Policy S7: Meeting Gypsies, Travellers and Travelling Showpeoples' Needs

how can we be expected to comment when you have not provided the GTAA on your evidence page?
We were promised this would be published on 14 December. I can not find it
Please advise when it is uploaded and can be studied so that meaningful comments can be made

Sites for more than 6 units should be within easy reach of the A27 and all allocated sites should be proportionate in size and scale to the existing settlement.

Policy S7 as worded is open to misinterpretation: the start of the final sentence should be amended to read:
Existing PERMITTED traveller sites will be safeguarded...

Resident of West Wittering
There has been no national evidence that the number of plots should be more than that defined in the adopted Local Plan. The new numbers were derived from the G&T Community, which could be biased.

This policy has too many loopholes and will be easily abused.

Ensure the people claiming to be of traveller and gypsy heritage are genuine in a direct line of descent.

We raise objections to the approach put forward to deal with provision for Gypsies and Travellers.
The high level of need cannot possibly be met by adopting the approach set out in Policy S7.
Restricting site selection in the method set out is unrealistic. Additional sites will need to be found and this will require consideration of sites beyond settlement boundaries.
A criteria based policy is needed to deal with proposals which may come forward and this must be sufficiently flexible to meet the high level of need.
Without such an approach the plan will be unsound and will not be effective in meeting the need for Traveller provision.

The SDNPA and all relevant authorities are required to have regard to the purposes of the South Downs National Park (SDNP) as set out in Section 62 of the Evironment Act 1995. The purposes are 'to conserve and enhance the natural beauty, wildlife and cultural heritage of the area' and 'to promote opportunities for the understanding and enjoyment of the special qualities of the national park by the public.' The Authority would appreciate reference to Section 62 being added to
paragraph 1.31 of the draft Plan.

Duty to Cooperate

As set out in our previous response, the SDNPA has a set of six strategic cross-boundary priorities.
I would like to take the opportunity to again highlight these which provide a framework for ongoing Duty to Cooperate discussions:
* Conserving and enhancing the natural beauty of the area.
* Conserving and enhancing the region's biodiversity (including green infrastructure issues).
* The delivery of new homes, including affordable homes and pitches for Gypsies, Travellers and Travelling Showpeople.
* The promotion of sustainable tourism.
* Development of the local economy.
* Improving the efficiency of transport networks by enhancing the proportion of travel by sustainable modes and promoting policies which reduce the need to travel.

Conserving and enhancing the natural beauty

We welcome the requirement in policies S26 (Natural Environment) and DM28 (Natural Environment) to ensure that development proposals have no adverse impact on the openness of views and setting of the SDNP. It is noted that a substantial amount of new homes are proposed on the A259 corridor between Emsworth and Chichester. This is a sensitive stretch of land in the coastal
plain between the coast, the south coast railway and the A27. This corridor provides the connection, including intervisibility, between the protected landscapes of the South Downs National Park and Chichester Harbour AONB, for example views of the channels within the Harbour from the Trundle and Stoke Clump.
We note the intention of identifying settlement gaps and look forward to seeing the evidence base and the proposed gaps in the Regulation 19 iteration of Chichester Local Plan Review 2035, particularly as to how they will contribute to safeguarding the relationship between the SDNP and Chichester Harbour AONB. We would welcome the opportunity to work with CDC on this matter.

Locations identified for development

Development in the CDC Local Plan Review 2035, particularly along the A259 (policies AL7 Highgrove Farm Bosham, AL9 Fishbourne Parish, AL10 Chidham and Hambrook Parish, AL13 Southbourne Parish) corridor, have the potential to deliver a significant cumulative adverse impact on the setting of the National Park and its important relationship with the Chichester Harbour AONB.
We consider that the policy wording for the A259 corridor Strategic Site Allocations could be more robust and proactive with regard to conserving and enhancing the National Park. In particular, it could provide more active direction to applicants in order to ensure adverse impacts are minimised locally, and in relation to the National Park. For example, with regard to green infrastructure, each of the
A259 Strategic Site Allocation policies (AL7, AL9, AL10 and AL13) include a criteria requiring the provision of green infrastructure, and we would suggest this could be re-worded as follows: 'Identify opportunities are taken for and secure the expansion and provision of multifunctional green infrastructure into the wider countryside and protected landscapes of the South Downs National Park, and Chichester Harbour AONB, including between settlements and facilities.'

