Objective 4: Employment and Economy

Please include specific reference to marine recreation industry

Lack of soundness. No reference has been made to marine leisure/recreation industry, which is a key sector in Chichester Harbour with a positive contribution to other strategic objectives of the plan

The Estate has shared with the planning authority an independent report prepared by LSE as to the very significant contribution made by Goodwood and Rolls-Royce locally (this report is in the process of being updated and it is understood Rolls-Royce has commissioned a similar study – it is intended such evidence will be available for the local plan examination). The REport and its findings should be reflected in the Plan.

The local plan is a major step forward in terms of protecting the Estate’s interests and allowing it to evolve and continue to contribute significantly to the local and regional economy. However, for the plan to be truly sound and provide a true basis for forward investment, we ask that changes are made to the plan as we identify through our representations.

Within the plan are policies or supporting information deficient on key matters affecting the economic sustainability of the district. The plan fails to recognise the full extent of th eimportant roles of Goodwood Estate and Rolls-Royce to the District economic vitality.

The plan seeks to accommodate Goodwood needs through its policies but continues to present major challenges threatening Estate sustainability.

The plan should identify and protect economic assets robustly, appropriate provision made or their sustainability and enhancement and clarity that interests will not be impacted adversely by developments on adjoining land, or which adversely affect infrastructure essential to its well-being.

If young talent is to be retained the City has to provide facilities that young people want in terms of leisure and entertainment. Family friendly facilities to encourage young families to stay. The demographic is of an older age range than average but this should not stand in the way of facilities such as night clubs or other facilities to make Chichester a vibrant 21st century city. With the closure of Air Arena and the threat that Cineworld will close, amenities for families are minimal.in the way of facilities such as night clubs or other facilities to make Chichester a vibrant 21st century city.

Further detailed policy support is required to deliver sustainable growth in sectors such as the hospitality and visitor economy. The plan does not provide an appropriate framework to support the on-going needs and evolution of businesses within that sector, such as The Goodwood Estate, where there is often conflict between policy objectives, e.g. new development and environmental protection, or a failure to recognise the environmental benefits arising from the historic and future activities of the Estate.

Over the coming years, more provision of space for nurseries, high-tech glasshouses, packhouses and reservoirs will be required; however, there will also be an increased need for ancillary development, such as: Vertical Farming Projects, Research & Development Facilities, Alternative Energy Centres, Logistics and Distribution Centres, Engineering and Technical Support Facilities.

The West Sussex Coastal Plain, with its exceptionally high winter light levels and all year round beneficial climate, is the preferred location for horticultural production in the UK.

The Horticultural Industry, concentrated around Chichester and Bognor Regis, generates annual turnover that exceeds £1billion pounds and employs more than 10,000 full time equivalent staff.

The Government has tasked Growers to grow more home grown produce, increase productivity, reduce food miles and the UK’s reliance on imported food. There is also an increasing need for space to grow plants, shrubs and trees. These aims can be achieved; however, the Horticultural and Food Industries need Local Planning Policies to be in place that enables sustainable development. To this end, more flexibility is needed in the current CDC Local Plan - Horticultural Policy to meet the needs of the Horticultural sector.

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.

The Council’s desire to support the horticultural industry is welcomed, however the mechanism for delivering this growth is fundamentally flawed and bakes in unwarranted constraints to realising the growth and competitiveness of the food production industry. Please refer to attached Savills SREBR.

The current HDA policy is noted by stakeholders within the 2018 HEDNA as a barrier to growth due to the failure to support functionally associated uses. The importance of functionally-associated uses to the cluster is also acknowledged within The Council’s evidence base and other key Government and Industry publications.

Accordingly, it is suggested that the Council should pursue a more positive and proactive wording of the HDA policy in order to allow for a greater breadth of functionally linked uses within the Runcton HDA. The proposed wording of the policy does not provide sufficient certainty to investors and businesses (both established within Runcton HDA or looking to locate within it) that The Council will support the functionally associated uses that are necessary to foster and maintain the growth and competitiveness of a world-class food cluster.

The Local Plan therefore conflicts with paragraph 81 of the NPPF in its entirety which states:

Planning policies and decisions should help create the conditions in which businesses can invest, expand and adapt. Significant weight should be placed on the need to support economic growth and productivity, taking into account both local business needs and wider opportunities for development. The approach taken should allow each area to build on its strengths, counter any weaknesses and address the challenges of the future. This is particularly important where Britain can be a global leader in driving innovation 42, and in areas with high levels of productivity, which should be able to capitalise on their performance and potential.

