1.38

Sustainability Appraisals should be independently assessed for soundness and the. sections they inform be rewritten on that basis.

The SA's that have been undertaken appear to be have been done to fit the proposed site allocations not vice versa. Sites that seem to have a better sustainability appraisal seem to have been ignored/modified/rejected for no apparent reasons or wighting has not been given to sustainable items such as distance fromt transport hubs and ability and proposensity to offset/mitigate environmental factors have been ignored. I refer specifically to the HIghGrove and French Gardens sites in the Bosham section.

The Chichester Transport Study has concluded the southern planning area can generally accommodate 700 dwellings per annum, with proposed mitigation. The SA conclusion that there is capacity for no more than 535dpa is therefore fundamentally flawed.

The SA must be revisited given that this factual flaw goes to the heart of the process of selecting and testing reasonable alternative options. Consequentially, the draft CLP decision-making making process will also need to be revisited, as this too has been infected by the factually incorrect SA.

e) Sustainability Appraisal

2.43 By way of context to these representations, we note that the Chichester Transport Study, dated January 2023, concludes at paragraphs 5.6.5 and 11.2.3:

“5.6.5 It is concluded that in the main, the 700 dpa (southern plan area) demands can generally be accommodated by the mitigation proposed for the 535 dpa core test although at the Portfield roundabout and Oving junction, capacity issues get worse with the 700 dpa demands, with additional mitigation being required. As no schemes have been designed to date, it would be advisable to retain some costs against for future works against Portfield Roundabout as a minimum.”

“11.2.3 A sensitivity test with 700 dpa has been undertaken. It is concluded that in the main, the 700 dpa demands can generally be accommodated by the mitigation proposed for the 535 dpa core test, although at the Portfield roundabout and Oving junction, capacity issues get worse with the 700 dpa demands and these junctions may need to consider further mitigation. As no schemes have been designed to date, it would be advisable to retain some cost against for future works against Portfield Roundabout as a minimum. It is unlikely there would be significant capacity in the network beyond 700 dpa, considering full mitigation package.”

2.44 Although the Transport Study is dated January 2023, it is noted that the report’s Document Control Sheet (page ii) confirms it was first issued back in April 2022, and has since been the subject of revisions prior to finalisation.

2.45 The Transport Study conclusion that 535 dwellings per annum (dpa) was not an absolute ‘cap’ to housing development within the southern planning area was therefore well known to the Council during the time that the SA was being prepared to inform draft CLP decision-making process.

2.46 In view of the above, we are fundamentally concerned that the basis of the reasonable alternatives tested have been infected by a fundamentally flawed starting point conclusion that there is capacity for no more than 535 dpa within the southern planning area:

“The southern plan area (i.e. the east west corridor and Manhood Peninsula) is highly constrained by capacity on the A27. Detailed discussions with National Highways and WSCC, over the course of 2019-2022, have led to a resolution that there is capacity for no more than 535 dpa in this area” (paragraph 5.2.11, first bullet).

2.47 The SA must be revisited given that this factual flaw goes to the heart of the process of selecting and testing reasonable alternative options. Consequentially, the draft CLP decision-making making process will also need to be revisited, as this too has been infected by the factually incorrect SA.

Reference to ‘ancillary’ with regard to the HDAs in relevant policies and supporting text should be modified to 'functionally linked' and include explanatory text clarifying that 'functionally linked' uses can include a range of activities including: food-related distribution; food manufacturing linked to the HDAs food preparation; on-site renewable energy to serve on-site activities; and R&D.

Object

Paragraph 8 of the NPPF recognises an economic objective as one of the three core tenets underpinning achieving sustainable development.

The failure to allow for functionally linked development within the Runcton HDA that could not reasonably be construed as ancillary development, would unduly constrain the economic potential of the horticultural industry within the Chichester District. The development and siting of associated and functionally linked businesses within the Runcton HDA would support the continued creation of local jobs and assist at providing employment opportunities that meet the needs of the residents of the dwellings planned to be delivered within the Local Plan period.

The correlation between the draft allocation 20 for business development to locate at Land South of Bognor Road and Runcton HDA offers no guarantee that land or premises within that allocation would be suitable for, or become available at the right time, to perform a complimentary function for the Runcton HDA.