Reference to considering and minimising impact on the SDNP in each of the A259 Strategic Site Allocation policies (AL7, AL9, AL10 and AL13) is welcomed, for example criterion 5 of policy AL9:
Fishbourne Parish. However, this could be usefully re-worded to ensure that developers do not create a scheme and only consider the impact afterwards. Wording to direct people to 'respect and respond to the National Park landscape, its setting and purposes prior to development design' avoids the risk of relying upon ill-informed and inappropriate mitigation measures This matter could also be usefully
addressed in relevant Strategic and Development Management policies elsewhere in the Local Plan concerning design, landscape, and the South Downs National Park. We would be happy to work with CDC on this matter.

We note Strategic Policy S32, which requires proposals for housing allocations and major development sites to be accompanied by a site-wide design strategy. We would strongly encourage masterplans and development briefs for each allocation (or settlement where the sites are to be allocated through a Neighbourhood Plan) to come ahead of applications and demonstrate positive design interventions which respond directly to landscape/SDNP sensitivities. We would be happy to be involved in shaping these as consultees in order to achieve the best quality scheme. These interventions could be written in to the policy wording.

There is an opportunity for allocation policies to seek to deliver the joining up of existing, and/or improvements to, the network of RoW (Equestrians, Cyclists and Pedestrians) to enable and encourage access into the National Park in accordance with the National Park's Second Purpose.
Further comments on specific allocations:
* Policy AL1 (Land West of Chichester) - We welcome the consideration of the Centurion Way in criteria 10. However, we would ask for stronger policy wording to explicitly state that development must not adversely affect, and preferably enhance usability of, Centurion Way connecting Chichester with the SDNP.
* We note that Policy AL4 (Land at Westhampnett/NE Chichester) still refers to Lavant Valley greenspace but we query if this is likely to be secured now based on planning applications submitted. We would suggest that criteria 12, last sentence, could also refer to securing offsite improvements/upgrades for cycleway links
* Policy AL6 (Land South-West of Chichester (Apuldram and Donnington Parishes)) should address the important opportunity to secure a safe off-road connection between the Centurion Way and Salterns Way as the two flagship and largely safe off-road multi-user trails linking Chichester with (respectively) SDNP and Chichester Harbour AONB. We would welcome the opportunity for further dialogue and joint working on this matter with CDC.
* We welcome criterion 5 of policy AL14 (Land West of Tangmere). It is a sensitive site due to the impact on clear views of the site from important locations in the SDNP such as the Trundle and Halnaker Hill. We therefore ask that criterion 5 is expanded to emphasise and address the sensitivity of the site
Specific wording comments on other policies/paragraphs:

We have the following comments on the following specific paragraphs:
* Para 2.29 (challenges and opportunities facing the Plan Area): We suggest that the 7th bullet point should say 'Protect and enhance the character of the area including the Chichester Harbour AONB and the setting of the SDNP'.
* Policy S20 (Design): As mentioned above regarding the A259 Strategic Site Allocation policies, we consider that the wording of this policy could be more proactive by including wording to direct people to 'respect and respond to the National Park landscape, its setting and purposes prior to development design'.
* Policy S25 (The Coast): Paragraph 5.44: We suggest adding 'serves to provide important scenic views from the water across to the SDNP which should be conserved'.
* Policy S26 (Natural Environment): We suggest deleting reference to 'openness' and to include reference to views from and to the National Park.
* Policy S32 (Design Strategies for Strategic and Major Development Sites): We suggest that the policy requires such design strategies to be informed by landscape character and the sites landscape context. We also suggest that criteria h. includes a requirement to state maximum building heights.
* Policy DM17 (Stand-alone Renewable Energy): The policy requirement for demonstrating no significant adverse impact upon landscape or townscape character is welcomed. We request reference is also made specifically of views of the SDNP.
* Policy DM19 (Chichester Harbour AONB): We request criterion three also identifies the relationship by way of intervisibility between the AONB and SDNP.
* Policy DM22 (Development in the Countryside): Further to comments on the A259 Strategic Site Allocation policies and S20 (Design), we consider that the wording of this policy could be more proactive by including wording to direct people to 'respect and respond to the National Park landscape, its setting and purposes prior to development design'.
* Policy DM23 (Lighting): The reference to the South Downs International Dark Skies Reserve is welcomed. However, proposals that aren't immediately adjacent to the Reserve may have significant adverse impact, for example due to the site's particular visibility within the landscape or sky glow; we suggest that wording is amended to reflect this.
* Policy DM32 (Green Infrastructure): We suggest that this policy could benefit from specifically citing that green infrastructure should be 'multifunctional'. We also recommend reference to opportunities to make better green infrastructure connections in line with Lawton Principles of 'bigger, better, more joined up', to ensure these spaces can function and therefore deliver benefits.