Supports SOSCA's Submission as attached.

The plan should be more specific in itemising the ways in which we are reacting to economic challenges, beyond leaving things to market forces. Reference needs to be made to credible plans for future investment and initiatives beyond allocation of suitable sites. More use must be made of volunteers and more emphasis needed to nurture businesses which are already in the area.

My thoughts on the Plan are general and difficult to fit into boxes. So, if I may, I send them as a whole.............

I’m particularly interested in Objective 4. Employment and Economy. Though the Plan talks about “a strong, thriving and diverse economy” and “job opportunities for all skill levels” there is no detail on how we get there, so an air of complacency is engendered as everyone knows these things don't just happen. The Plan says there will be support by allocating “employment sites”, but that is all. Suitable sites are only one ingredient for a thriving economy.

Again, asserting that “Chichester city will have a key role as a vibrant sustainable city with a good range of business, leisure and retail uses based on the aims of the Chichester Vision”. A Vision is fine, but it needs a detailed Plan of where the money is coming from and who is going to be responsible for delivery, otherwise it sounds like wishful thinking.

Asserting that “Local industries such as horticulture, agriculture, fishing and tourism will flourish” and proclaiming also that “The dynamic local knowledge-based economy will excel in innovation and continue to diversify” sounds overly optimistic when we know there are real challenges ahead. Reference needs to be made to credible plans for future investment and initiative in these areas. As for diversity of jobs, we have some way to go as we are oriented very much towards the public sector. How exactly are we going to boost the private sector? Who is going to be responsible?

For new growth initiatives the Plan is decidedly down-beat with an emphasis on the hurdles to be negotiated before any planning permission is given - ten of them for horticulture for example. We need to give a genuine welcome if we are to succeed in attracting investment.
I could not find any financial data in the Plan and, if there is none, that would make it a most unusual Plan. Talk about the Southern Gateway yet again, for example, must surely be tempered by acknowledgement that there is no money, so it won’t happen in the foreseeable future. And, incidentally, bus stops along Avenue de Chartres do not help constitute a sensible public transport hub.

The Local Plan should surely not ignore the national context. The economy as a whole is sluggish so it needs extra effort if Chichester is to buck the trend. High interest rates currently will mean businesses put investment on hold. The recent government announcement that there are going to be special incentives for business in 12 new enterprise zones, makes attracting investment more difficult for those parts of the country, like Chichester, which are outside.

With little money available for new initiatives, more use must be made of volunteers and more emphasis will be needed to nurture businesses which are already in the area. A positive attitude towards business should be proclaimed while obviously preserving the ambience of an attractive city.

Altogether the Plan has an air of unreality about it. It strikes an optimistic note on the economy when it is obvious that the outlook for the foreseeable future is not rosy. That is fine and we must aim to buck the trend, but the Plan needs to recognise that there are a whole host of requirements needed to get a strong diverse economy and provision must be made to put them in place. Simply leaving things to “market forces” does not achieve an optimum result. Chichester is in a competitive environment to attract inward investment and well-paid jobs. We are in a competitive environment to attract visitors and tourists. The Plan should be more specific in itemising the ways we are reacting to the challenges we face.

We have reviewed the publicly available Local Plan documents and provided comments in the attached letter, in relation to the transport implications of the plan for the safety and operation of the SRN.
Our comments include issues to resolve, comments, requests for further information and recommendations. A brief summary of our main comments are:
- the reliance on the delivery of the A27 Chichester bypass improvements project.
- the requirements for new, additional, and adapted processes and assessments, especially in assessing Transport Assessments, mandating Travel Plans and monitoring traffic associated with new developments.
- collaborative working between agencies in combination with a robust monitor and manage policy.
We hope our comments assist.
To date National Highways have worked collaboratively with Chichester District Council (the Council) and West Sussex County Council (WSCC) and we will continue to work with the Council and other key stakeholders. We look forward to continuing to participate in future consultations and discussions.
Once you have had the opportunity to digest all the representations received, we would welcome a meeting to run through all the transport related matters and agree how to progress any required evidence gathering or other work.

Background

National Highways has been appointed by the Secretary of State for Transport as strategic highway company under the provisions of the Infrastructure Act 2015 and is the highway authority, traffic authority and street authority for the strategic road network (SRN).

National Highways is responsible for operating, maintaining, and improving the Strategic Road Network (SRN) i.e., the Trunk Road and Motorway Network in England, as laid down in Department for Transport (DfT) Circular 01/2022 (Strategic Road Network and the delivery of sustainable development).

