with the A.286 via a roundabout would merely push the traffic south and cause further havoc = eg: cars wanting to access the new Chichester Free School would have to then drive across Wophams Lane, through Hunston to the school, both roads are narrow and are not capable of coping with a huge flow of traffic. Those roads are already used by locals who wish to avoid the congestion on the A.27.

Once upon a time there were traffic lights on the A.27, these were removed and replaced with roundabouts, now you propose to put back traffic lights at the Stockbridge and Whyke roundabouts with no right turn if you are driving in a west - east direction. I have heard the cost to be in the region of £80 million pounds, money you do not have. Just leave the A.27 alone until someone with a vision of the future needs of Chichester has the guts to implement a northern route.


I quote 2 reasons why: An accident on the A.286 on 2nd February 2019 closed the road for 5 hours; a cyclist was killed on 10th May 2018 the A.27 was closed for approx 9 hours. The surrounding roads and Chichester were gridlocked.

The minimum number of houses the CDC proposes to build are: the Manhood 1,933, an east-west corridor of 10,056, with a token number of 489 for north of the area plan make no allowances for the inadequate number of police, doctors, schools and transport we already have in place. The East Wittering's Medical Centre had listed over 10,300 patients registered in 2018 - where is the provision for more medical centres?
All these extra houses will have at least one car per family, reality says two cars; how on earth is the A.27 going to cope with these larger numbers when it cannot cope with today's numbers?

The A.27 is the crux of the problem - get that sorted; then the CDC will have a mandate for the future.

The following are my general comments on what I consider to be serious problems that are likely to be encountered with these latest proposals.


Based on past experience I think it fair to say that will be big problems with the lack of sufficient infrastructure (money).


Look at where we are with the current Local Plan:-


Roads - increasing traffic, but crumbling roads, no A27 bypass solution.


Foul Drainage - denials by Southern Water that there are problems. Proposal to run a sewer from Whitehouse Farm around north of Chichester to Tangmere instead of upgrading Apuldram WW treatment works. Sewer pipe problems at Bosham and elsewhere. Untreated sewage discharged into the harbour. Increasing danger to public health.


Education - existing schools short of funding Police - also short of funding
Hospitals - under pressure


The latest Plan will substantially increase the amount of development in the East - West corridor along the A259. This is likely to have an adverse impact on the wild life in the Chichester Harbour AONB, with increased public use of the shoreline footpaths.


I thought the AONB had the same status as a National Park. Surely any ideas for development likely to affect it should be treated in the same way as the NP?

The actual control of when building takes place once permissions are granted seems to rest entirely with developers?

Chichester District Council
Local Plan consultation 2018/19

Comments by
Anthony Tuffin

1. There is no simple and intuitive way to comment online. A cynic could be forgiven for suspecting that the web designer had been instructed to make it difficult for the public to comment. So, I am commenting by e-mail.

2. Summary:
2.1 Selsey is not a hub.
2.2 Opportunities have been missed for development north of Chichester.
2.3 Manhood cannot cope with more development until a new A27 has been built north of Chichester.

3. 6.79 describes Selsey as 'settlement hub', but goes on to state that "it is located at the southern end of the Manhood Peninsula (Selsey Bill)" and 6.81 states, "The B2145 is the only road connecting the town to the north" As there is sea to the east, south and west of Selsey and only one road to the north in and out of the town, it is not a hub. Indeed, it is at the circumference end of just one spoke.

According to the Oxford English Dictionary, "hub" means;
* The central part of a wheel, rotating on or with the axle, and from which the spokes radiate.
* The effective centre of an activity, region, or network.
* A central airport or other transport facility from which many services operate.

I.e., "centre" or "central" is the key part of the meaning, but Selsey is neither a centre nor central.

4. The Council should not import housing need that the South Downs National Park (SDNP) refuses.

5. The Chichester District cannot accommodate future housing or employment space until the A27 uncertainty is ended. The local population rejected Highways England's last proposal.

6. Para 3.4 omits development opportunities north of the city. Including these would help us reduce the pressure to the south where there is a lack of appropriate space because of the flood plain.

7. Para 3.7 states, "The relationship between the National Park and significant natural areas to the south, especially Chichester Harbour Area of Outstanding Natural Beauty, will be carefully managed by maintaining and enhancing the countryside between settlements." How, then, can you justify the proposal at Apuldram, which would remove the only view of a cathedral from the sea in the country and long-distance views of the downs?