Conserving and enhancing the region's biodiversity (including green infrastructure).

The SDNPA welcomes the approach taken by CDC to identify green infrastructure and habitats networks as cross boundary issues in paragraph 1.26 of the Plan. The SDNPA looks forward to continuing to work with CDC on green infrastructure matters particularly as your Plan is progressed to pre-submission.

We note that an open space study has been prepared and this could be linked up with other work into a wider green infrastructure approach incorporating the identified strategic wildlife corridors, areas for natural flood management, PROW and connections between the settlements, protected landscapes and the stations, landscape views/settlement gaps and some land management guidelines
for these really important areas. This would be particularly useful to inform development proposals in the A259 corridor.

Policy SD30 - Strategic wildlife corridors

The SDNPA very much welcomes and supports the inclusion into policy of wildlife corridors which traverse the district connecting the two protected landscapes of the Chichester Harbour AONB and the SDNPA.

It is important to note that there is no corresponding policy within South Downs Local Plan, currently at examination, to continue protection of the wildlife corridors within the SDNP. We have concerns that it is unlikely to be sufficient for the corridors just to reach the SDNP boundary. We also note that several of the corridors appear to be quite narrow, especially to the east of the City, and we query whether they are substantial enough to perform the intended function.

We note the detailed evidence outlined in the background paper and the SDNPA would like to work with CDC on the continued development of the strategic wildlife corridors, in particular with regard to their connection points with the National Park and how we can work together on robustly delivering this strategic cross boundary objective.

Ebernoe Common, The Mens, and Singleton & Cocking Special Areas of Conservation

The SDNPA has been working together on technical advice to facilitate sustainable development within proximity Ebernoe Common, The Mens, and Singleton & Cocking Special Areas of Conservation, which are designated for their populations of Bechstein and barbastelle bats. The draft Sussex Bat Special Area of Conservation Planning and Landscape Scale Enhancement Protocol was published in 2018 in the Core Document Library as part of the South Downs Local Plan Examination. The Protocol is based on published data which identifies key impact zones, one of 6.5km and one of 12km, around each of the three SACs. It also sets out avoidance, mitigation, compensation and enhancement measures to inform and be addressed by development proposals. Parts of the Chichester District Local Plan area are within these key impact zones. These zones have been incorporated into policy SD10 of the South Downs Local Plan and the policy has not been modified by the Inspector as a result of the examination in public. The SDNPA would welcome the opportunity for further discuss with CDC and Natural England on this work.
Solent Recreation Mitigation Partnership

Both CDC and the SDNPA are members of the Solent Recreation Mitigation Partnership (SRMP) (also known as Bird Aware Solent) which has provided a strategic mitigation solution to address potential harm to the protected habitat at Chichester Harbour and ensuring compliance with the Habitats Regulations. We note that the SRMP mitigation solution is reflected in Policy DM30 and we look forward to continuing to work with CDC and other members of the SRMP on this matter.
With regard to paragraph 7.185 we suggest reference to the Medmerry Realignment be a new bullet point: 'Medmerry realignment, which is intertidal habitat created in 2013 to compensate for historic losses across the Solent to SSSI and Natura 2000 sites'.
We also suggest the following wording amendment to paragraph 7.187: '...This is particularly relevant to Chichester and Langstone Harbour and Pagham Harbour and the impact of recreational pressure on the birds that use these Special Protection Areas. Any negative impacts that the development may have should will be weighed against the benefits of the proposal. This may include looking at whether the assets are surplus to requirements, if the proposal impacts on a small area or corridor or if a wider need exists for the development and there is no alternative location....'

The delivery of new homes, including affordable homes and pitches for Gypsies,
Travellers and Travelling Showpeople

Policy S4: Meeting Housing Needs
The SDNPA welcomes the uplift to the housing target to address unmet need arising in that part of the SDNP within Chichester District (estimated at 44 dpa at the time the last Statement of Common Ground was agreed in April 2018). The provision of 41 dpa broadly meets this need.
We note that the Objectively Assessed Need is calculated only for the area outside the SDNP using the 'capping' method set out in the Government's standard methodology (the currently adopted target of 435 dwellings per annum plus 40% = 609) - this is helpful as it makes a clear distinction between the assessed need for Chichester District Local Plan area and that for the SDNPA, notwithstanding
the Duty to Cooperate.