The SRN is a critical national asset and as such we work to ensure that it operates and is managed in the public interest, both in respect of current activities and needs as well as in providing effective stewardship of its long-term operation and integrity.

Our responses to Local Plan consultations are guided by relevant policy and guidance including the National Planning Policy Framework (2021) (NPPF):

• Transport issues should be considered from the earliest stages of plan-making and development proposals so that the potential impact of development on transport networks can be addressed (para 104).

• The planning system should actively manage patterns of growth such that significant development is focused on locations which are or can be made sustainable, through limiting the need to travel and offering a genuine choice of transport modes. (para 105).

• Planning policies should be prepared with the active involvement of highways authorities and other transport infrastructure providers so that strategies and investments for supporting sustainable transport and development patterns are aligned. (para 106).

• In terms of identifying the necessity of transport infrastructure, NPPF confirms that development should only be prevented or refused on highways grounds if there would be an unacceptable impact on highway safety, or the residual cumulative impacts on the road network would be severe. (para 111).

• Planning policies and decisions should support development that makes efficient use of land, taking into account the availability and capacity of infrastructure and services – both existing and proposed – as well as their potential for further improvement and the scope to promote sustainable travel modes that limit future car use. (para 124).

In relation to the tests of soundness set out at paragraph 35 of the NPPF, in the context of transport, these are interpreted as meaning:

a) Positively prepared - has the transport strategy been prepared with the active involvement of the highway authorities, other transport infrastructure providers and operators and neighbouring councils?
b) Justified – Is the transport strategy based on a robust evidence base prepared with the agreement in partnership, or with the support of the highway authorities?
c) Effective – Does the transport strategy and policy satisfy the transport needs of the plan and is it deliverable at a pace which provides for and accommodates the proposed progress and implementation of the plan?
d) Consistent with national policy – Does the transport strategy support the economic, social, and environmental objectives of the Plan and the NPPF/NPPG?

We will be concerned with proposals that have the potential to impact on the safe and efficient operation of the SRN; in this case, the A27 trunk road (Chichester Bypass and its junctions) which is the main access route in the Chichester area. We have particular interest in any allocation, policy or proposals which could have implications for the A27 and the wider SRN network. We are interested as to whether there would be any adverse road safety or operational implications for the SRN. The latter would include a material increase in queueing or delay or reduction in journey time reliability during the construction or operation of the development set out in the plan.

National Highways is a key delivery partner for sustainable development promoted through the plan-led system, and as a statutory consultee we have a duty to cooperate with local authorities to support the preparation and implementation of development plan documents.

In accordance with national planning and transport policy and our operating licence, we are entirely neutral on the principle of development as it is for the local planning authority to determine whether development should be allocated or permitted; albeit it must comply with national policy on locating development in locations that are or can be made sustainable. Therefore, while always seeking early and fulsome engagement with local plans and/or developers, we will simply be assessing the transport and related implications of plans or proposals and agreeing any necessary transport improvements and relevant development management policy.

In progressing Local Plans, we will seek to agree the following:
• Assessment tools and methodology
• Baseline Assessment i.e., to demonstrate that the assessment tool accurately reflects current transport conditions
• Comparator case assessment i.e., to forecast the transport conditions that would occur in the absence of the plan
• Forecast modelling i.e., to forecast the transport conditions that would arise with the plan in place, this will include an assessment at the end of the Plan period; and, if required, at full build out if that occurs after the end of the Plan period
• Outputs and outcomes of modelling, demonstrating, as appropriate, what transport infrastructure is necessary to support the plan o It should be noted that a suite of transport modelling tools may be required. This includes strategic modelling covering an area at least one major junction beyond the district boundary, localised network modelling where several links/junctions are close together and/or individual junction modelling
o A DMRB (Design Manual for Roads and Bridges) compliancy assessment may also be required for certain highway features, such as
Merge/Diverge assessment at Grade separated junctions, link capacity assessments, and others.
• The design of any necessary transport infrastructure, to an extent suitable for establishing deliverability during the plan period at the time that it becomes necessary for the purpose of ensuring that unacceptable road safety impacts or severe operational impacts do not arise as a result of development. This may be to at least General Arrangement design stage or preliminary design stage. Whichever degree of detail is agreed, the products must be in full compliance with the DMRB.
• Industry standard transport intervention costings.
• The delivery/funding mechanisms for necessary transport interventions. It should not be assumed that National Highways will have any responsibility to identify or deliver necessary transport interventions.
• If considered appropriate, a “Monitor & Manage” (M&M) framework, aimed at managing the pace of development in line with the pace of funding and delivery of necessary highway interventions in a manner which responds to the realworld impacts of development may be agreed for inclusion in the plan subject to the adequacy of risk control measures included therein. This can include the move from a ‘predict & provide’ style of delivery to ‘a vision & validate’ style. o Any M&M framework must be based on a “worst case scenario” whereby necessary mitigation is understood, as well as setting out the desired alternative scenario. It must set out details of responsibility, funding and governance of the framework together with the methodology for determining the timing for any mitigation delivery while remaining clear on the fallback position where identified mitigation or desired alternatives are not ultimately achievable. It must be translated into development management plan policy and policy relating to development allocations.