8. Para 3.19 Strategic infrastructure excludes the Mitigated Northern Route. Tweaking the existing A27 lacks local community consensus and would prevent us from getting a long-term solution; i.e., a strategic northern route.

9. Policy S4 Why is there no housing planned for the area between the city and the SDNP to relieve the pressure south of the city?

10. Para 4.84 "Some funding for the A27 junctions package of improvements has already been secured from planning permissions granted to date." The population of Chichester have asked for a new strategic route for the A27 endorsed by both CDC and West Sussex County Council (WSCC) in a democratic process.
We should not spend money to improve a road that is Highways England's responsibility.
It is Highways England's responsibility to provide a suitable trunk road for the south coast and it is the Government's responsibility to fund it.
CDC cannot accept housing allocation for the Manhood Peninsula surrounded by the sea and the congested A27 until the congestion is relieved.
11. DM24 air pollution. There seem no recommendations for the reduction in air pollution. As the prevailing wind is from the south-west, the best long-term solution would be to site the A27 north of the city.

End.

I have a number of issues with the PLAN.
The old plan has not expired yet a more aggressive plan is being introduced.
Few people have commented.
A mail shot to all residents should be implemented outlining the individual aspects
The A27 Junction alterations appear to be a "southern route" by stealth.
The Appuldram link road in particular is of serious concern what with its proximity to the Harbour.
No provisions for education have been met on previous big builds how can we be assured that planning for education will in fact be carried out.
The intensity of build projects appear to have exceeded the current plan targets, why impose a greater plan ahead of requirement.
A stronger opposition to building the large scale developments should be implemented.
Of the new build how many will be for Chichester residents. If outside families move into the borough their children's requirements will only exasperate the future housing requirements.
What properties are for current residents and will a rule apply to prevent outside occupation.

My main concern is that the PLAN is too big and complex for many to fully understand and longer should be taken to fully explain the implications.

We have no comment to make on the detail of your plan but we recognise the similar issues our two local planning authorities face in relation to planning for housing with regards to part of our districts lying within the South Downs National Park.

We would therefore welcome a discussion around this matter at our forthcoming Duty to Cooperate meeting.

4.4.2 and Table 3 4.6.4 , 4.7.3 Sustainability Appraisal 010

This Sustainability Appraisal is full of highly subjective notions which leads its impact assessments to be generally questionable ie on whether an option has a positive or negative impact on eg biodiversity.
In para 4.4.2 who were the "further discussions" with to cause scenario 1a to be added ?
Para 4.6.4. in trying to justify the allocation of 1250 dwellings to Southbourne, it talks of the "potential advantages" but does not mention the obvious disadvantages in almost doubling the population of this village. What provisions will the plan make eg to ensure that the Southbourne railway station is capable of handling possibly a doubling of passenger traffic.? The answer is that it can't because investment in the railway network is outside it's jurisdiction. I would only support an option that shares any new housing more evenly between settlements which is more likely to limit the obvious damage that is going to be caused to natural habitats by this Local Plan review.

What improvements or changes would you suggest?

As above.

003 Housing and Econ Devt

This document appears to rely for it's conclusion of new housing numbers on the unbridled continuation of economic growth levels through the Plan period to 2035[par a 1.17].I believe that this is an unsustainable model on which to plan the future for our children and grandchildren.
There is no attempt that I can see to apply some sort of sensitivity analysis to the single end figure of 609 dwellings per annum so that lower numbers could be chosen as a preferred option. There are many factors which could influence housing numbers over the long Plan period so it would seem sensible to start with lower numbers to try and reduce the inevitable negative impact on natural habitats that any increase in human numbers will cause.

What improvements or changes would you suggest? As stated above

5.5 in particular Strategic Wildlife Corridors Background Paper

Whilst supporting the concept of Wildlife Corridors in the Plan [why was this not done 20 years ago ?] I do object to the removal from the Plan Review of the Chidham/East of Nutbourne Wildlife Corridor. If the Southbourne Neighbourhood Plan Review [SNPR] wishes to give more priority to natural habitats then it can devise policies which avoid "the close proximity of...proposed development" cited in paragraph 5.5.
Glossary - Wildlife Corridors are not defined in the Glossary and should be included.

What improvements or changes would you suggest? As stated above.

All but especially sub-areas 82 and 83 Landscape Capacity Study - 007

Apart from it being a useful inventory of landscape types in Chichester District, this document appears to me a rather pointless exercise in Planning fudge. For example on page 496 in is saying that development could be accommodated etc etc at the same time as avoiding any "landscape or visual harm " This sort of language is found all over this document and givers too many opportunities for misunderstanding or misinterpretation.
It would have been helpful to have page numbers for the sub-areas. As it is the location of sections is prolonged.