Policy S5: Parish Housing Requirements 2016-35
We support identification of parish specific housing requirements providing certainty to local communities. This is the same approach as we have taken in the South Downs Local Plan.

Affordable housing
We note that there is a need for 285 affordable homes per annum (source: HEDNA) which underlines the need for a strong policy which seeks to maximise affordable housing delivery. This high level of need is common to the wider sub-region and is an issue relevant to the wider housing market area.
The SDNPA supports CDC's approach of taking opportunities arising from new residential development to contribute to the supply of affordable housing, to meet local needs in terms of type and tenure (paragraph 4.35). In this respect, it is important that the whole plan viability testing currently being undertaken should fully reflect Planning Practice Guidance on viability, such that as high as possible a percentage of affordable housing is sought. We also support the positive approach to Community Land Trusts (CLTs) as a mechanism for delivering affordable housing (paragraph 4.45). Chichester District Council may also wish to note that SDNPA has, subject to main modifications consultation, received the go-ahead from its Local Plan Inspector for unmodified inclusion of Strategic Policy SD28: Affordable Housing in the South Downs Local Plan. This includes a lower threshold than that advised in Government policy, and also seeks on-site affordable housing from small sites below the 11 threshold stipulated in Government policy.

Policy S7: Meeting Gypsies, Travellers, Travelling Showpeoples' Needs
The SDNPA supports the principle of the policy and whilst noting the significant need arising. It is not clear whether the intention is to allocate sites to meet the need in a separate DPD. Paragraph 4.49
refers to 'the forthcoming DPD' and policy S7 to sites being allocated in a Site Allocation DPD 'where there is a shortfall in provision'. Has this work already been triggered by the scale of need? The policy and associated text could be clearer on this matter.
We would like to highlight that there is limited capacity within the National Park to allocate sites for Gypsies and Travellers through DtC, given significant landscape constraints. We suggest that the coastal authorities and SDNPA continue to work closely with regards addressing the need.

Improving the efficiency of transport networks by enhancing the proportion of travel by sustainable modes and promoting policies which reduce the need to travel
The SDNPA supports in principle Policy S23 (Transport and Accessibility). In particular, we support emphasis on encouragement of use of sustainable modes. We suggest explicit support in the text for improving links into the National Park, particularly by sustainable and active transport modes.
Allocation policies should also should seek to deliver the joining up of existing, and/or improvements to, the network of Public Rights of Way.

SDNPA notes reference in the policy to a coordinated package of improvements to the A27 Chichester Bypass, as well as to a new road from the Fishbourne roundabout. The SDNPA would urge that any such schemes be fully assessed, including streetlighting, for potential adverse impacts on landscape where there is a relationship with the National Park and its setting. Any such impact will
need to be mitigated, and opportunities taken to enhance green infrastructure networks and public rights of way networks. CDC may wish to consider whether the Policy S23 should include additional wording to reflect these principles.

Centurion Way
The SDNPA supports the reference to Centurion Way in paragraph 7.185 in relation to Green Infrastructure & resistance to dissection of green movement corridors. There are opportunities to improve these links, for example, suggest explicit reference to protecting and enhancing the Centurion Way. The reference to Salterns Way is also supported. Centurion Way and Salterns Way are two flagship off-road routes for the SDNP and AONB respectively and do not currently benefit
from safe off-road connection. The SDNPA would strongly support policy to secure this connection and would welcome opportunities to discuss this further and work jointly with CDC on this strategic issue.

With regard to Strategic Policy S14 (Chichester City Transport Strategy) we request that the SDNP is included in the penultimate bullet point as a destination for strategic cycle routes.

Transport evidence
We would highlight that the transport assessment carried out to inform the South Downs Local Plan.
This indicated a potential severe impact on the Petersfield Road / Bepton Road / Rumbolds Hill junction in Midhurst of additional development in the town, in the context of junctions already becoming overcapacity due to background traffic growth, for example, . arising from strategic development in neighbouring planning authorities.
A review of the CDC Transport Study of Strategic Development indicates significant traffic growth arising from Scenario 1 (the preferred strategy). It is not clear from the study how this will impact on the A286 towards Midhurst, which in turn could have a critical impact on junction capacity at Midhurst.
SDNPA may seek further assurance that such potential impacts have been looked at, and appropriate mitigation sought.
Other comments
Page 16 - Local Plan area map: Request clarification whether the Local Plan area includes the following two properties, as not clear from the Local Plan Area map: Stedlands Farm, and The Stable/Little Stedlands, Haslemere GU273DJ
We would like to wish you well in the progression of your Local Plan and would welcome further discussion and joint working on the strategic cross boundary matters raised.