Further detail on the above can be provided by National Highways.

While ideally all the above should be agreed prior to the Submission of the Local Plan for examination, we recognise that this is not always possible. However, all parties should work towards all matters being agreed and reflected in a Statement of Common Ground (SoCG) by the start of the Local Plan Examination at the latest. Ideally the SoCG between the Council and National Highways would be prepared well in advance of plan submission in order to guide resource input and to track progress towards final agreement on all relevant matters starting from the earliest plan iterations until the final version is agreed.

It is acknowledged that Government policy places much emphasis on housing delivery as a means for ensuring economic growth and addressing the current national shortage of housing. The NPPF is very clear that:
“Strategic policy-making authorities should establish a housing requirement figure for their whole area, which shows the extent to which their identified housing need (and any needs that cannot be met within neighbouring areas) can be met over the plan period.”

However, new DfT C1/22 and the NPPF are equally clear that any development, including housing delivery, must be tempered by the requirement to ensure that the associated transport demand can be accommodated without unacceptable impacts on the safety of the SRN or severe impacts on the operation of the SRN including reliability and congestion. Therefore, as necessary and appropriate, any plan and/or development must be accompanied by suitable mitigation in the right places at the right time, that is to the required design standards and is deliverable in terms of land availability, constructability and funding.

We would also draw your attention to the then Highways England document ‘The Strategic Road Network, Planning for the Future: A guide to working with National
Highways on planning matters’ (September 2015). This document sets out how National Highways intends to work with local planning authorities and developers to support the preparation of sound documents which enable the delivery of sustainable development. https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachmen t_data/file/461023/N150227_-_Highways_England_Planning_Document_FINAL-lo.pdf

Responses to Local Plan consultations are also guided by National Planning Policy Framework (NPPF) revised on 20 July 2021 which sets out the government’s planning policies for England and how these are expected to be applied.

Updated Circular (01/2022)
It should be noted that since the start of the Local Plan consultation process, on the 23 December 2022, the Department for Transport released a new circular on the ‘Strategic road network and the delivery of sustainable development’ (Circular 01/2022), which replaces all of the policies in Circular 02/2013 of the same name. These representations take account of the new circular and the requirements in terms of the Local Plan evidence base and process.

We request that the Local Plan is prepared in line with all aspects of the new circular. Particularly, the principles of sustainable development (paragraphs 11 to 17), new connections and capacity enhancements (paragraphs 18 to 25), and engagement with plan-making (paragraphs 26 to 38).

Regulation 18 submission
In our Regulation 18 submission we noted several matters including:
• The need to mitigate the adverse impacts of strategic development traffic to the A27 Chichester Bypass and its junctions at Portfield Roundabout, Bognor Road Roundabout, Whyke Roundabout, Stockbridge Roundabout and Fishbourne Roundabout and Oving junction.
• The need to identify a mechanism to calculate contributions towards the delivery of the previously agreed Local Plan A27 improvements
• The need to confirm the number of dwellings needed within the plan period
• The need to establish National Highways acceptance of the traffic model reference and future case scenarios
• The need to confirm costs, viability, and funding associated with mitigating the safety and congestion impacts of the development included within the plan.

Local Plan context
This Local Plan (Chichester Local Plan 2021 – 2039), prepared by the Local Planning Authority (LPA) Chichester District Council, sets out the vision for future development in the district and will be used to help decide on planning applications and other planning related decisions including shaping infrastructure investments.

The draft sets out how the district should be developed over the next 18-years to 2039 including for the full Plan period (1 April 2021 to 31 March 2039) the total supply of
- 10,359 dwellings
- 114,652 net additional sqm new floorspace
Minus the completions this is equivalent to around 530 dwellings and 6,150 sqm of floorspace a year.