What improvements or changes would you suggest?

Avoid attempts to give facile conclusions and recommendations.

Paras 5 and 7 various Natural Environment

Para 5.51 [Strategic Policies] suggests the Council will only object to development that causes "significant harm" to the function of the natural environment but there is no definition of this phrase
7.168 Is stating that "providing open space, sport and recreation is part of "protecting and enhancing the natural environment" This is not true as these are all man-made features designed for humans, not for nature.
Para 7.189 and others mention "priority habitats" but I can see nowhere in the Plan Review that identifies the 21 types of these habitats mapped in Sussex* either by list or on a map of the District.These important habitats are often overlooked when development applications are made [eg ref 16/03569/OUT] and this Plan is a good opportunity to draw the public's attention to those in their area.
Para 7.189 refers to a Map 5.1 but gives no easy reference to where this can be found ?
Note: *Sussex Biodiversity Record Centre records these as "Habitats of Principal Importance" - which designation is correct ?
Glossary issues: Priority Habitats are missing and should be included in the Glossary in the Plan Review.

As a consultation we assume that means you will listen to comments and make changes based on the views of locals affected by this Plan. Otherwise why would you go out to consultation except to meet legal requirements!


How do you justify the plan to enforce 250 Neighbourhood Plan Lead houses on Fishbourne. There is no justification for this number other than the chance of land being available. If Fishbourne new neighbourhood plan can only agree on say 200 homes this ought to be acceptable as it would be plan lead.

You talk about Minding The Gap between villages but then close the gap by proposing large scale developments at Highgrove Farm in Bosham and Bethwines at Fishbourne....... We MIND the GAP and this should not happen.....you well know that if any houses are allowed in Bethwines the developers will pester and worm until they get 1000 houses and then the gap will gradually disappear and Fisham or Bosbourne will be the new name of the once two villages.

All of this is of course illegal as it will (with the other houses along the A259) make the pollution level at Fishbourne and the roundabout even worse that it is at the moment !

Who will be liable for causing this extra illegal pollution? Will it be Planners or Councillors or will it be central government .......The answer of course is nobody!!! We will all have to suffer !

Why do CDC have to take extra houses because the South Downs "cannot" ...they should be told to make 10 extra houses, for locals only, in each village or hamlet...

We hope that these issues will be taken notice of and not just added to all the other objections and ignored .

Thank you for the consultation on the above document. We have reviewed the document and have the following comments to make in response.

Summary
Overall we are pleased to see that the Plan provides a framework to ensure that new
development will take place in a considered manner to address environmental constraints as well as provide policy hooks for the delivery of environmental enhancements. However, to ensure that the Plan is as effective as possible and meets necessary policy and legislative requirements we have made some recommendations for improvements. These are set out in detail below. Where we support a policy we have also highlighted this below.

We have highlighted concerns with policy AL6 - Land SW of Chichester and have made recommendations for more significant changes to policies in relation to flood risk management (both strategic and development management) and wastewater management and water quality.

As a general comment we note that a significant proportion of the housing numbers
proposed through the Local Plan will be delivered by Neighbourhood Plans. We have
highlighted key criteria for individual locations that we would wish to see considered by those Plans when allocating sites. Where possible we would wish to see these included within the Local Plan policy but as you will be aware we have produced a checklist for Neighbourhood Plan groups in your District which will guide the identification of sites and other key issues and opportunities to be addressed in their Plans.
We would be happy to meet with you to discuss further any of our comments and support the rewording of the policies prior to the production of a pre-submission Plan.

Specific comments

Strategic policies
Policy S12 - Infrastructure
Overall we support the policy. We would recommend that paragraph 3 be amended to
include reference to flood risk management infrastructure.

Policy S17 - Thorney Island
We are currently exploring opportunities for habitat creation in an area on Thorney Island. This is part of our Habitat Creation Programme which seeks to create new habitat to offset losses elsewhere as a result of sea level rise and implementation of coastal and flood risk management infrastructure.
Whilst the policy as drafted, along with other policies in the Plan, would not restrict this opportunity we would like you to consider whether further wording could be included to provide specific support for habitat creation.

Policy S18 - Integrated Coastal Zone Management
We support the continued inclusion of this policy and the specific references to key Plans.
We also support the intention that financial contributions should be sought to deliver both flood risk management infrastructure as well as improvements to the quality of watercourses in the area.