Horsham District Council welcomes the opportunity to comment on the Regulation 18 Draft "Preferred Approach" version of the Chichester Local Plan. Our comments focus on Policy S3 "Development Strategy"; Policy S4 "Meeting Housing Needs"; Policy S5 "Parish Housing Requirements 2016-2035"; Policy S7 "Meeting Gypsies, Travellers and Travelling Showpeople Needs"; Policy S8 "Meeting Employment Land Needs" and "Strategic Site Allocations".

Policy S3 Development Strategy/ Policy S4: Meeting Housing Needs
Policy S4 deals with meeting housing needs in Chichester District between 2016 and 2035. Policy S4 states that Chichester will provide for at least 12,350 dwellings between 2016 and 2035. This equates to an annual target of 650 dwellings per year, which is slightly in excess of the current identified housing target of 609 dwellings per year, as set by the Government. Horsham District Council therefore supports strategic policy S4, as it seeks to meet the full identified housing need in Chichester District.

We do, however, have concerns over the "Proposed Strategic Locations/Allocations" target of 4,400, which is set set out in the table in Policy S4. Policy S3 "Development Strategy" sets out the 14 proposed strategic development locations for Chichester District, which would make up the total strategic allocations target of 4,400 dwellings from Policy S4. Further detail on these individual sites is provided in the "Strategic Site Allocations" section of the draft plan (pages 95-133). First, the total number of dwellings identified in the strategic development
locations in Policy S3 is 8,085. This number is significantly in excess of the 4,400 identified in Policy S4 and no explanation is given as to why the numbers differ. Second, the 14 strategic development locations identified in Policy S3 include 5 neighbourhood plan 'housing allocations' (totalling 2,550 dwellings). These are Policy AL8 East Wittering (350 dwellings); Policy AL9 Fishbourne (250 dwellings); Policy AL10 Hambrook (500 dwellings); Policy AL11 Hunston (200 dwellings) and Policy AL13 Southbourne (1,250 dwellings). Horsham Council would like to see further evidence that this number of neighbourhood plan sites can realistically be delivered within the identified timescales, given the inherent difficulties of both "making" neighbourhood plans and bringing forward development sites within these neighbourhood plans.

In addition to meeting Chichester's identified needs, Horsham Council notes and welcomes the reference in paragraph 4.23 to the West Sussex and Greater Brighton Strategic Planning Board, and attempting to address the objectively assessed housing and other development needs within the wider West Sussex and Greater Brighton area. Horsham District Council considers it important that all districts and boroughs within the Strategic Planning Board area work together to aim to meet as much of the longer term and unmet development needs of the wider sub-region as possible, through an accelerated work programme of Local Strategic Statement 3.

Policy S5 "Parish Housing Requirements"
Horsham Council notes and supports Policy S5, which allocates parish housing requirements for small sites between 2016 and 2035.

Policy S7 "Meeting Gypsies, Traveller and Travelling Showpeople Needs"
Horsham Council notes and supports Policy S7, which identifies a need for 91 additional permanent residential Gypsy & Traveller pitches and 28 additional plots for Travelling Showpeople, and states that where there is a shortfall in provision, a Site Allocation DPD will be prepared to allocate sites.

Policy S8 "Meeting Employment Land Needs"
Horsham Council notes and supports Policy S8, which sets out the identified employment floorspace requirement for 2016-2035 (231,835 sqm) and which seeks to meet it through an identified supply of 235,182 sqm.
I trust these comments are helpful. Horsham Council is keen to work with Chichester District Council in taking the Chichester Local Plan through to adoption.

INTRODUCTION - strategic and local importance of A27 improvement

The PC is concerned that the strategic context of the Plan, whilst making reference to the importance of the A27 trunk road, fails to realise the impact of the lack of the implementation of a scheme has on the future sustainability of new development proposed, let alone the completion of those proposed under the current plan.

Reliance on S106 and CIL contributions to mitigate, for instance increased traffic, will have little impact on alleviating the problem that the current A27 represents to communications and, importantly, the city of Chichester's future economic viability.

The plan makes little attempt to future proof Chichester and its hinterland with its continued reliance on relatively low paid employment in tourism, horticulture and areas such as retail.
The Coastal West Sussex and Gt Brighton Local Strategic Statement makes strong reference to the
Inter-relationship between the Bognor Regis northern bypass on the A259, the Arundel bypass and the A27 improvement at Chichester - the impact of these two schemes on Chichester, already apparent at the Bognor roundabout, could be catastrophic congestion.