National Highways Representations
To date National Highways have worked collaboratively with Chichester District Council (the Council) and West Sussex County Council (WSCC) and we will continue to work with the Council and other key stakeholders.

We have undertaken a review of the Chichester Local Plan 2021-2039 proposed submission version and accompanying evidence documents, our comments are set out in the tables below (following pages). [see table within attachment]

Summary

We have reviewed the publicly available Local Plan documents and provided comments above in relation to the transport implications of the plan for the safety and operation of the SRN. We understand that other technical information is available, but this was not presented as part of this consultation.
Chichester, and the A27, are already heavily congested, infrastructure in the existing Local Plan remains undelivered and the growth set out in the new Plan will further increase travel demand.
As presented, satisfying the transport needs of the plan is clearly reliant on the delivery of the A27 Chichester bypass improvements project. The A27 Chichester bypass improvements project is one of 32 pipeline schemes being considered for possible inclusion in National Highways third Road Investment Strategy (RIS3) covering 1 April 2025 to 31 March 2030.
On 9 March 2023 the UK Transport Secretary ensured record funding would be invested in the country’s transport network, sustainably driving growth across the country while managing the pressures of inflation. The announcement cited the A27 Arundel Bypass as being deferred from RIS2 to RIS 3 (covering 2025-2030). The transport secretary also identified a number of challenges to the delivery of the road investment strategy and cited the benefit of allowing extra time to ensure schemes are better planned and efficient schemes can be deployed more effectively.
At present, there is no commitment by DfT to carry out the A27 Chichester bypass improvements project. Until the A27 Chichester bypass improvements project is published in the RIS3, consented and a decision to invest is made it cannot be assumed to be a committed project.
We note that the Plan does not address any uncertainty of delivery of the A27 Chichester bypass improvements project and we strongly recommend that there is either no reliance placed on RIS3 to realise capacity for growth in the Plan or that contingency measures are included to cover the eventuality that RIS3 funding is not forthcoming within the plan period. It is not clear that the potential impact of development on transport networks can be addressed in the absence of the A27 Chichester bypass improvements project.
Achieving net zero, reducing emissions reduction, acting on climate, and supporting thousands of new homes and new employment developments will be problematic with existing processes. New, additional, and adapted processes and assessments will likely be required, especially in assessing Transport Assessments, mandating Travel Plans and monitoring traffic associated with new developments. We acknowledge that change is complex, expensive, and time-consuming, especially for smaller district level Councils. But the hard work will deliver benefits for the Council and residents in the longer-term.
National Highways seeks to continue working with the Council and WSCC to progress coordinated and deliverable packages of interim mitigation measures and alternative transport solutions while a long-term strategic solution is considered by government. This must however be in combination with a robust monitor and manage policy that appropriately manages the risk of unacceptable road impacts resulting from new housing
and other development over the Plan period.

We have been in discussion with Chichester District Council regarding their proposed Monitor and Manage Strategy. At present, we do not consider the current strategy to be robust and we seek further information and detail especially on who, when and when monitoring and management will be undertaken. Developments in the right places and served by the right sustainable infrastructure delivered alongside or ahead of occupancy must be a key consideration when planning for growth in all local authority areas. Any M&M framework must be based on a “worst case scenario” whereby necessary transport mitigation is understood, as well as setting out the desired alternative scenario. It must set out details of responsibility, funding and governance of the framework together with the methodology for determining the timing for any mitigation delivery while remaining clear on the fallback position where identified mitigation or desired alternatives are not ultimately achievable. The M&M framework must set out that the alternative to mitigation not being delivered is that development does not proceed where that development would give rise to unacceptable road safety risk or severe cumulative impacts on the road network in the absence of that mitigation. The M&M framework must be translated into development management plan policy and policy relating to development allocations.
As we have reiterated throughout our comments, we welcome the opportunity to work with you to address these outstanding matters and we will continue to liaise over submitted Transport Assessment, Travel Plan policy and Monitor and Manage Policy to help to work towards a viable plan.
We hope our comments assist.
We look forward to continuing to participate in future consultations and discussions. Please do continue to consult us as the Plan progresses so that we can remain aware of, and comment as required on, its contents.
Once you have had the opportunity to digest all the representations received, we would welcome a meeting to run through all the transport related matters and agree how to progress any required evidence gathering or other work.

State amount of jobs/employment floorspace seeking to achieve. Clarify objectives for employment in villages and rural areas.

See attachment.

See attached representation.

See attached.