Policy S20 - Design
We support the specific requirements of this policy in point 5 and 8 with regard to green infrastructure and enhancing biodiversity and climate change resilience.

Policy S23 - Transport and Accessibility
The policy includes a new road connecting Birdham Road to the A27 Fishbourne
roundabout. The site includes areas within flood zones 2 and 3 and will cross a number of watercourse. It is essential that the requirements of the NPPF paras 157-8 are satisfied prior to the allocation. We have made detailed comments on this in relation to policy AL6 - Land South West of Chichester.

Policy S25 - The Coast
We are pleased to see the support in this policy for future habitat creation as well as the delivery of flood defences and adaptation to climate change. This supports principles of net environmental gain advocated through the NPPF and the 25 Year Environmental Plan as well as providing necessary policy hooks to support our future plans through our Habitat Creation Programme.
As we highlighted through the Issues and Options consultation this Programme was set up to deliver the compensatory habitat required to address the losses in habitat that would take place as a result of the flood and coastal risk management measures identified in the Shoreline Management Plans. There are specific locations within Chichester District which offer opportunities to provide saltmarsh and coastal grazing marsh in the medium to longer term. These locations include areas in Fishbourne, Chidham and Hambrook and on Thorney Island.

Policy S26 - Natural Environment
We would recommend that the policy wording be extended to say "protect and enhance biodiversity". This is consistent with the NPPF requirements in para 170 regarding net gain and current Government proposals to mandate biodiversity net gain for all new developments.

Policy S27 - Flood Risk Management
We support the intention of the policy, however, we would wish to see changes made to ensure the policy is as clear as possible. We would also recommend you consider what a strategic policy on flood risk management is seeking to achieve in addition to the development management policy. As drafted there are some duplications and/or inconsistencies between the two policies.
It may be more prudent to have a shorter overarching policy that seeks to ensure that flood risk will be taken account of at all stages in the planning process in order to avoid inappropriate development in areas at current or future risk (taking into account climate change) and to direct development away from areas of highest risk. Reference could and should be made to the Strategic Flood Risk Assessment to enable this. We would also support a requirement here for development to seek to achieve a reduction in flood risk for existing communities on and off site.
The principle of point 3 is supported but again should be considered whether it sits best within the development management policy.
We would recommend removing point 4. It is not clear entirely what the rationale behind this is but as drafted it suggests that development within areas with a certain level of flood risk would be approved. This should only be the case when the sequential and exception test have been satisfied in accordance with the NPPF paragraph 157- 8. I would be happy to discuss this further if the intention behind the statement is different.

Policy S29 - Green Infrastructure
We support the policy and are pleased to see specific reference to "blue" infrastructure.

Policy S30 - Strategic Wildlife Corridors
We are supportive of this policy and believe it provides a strong framework for the protection and enhancement of biodiversity within the Plan Area. In particular we support the corridors along watercourses and the links with Biodiversity Opportunity Areas.
As previously highlighted in our Issues and Options response to the Local Plan the
Environment Agency are looking to deliver more natural flood management (NFM) measures to complement and support traditionally engineered flood defenses. This is about working with natural processes in whole catchments and has the potential to help us manage and reduce flood risk in a more efficient, cost effective and sustainable way whilst securing wider environmental benefits. We would be interested to discuss whether the Strategic Wildlife Corridors Background Paper could be expanded upon to consider these opportunities.
A nationally consistent set of opportunity maps to indicate potential for natural flood
management have been produced and I have attached a briefing not which shows how you can access this screening information. The identification and safeguarding of wildlife corridors could support our further work on NFM in the Chichester District and we would welcome the opportunity to discuss this further. In particular we would be interested to discuss whether the Strategic Wildlife Corridors Background Paper could be expanded upon to consider these opportunities.