Comments on Main policies.

S4 Meeting housing need

The Manhood Peninsula is expected to deliver 1993 units during the Plan period. Of this figure, 600 are in Selsey, East Wittering and Hunston, 175 as parish housing requirement in Birdham and North
Mundham. It is not clear what proportion of the residual 1208 fall into the category planning permissions, committed or made as of 2017 and what are expected to be small windfall sites.
Without this breakdown the potential impact on parishes such as Sidlesham, that are deemed unsustainable for housing, cannot be assessed. This is particularly important in Sidlesham where, due to prior consent approvals through the conversion of agricultural / horticultural buildings there is potential for 100 plus new units. This potential that would appear to be categorised as "windfall" obviously does not fit the definition, especially as to date (32 approvals in Sidlesham and Earnley), none are social housing but all are full market and some, costing £600k, are beyond any prospect of meeting the needs of first time buyers. The parish considers the majority of the conversions inappropriate and the potential scale of the number of conversions challenges the District's sustainability definition that is well founded for the parish. Whilst the Parish Council appreciates that the guiding legislation stands outside the local plan process, the potential distortion the developments, which are essentially on the ex Land Settlement Estate, needs to be specifically addressed in the local plan. Additionally, there are implications for policies S11 and DM15.

S6 Affordable Housing, DM4 Affordable Housing Exception Sites (S12 Infrastructure Provision)

The policy and supporting text gives too great a flexibility to developer, especially in terms of the economic viability of development. The renegotiation by developers of the proportion of social housing post original consent appears to have characterised many developments arising from the existing plan and consents that were granted prior to its approval. The fact that the plan seeks to control the artificial sub division of sites to avoid the social housing "trigger" gives a strong indication of many volume builders' reluctance to truly engage in meeting the true scope of overall housing demand. Whilst the hybrid of shared ownership meets a particular aspect of overall demand, it fails to address the increasing necessity of proper social housing. The true economic viability of sites needs rigorous independent assessment and, if not viable as market led development, the appropriateness of the site for development should be reassessed or its consideration for acquisition by, for instance, a community land trust scheme or compulsory purchase to provide social housing should be considered.

Policy S12 is welcomed, but the range of provision to be supported, especially if whole life costs are to be met will place great demands on funding streams such as S106, CIL and other funding streams and there must be doubt as to whether your council's Infrastructure Development Plan can be fully met.

S7 Gypsy and Travellers and Travelling Show People, DM5 Accommodation for Gypsies

It is noted that separate provision is required in the 5yr housing supply for this category. The eligibility for inclusion is that the individual still has an itinerant life style, ie travelling from place to place. Many of the gypsy families/individuals that seem to qualify under this category patently do not exhibit this form of life style. Local experience fully supports this position with gypsy communities simply using their caravan homes as a base to engage in trade, with the site often becoming the builders' type yard for the storage of materials or the waste from their trade. This form of occupation does not distinguish the use from any other individual living in an area and consequently should not qualify for any special recognition; in fact, in many cases such use under normal planning powers would be contrary to policy.

This "special treatment" causes a great deal of resentment in local communities especially where there is a social housing need - that is most areas - and where school places are under pressure.
The qualifying criteria must be fully investigated and a change in status over time reviewed as many sites, originally for itinerate use, simply become settled locations and do not therefore meet the criteria. It seems that the process from itinerant to settled status is a common progression and has the result of the "need" for new pitches continually increasing.

The substantial increase from the 2015 plan requirement to the 90 plus gypsy pitches now identified illustrates how the process is being used to bypass Planning that would restrict the provision of such "housing" if it were built development and that areas become favoured by gypsy communities as other gypsies are already located there and a sub community established. The criteria for assessment of eligibility must be reviewed together with the transition to settled status and additionally the degree to which concentrations of gypsy and other travellers are occurring in specific areas - this is considered to be the case in Sidlesham.

DM6 Accommodation for Agricultural Workers

The reintroduction of this qualifying criteria is welcomed. However, there is a major issue with enforcement and the policy needs to be strengthened to ensure the occupant continues to be employed in agriculture or horticulture. The change away from agricultural/horticultural occupation is often not declared and after the requisite elapse of time, ELD status is applied for. The need to register agricultural/horticultural occupation on an expiry time basis that would exclude qualification under ELD should be considered in the policy and/or the surrounding text. The subdivision of land and the separation of the original accommodation from the land is an increasing aspect of land holding in areas such as Sidlesham. On many sites an agricultural viability assessment is made as to whether a subdivided holding is viable and whether a constant presence on site is required to maintain the use and therefore accommodation required. However, this potential position should be a consideration at the original point of separation and a condition made that the subdivided land should not benefit from a subsequent consent for another house/residential caravan. This subdivision has and continues to be a trait on the ex LSA estate and, particularly within the HDA's, undermines their priority for horticultural production. At least in the HDA's the approval of agricultural worker accommodation should be restricted and perhaps limited to a residential caravan on a temporary consent and not lead to a progression to a permanent building as currently happens.

S11 Horticultural Need, DM15 Horticulture

There appears to be a weakening of the distinction between what in the 2015 Plan were termed
"hub" sites at Runcton and Tangmere and the other HDA sites in Sidlesham and Almodington.
Para 7.92 is particularly troubling ". It is not expected that large scale glasshouse development
(228,000 sq m required) will occur in Sidlesham and Almodington HDA's to the same extent as at
Runcton and Tangmere. The statement introduces doubt over the distinction between large scale industrial type of production and what is termed "market garden" horticulture expected at Sidlesham and Almodington.

The statement about "land adjacent to an HDA" previously related to Runcton and Tangmere. Its extension to Sidlesham and Almodington again introduces doubt over your council's true intentions about the scale of the industry envisaged outside the old hub sites and undermines the strong position it took on large scale such the Madestien proposal in Almodington. Your council stresses the importance of the HDA but continues to allow the break-up of the land within the smaller ones through conversion of buildings to residential and the take of land for gardens under "prior consent" as mentioned above. This approach is contrary to the proposed policy and will lead to further fragmentation and inefficient use of the land that remains. This approach could lead to requests for land outside the current smaller HDA's and bring glasshouse development into conflict with the overall environment. Many of the largest glasshouse developments are outside the HDA's but in established glasshouse areas and lead to the possibility that the HDA's need review and at least two new areas established based on the Fletchers Estate and Jakes Nursery and on Street End Lane. These area are equal or probably exceed production in many parts of the two HDA's.

S23 Transport and Accessibility

The strategic need for a solution to the A27 has already been mentioned but the impact locally cannot be overstressed in respect of the Manhood Peninsula. The high levels of out commuting for employment and many services are all dependent on a functioning A27 and further development in reality can only aggravate a non-functioning situation.

The cul-de-sac position of Selsey presents major problems for the town - the second largest in the district - in terms of emergency services and, for instance, the levels of congestion when heavy domestic traffic flows are combined with the summer tourist traffic that swells the population to approaching four to five times its winter levels. The sustainability of this situation in terms of environmental impact, the economic viability and overall acceptability must be doubtful. This is apparent to the road users but increasingly the areas that the road passes through, such as
Sidlesham, suffer pollution from exhaust emissions, noise, unacceptable delay in access from adjoining roads and properties, just simply crossing the road by pedestrians is made almost impossible as traffic is so often two way with no gaps. This situation cannot be ignored and just allow the road to be loaded with more traffic. The carrying capacity of the B2145 must be seen as a limiting factor in any future development in Selsey. This situation is mirrored on the A286 with The Witterings and Bracklesham.

It will be important that development in Selsey contributes to traffic management on the B2145 and that the whole of the road is eligible for any S106 and CIL contributions and not just the immediate locality of Selsey. The overall intention should be to improve safety, ensure speed is observed and allow safe road crossing. These factors will be considered within the Sidlesham Neighbourhood Plan.

Pollution is an increasing concern and in line with the Plan's policy objectives for greening of the environment, structural tree planting will be proposed within the B2145 corridor. The plan makes reference to sustainable transport but there are no specific proposals. It is suggested that for the Manhood Peninsula the proposed Greenway Selsey to Chichester is part of a specific policy that seeks to protect the adopted route and that Neighbourhood Plans for Hunston, Sidlesham and Selsey then adopt the route into their plans.

S24 Countryside, DM22 Development in the countryside, DM31 Trees, hedgerow and
woodland, DM29 Biodiversity

These policies and accompanying text is supported and will form the basis of Sidlesham's Neighbourhood Plan. Para 5.39 indicates conversions of existing buildings will be favourably considered where they lead to uses needed to support the rural economy and create 'rural affordable housing'. Currently, many conversions do not meet these criteria, especially the latter where often large upper market houses are developed way out of the range of meeting any local social need. The policy needs to reflect this problem with more specific criteria covering what is acceptable within the scope of any conversion.