Policy S31 - Wastewater Management and Water Quality
We support the intention of this policy, however, we recommend that the policy is amended to ensure that specific issues associated with the Apuldram WwTW catchment are addressed and that wider opportunities for the necessary protection and enhancements of water quality in the catchments across the Plan area are taken forward through development. As drafted the supporting text to the policy talks primarily around wastewater treatment capacity and impacts on water quality. However, we would recommend that this is expanded to discuss wider water quality and water resources issues within the Plan area.
This should include reference to the Water Framework Directive and the South East River Basin Management Plan, for which the Council has an obligation to support their delivery.
We would wish to see the Plan include a policy that will ensure that the design and location of development will both protect and enhance water bodies, both surface and groundwater.
We are aware of a few adopted policies regarding water quality that you may wish to review ahead of the further iteration of your Plan. These include policy W DM1 - Water supply and quality in the Arun Local Plan and Policy 31 - Integrated Water Management and the water cycle in the Cambridge Local Plan. The Policy in the Arun Local Plan is subdivided in to 3 sections to cover issues of water supply, water quality and catchment specific measures.
This approach or layout may be useful for you to consider here.
You may also wish to consider whether there are elements of this policy that would be better situated in a development management policy to direct decision making on individual sites.
I would be happy to work with you further to develop this policy, however, to support this the following identifies some key wording that could be included:
"All new development must demonstrate:
* That it has no adverse impact on the quality of water bodies and groundwater, or will prevent future attainment of good status;
* That development contributes positively to the water environment and its ecology and does not adversely affect surface and ground water quality"
This will reflect that impacts on water quality will not solely relate to wastewater infrastructure but can include diffuse pollution as well as physical changes to watercourses.
With regard to the specific requirements for the Apuldram WwTW the policy as drafted broadly reflects the current adopted Plan policy. Would there be an opportunity here for the policy to reflect elements of the recently endorsed Position Statement between the Environment Agency and Southern Water in terms of managing development in the catchment?
The policy makes reference to the higher building regulations standard of 110 l per person per day. We support this standard but would recommend you consider whether this detail is needed in this strategic policy as well as development management policy DM16 - Sustainable Design and Construction.

Site Allocations
Please note we have no additional comments to make on the sites that are being taken forward from the current adopted Local Plan as we consider that the key policy criteria we sought at that stage has been transposed across. We continue to support these requirements.

Policy S32 - Design Strategies for Strategic and Major Development Proposals
We support this policy and specifically requirements for issues such as green infrastructure and SuDS to be fully considered through a Masterplan. Without this overarching vision for larger sites it is often difficult to provide a comprehensive scheme to address key environmental constraints and opportunities.

Policy AL13 - Land East of Chichester
There is a small area within the site located in Flood Zone 2, along with an additional surface water body (lake). We would recommend that the masterplan for this site fully considers these constraints in designing the site including the adopting the sequential approach. We would wish to see built development located solely within Flood Zone 1.

Policy AL 5 - Southern Gateway
We have previously made comments on the proposals for the Southern Gateway through the adopted masterplan for the site. As highlighted there are a number of constraints to development in this area, however, we are pleased to see specific criteria in the policy toensure that these key constraints to the site within our remit are fully considered.
These are:
- Bullet 8 which requires the provision of a wastewater management plan which
demonstrates no net increase in flow to the Apuldram WwTW. This is in line with the
Surface Water and Foul Drainage SPD and the Position Statement on managing new
housing development in the Apuldram (Chichester) Wastewater Treatment Works
Catchment agreed between the Environment Agency and Southern Water.
- Bullet 10 which sets out the requirement for a Flood Risk Assessment to address the
specific flood risk issues on the site. We would recommend that this policy criteria
could be expanded upon to require the sequential approach within the site and to
ensure that more vulnerable uses such as housing be located in the lowest areas of
flood risk.

Policy AL6 - Land SW of Chichester
At this stage we do not support the inclusion of this site within the Plan.
The allocation is composed of housing, employment and a road scheme. Large areas of the allocation falls within flood zones 2 and 3 and we would wish to see further evidence to support this allocation. This may be as part of a Level 2 Strategic Flood Risk Assessment for this site which would then inform a Sequential and if necessary an Exceptions Test. The assessment would need to consider how the proposals could be delivered and identify any mitigation and/or compensation measures that may be necessary to ensure that the development is safe and that there is no increase in flood risk to third parties.
Whilst we note that there are areas outside of the flood plain within the allocation and that some of the development could avoid these areas it is anticipated that the road would cross the flood plain and therefore further detailed understanding of this risk and how it would be managed should be provided.
As drafted the policy makes no reference to flood risk and we would wish to see this
amended.
With regard to housing development we would wish to ensure that all development be located in Flood Zone 1 and that the policy criteria would reflect this.
Other issues include the crossing of watercourses and impacts on biodiversity and water quality. This should be referenced within the policy criteria with requirements for any watercourse crossings to be clear span in design. This will ensure that flood water conveyance is not impeded and protect the habitat associated with those watercourses.
In addition to flood risk we also have concerns with regard to where the sites wastewater would drain to. In line with our Position Statement on managing new housing development in Apuldram (Chichester) Wastewater Treatment Works Catchment allocations within the Local Plan should not drain to the Apuldram WwTW but be directed to alternative WwTW catchments, notably Tangmere WwTW via the new sewer pipeline connection once operational.
It is difficult to understand how this site would connect to an alternative WwTW and therefore would question whether the site would be deliverable.