The identity of the rural areas is an important consideration in maintaining their character if they are not to become just the spaces between larger settlements. This is particularly important on the
Manhood Peninsula and in the countryside associated with the transport corridors of the A286 and
B2145. The open countryside along these routes with their small settlements are in danger of encroachment by development and urbanisation. A specific policy is suggested to protect such areas and enhance their character by schemes of tree planting, improvement to the roadside environment and strong traffic management. Again, this approach will feature in the Neighbourhood Plan.
Whilst it is appreciated that agriculture is currently in a state of uncertainty, a policy that seeks to promote the balance between agricultural production, the environment and amenity would be welcome as a basis for whatever system of agricultural subsidy eventually is formulated. Particular emphasis should be placed on the protection of high grade agricultural land (grade 1 - 3a), biodiversity , and for instance structural tree planting for drainage and co2 reduction. A positive approach to recreational access in support of green tourism should also form part of a strengthened countryside policies.

S25 The Coast, S30 Strategic Wildlife Corridors

The policy makes reference to Chichester Harbour Management Plan but should also make reference to the Pagham Harbour Management Plan - although this currently only covers the period to 2018, the RSPB can be expected to bring forward a new plan for the next 5-10yr period.
The significant changes to the Pagham Spit over a relatively short period of time could have significant impact on the drainage of the harbour and particularly the surrounding land and including the R. Lavant flood relief channel. The importance of the Harbour's drainage function should be reflected in a specific policy that balances the significance of the habitat with the land drainage issues.

The Medmerry Scheme has created a significant change in the coastal geography creating a significant new coastal habitat extending westward from the margins of Pagham Harbour to within a short distance of the edge of Chichester Harbour AONB. An important corridor for wildlife is developing over the short distance between the two and should be considered as a designated area under policy S30.

S27 Flood Risk Management

The plan makes reference to flood risk but does not fully realise its significance to the Manhood
Peninsula and the constraints it places on development, the future of its economy and the resilience of its communities.

Whilst SUDS has its uses in localised drainage it often simply drains an area into a downstream network that has to cope with the additional run off. The Peninsula has an extremely high water table for the majority of the year that makes most soakaway drainage ineffective. An integrated network utilising the existing ditch system and augmenting this with attenuation areas with good clear outlets to the sea must be developed and maintained.

Many new housing developments rely on SUDS but simply only cover the development site. Developers have to be responsible for the water they produce from the point of generation to its disposal to the sea or main river. This should form a requirement of any planning agreement and a policy within the plan should reflect and formalise this responsibility. Realisation of the true infrastructure cost of drainage should be fully reflected in the site evaluation process and its economic viability. The development of many coastal locations or those on flood plain may be proven uneconomic if the real cost for drainage were realised and not the passing on of the problem
downstream as currently occurs.

Reference is made to Surface Water Management Plans. It is the responsibility of the lead strategic flood authority (in this case WSCC) to produce and maintain these plans. As a material consideration there should be policy and text to ensure the plans are kept up to date and that priorities identified in plans are brought forward for action and funding such as CIL directed to their implementation.

S31 Wastewater Management and Water Quality

Southern Water needs to have information on future demand foul drainage - detailed discussions with SW have shown that the levels of development known to them, especially in respect of
Sidlesham Waste Water Treatment Works, do not appear to reflect the development levels and question the capacity of the facility. Additionally, the size and overall functioning of the pipe network is very troublesome, for example, the "trunk main" from the Witterings. It would appear that calculations are primarily based on dry flow rates where much of the pre 1960's housing on the
Peninsula has mixed drainage and the foul system suffers from ground water inundation. The Parish requests that a clear reappraisal of the wastewater capacity of SWWTW and of the network is made and the infrastructure costs of a system that has the required headroom and a network that will support existing and any new development is made and factored into the plan.

DM35 Equestrian Development

The parish is concerned about the high level of horse related development that is occurring on the
Peninsula, especially on the settlement boundary margins, within the ex LSA estates, and associated with gypsy sites. Much of this development is often deemed as "agricultural use" when it is really a "change of use" as the livestock are not supported by grazing of the land. The use for "horse culture" often removes high quality land form agricultural/ horticultural use, despoils the land creating a strong visual intrusion often close to residential areas. The Plan policy should ensure that the change of use is properly applied and enforced. Clarity should also be sought as to the true recreational nature of much of the horse keeping and as there is no bridleway network on the Peninsula how often large numbers of horses kept on a small acreage might be exercised.

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