Policy AL9 - Fishbourne
Fishbourne parish falls within the Apuldram WwTW catchment and we would recommend that the policy makes specific reference to the issues that the Neighbourhood Plan group should consider when identifying sites for their Local Plan.
We would also recommend that specific reference is made to the Source Protection Zone that covers part of the parish in order to ensure that the groundwater, and in turn the drinkingwater supply, is protected.

Policy AL11 - Hunston
There are parts of Hunston that fall within flood zones 2 and 3. We would recommend that if possible the policy makes reference to the fact that built development should be located solely in Flood Zone 1. If this is not possible some reference would need to be made to flood risk and the requirement for the Neighbourhood Plan group to fully consider this through their site allocation process. If sites were to be allocated in flood zone 2 or 3 it is likely that the Plan would need to be supported by a Level 2 SFRA or equivalent.

Policy AL13 - Southbourne Parish
Point 16 identifies the need to ensure that sufficient capacity is available at the relevant Wastewater Treatment Works prior to the delivery of development. This could be expanded to include sewer network capacity. Liaison with Southern Water regarding any necessary phasing of development would be encouraged.

Development Management Policies

Policy DM5 - Accommodation for GTTTS
We support the specific criteria in this policy to ensure that GTTS sites are not located in areas at risk of flooding.

Policy DM14 - Caravan and Camping Sites
We support the particular reference to restricting the occupancy of these sites in flood risk areas. However, there is no specific mention that flood risk areas should be avoided where possible. We would recommend that this should be included within the policy criteria.

Policy DM15 - Horticultural Development
We are pleased to see specific reference to the need to demonstrate adequate water
resources are available and/or water efficiency measures.

Policy DM16 - Sustainable Design and Construction
We support the requirement for new development to achieve a water usage of a maximum of 110litres per head per day.
For completeness we recommend that point 5 should be expanded to include compensation as well as make reference to net gain. This is in line with NPPF para 170.
We support the requirement in point 8 with regard to measures to adapt to climate change.

Policy DM18 - Flood Risk and Water Management
para. 7.115 - reference to the Environment Agency should be removed from this sentence.
The responsibility for surface water drainage and consideration of SuDS sits with West Sussex County Council as the Lead Local Flood Authority for this area.
para. 7.116 - vulnerability - it should be noted that not all development types would be appropriate in all flood zones. Basement dwellings would not be supported in flood zone 3. This paragraph should be amended to reflect this.
We would recommend that you review this policy alongside the strategic policy on flood risk to ensure that they are complementary. Whilst the intention of the policy is good some further clarity could be provided to ensure that all sources of flood risk are considered through decision making.
As drafted there is no reference to the Sequential Test which is a key step in decision
making with regard to proposals in a flood zone. It appears that a number of the criteria included in policy 42 of the current adopted Local Plan have been stripped out. We would recommend further consideration of this for the next iteration of the Plan.
We note that the policy also makes reference to wider water management and does refer tothe South East River Basin Management Plan, however, as per our comments on policy S31 we would wish to see a specific policy that provides for the protection and enhancement of water quality. It may be prudent to consider whether an overarching strategic policy to address flood risk and water management would be best with separate detailed development management policies for each topic.
We would be happy to work with you regarding this detail.

Policy DM20 - Development around the coast
We support this policy and the requirement to safeguard a strip of land behind existing or proposed sea defence or coastal works. Please note that the Environment Agency would seek a 16 metre buffer behind any of our tidal defences.
We support the specific requirement to ensure that development for boat or marine use would not be detrimental to water quality.

Policy DM24 - Air Quality
We are pleased to see that this policy recognises that new development may be located near to existing uses that may be potentially polluting to housing. It is important that the onus should be on the developer/applicant to manage any impact to ensure that they don't leave the existing user affected, e.g. by complaints.

Policy DM26 - Contaminated Land
We support this policy as drafted.

Policy DM29 - Biodiversity
We support this policy as drafted and are pleased to see that specific reference has been
provided to ensure that net gain in biodiversity is actively pursued. Consideration should be
given to the current Government consultation on mandating biodiversity net gain in all new
development and whether this may require further strengthening of the policy wording.
Policy DM32 - Green Infrastructure
We support policy.