Objective 7: Strategic Infrastructure

The plan should be biased towards improvements and development along the A27 and away from inefficient piecemeal building, with each location requiring its own expensive infrastructure upgrades.

This Objective highlights/prioritises the mitigation of impacts on the A27, implying that other areas will be developed with a weaker view on any detrimental effects and development along the A27 will be delayed. The A27 is struggling to cope and needs work whatever other development happens. The A27 corridor should be seen as an opportunity for a joined up approach to a major infrastructure and housing plan.
Our local water and sewerage systems also struggle and whilst fixing them would allow for more housing it would be a huge expense for relatively small return when compared to the A27 corridor.

I support the objective, but am concerned that without establishing achievable improvements to the A27 and ensuring the New Climate change map is sound it would be premature to propose to centre development in relatively small settlements along the West/east corridor. This could result in more congestion as Chichester will be the core settlement, without delivering the necessary infrastructure improvements. .

There needs to be clear agreement with the relevant statutory undertakers as to when the deficiencies in infrastructure will be rectified, so that housing land release is phased in line with such provision. This should be set out in an agreed Statement of Common Ground.
In relation to traffic mitigation to relieve congestion and to shift travel to sustainable and active travel modes the draft polices lack teeth to achieve these aims. Again land release for development should follow from such transport investment, not proceed it.

While the objective says all the right things the policies which follow in in draft Plan Policies will not achieve the stated objective..

Key infrastructure to support the local plan will be required to provide sufficient renewable electricity distribution for heating of housing, Electric Vehicle charging and community or individual solar power generation.

Amend as follows:
- To work with infrastructure providers to ensure the timely delivery of key infrastructure to ensure that there the needs of existing residents are met, and provide for all of the infrastructure requirements of existing dwellings prior to considering any new development, and then after that, to support delivery of new development.
- New development will be supported by sufficient provision of infrastructure to enable the sustainable delivery of the development strategy for the plan area.
- Key infrastructure to support the Local Plan will include improvements to transport, open space and green infrastructure, education, health, water supply and removal, telecommunications, flood risk and coastal change management and the provision of minerals and energy first for existing and then for new developments only if it can be demonstrated that there is resilience in the infrastructure to accommodate growth.
- A sustainable and integrated transport system will be achieved through improvements to walking and cycling networks and links to accessible public transport, including new train stop to serve any development that is located in Tangmere, using the existing railway between Barnham and Chichester to place a new station stop in Oving. Highway improvements will be delivered to mitigate congestion, including measures to mitigate potential impacts on the A27 through a predict and provide process.
- Sewerage undertakers will need to work with regulators to deliver improvements in wastewater infrastructure to support existing and new development and to ensure adverse environmental impacts are avoided in domestic properties, businesses on internationally designated habitats.
- Development proposals will be considered only after it can be demonstrated that there is a sustainable source of fresh water supply to meet the needs of existing requirement for the foreseeable future, and taking climate change into account. Improvements to water efficiency, conservation and storage capacity will be made. Infrastructure requirements will be kept under review through the Infrastructure Delivery and Business Plans and development will be phased to align with provision of essential infrastructure.

There is much to commend in this document and the supporting technical documents that accompany it, and I have listed in the appendix to this letter 26 such paragraphs and policies. I am happy for my support to be registered against these sections of your consultation document. There is also much upon which I must represent a concern, so I attach representations relating to 22 paragraphs or policies.

I am happy to participate in a hearing session, and I would flag at this stage that the common theme that links all of these representations is the need to safeguard the natural and built environment in and around Saxon Meadow, Tangmere from the risks of unsustainable development, I consider that the independent examiner should focus their review on the aspects of the local plan that relate to this matter.

Appendix 1: list of policies that I support
1. P14, 1.23, 1.24: Duty to cooperate
2. P24, para 2.30 "the council declared a climate emergency in July 2019"
3. P24, para 2.32 — "all proposal for new development should be considered in the context of a climate emergencV'
4, P30: Objective 2: natural environment: "development will achieve net gains in biodiversity'
5. P43, 4.1 "National policy promotes increasing energy efficiency, the minimisation of energy consumption and the development of renewable energy sources"
6. P43, 4.3: "Some renewable energy projects provide significant opportunities to enhance biodiversitV'
7. P53, Policy NE5: Biodiversity and Biodiversity Net Gain
8. P62, Para 4.42: Hedgerows and some types of woodlands are identified as a priority habitat
9, P62, Policy NE8: Proposals should have a minimum buffer zone of 15 metres from the boundary of ancient woodland or veteran trees to avoid rood damage (known as the root protection area)
10. P68, Policy NEIO: Criteria for Development in the Countryside - Does not prejudice viable agricultural operations or other viable uses
11. P80, Para 4.91: There are serious concerns about the impact of flooding, both in respect of current properties at risk but also the long-term management of the area.
12. 4.92: any development in the plan area must therefore have regard to flood and erosion risk.
13. 4.94: built development can lead to increased surface water run-off; therefore, new development should include SuDS to help cope with intense rainfall events
14. P81, Para 4.96: Environment Agency consent is required for any works within 16 m of tidal waters and 8m of fluvial watercourses in line with the Environmental Permitting Regulations 2016. This strip is required for access. The policy includes a setback requirement to ensure this access strip is not obstructed.
15. P80, 4.92, Any development in the plan area must therefore have regard to flood and erosion risk, now and in the future, by way of location and specific measures, such as additional flood alleviation, which will protect people, properties and vulnerable habitats from flooding. Recent changes to national guidance highlight the importance of considering flood risk from all sources, and this is particularly significant for the plan area as large parts of it are at risk from groundwater flooding, which needs to be recognised in development decisions alongside the well-established risks in relation to tidal, fluvial and surface water flooding. Appropriate mapping of all sources of flood risks is still evolving, and is likely to develop further over the plan period
16. P93, Policy NE20 Pollution: Development proposals must be designed to protect, and where possible, improve upon the amenities of existing and future residents, occupiers of buildings and the environment generally. Development proposals will need to address the criteria contained in, but not limited to, the policies concerning water quality; flood risk and water management; nutrient mitigation; lighting; air quality; noise; and contaminated land. Where development is likely to generate significant adverse impacts by reason of pollution, the council will require that the impacts are minimised and/or mitigated to an acceptable level within appropriate local/national standards, guidance, legislation and/or objectives.
17, P94, 4.127, Light pollution caused by excessive brightness can lead to annoyance, disturbance and impact wildlife, notably nocturnal animals. The design of lighting schemes should be carefully considered in development proposals to prevent light spillage and glare.
18. P94, 4.128, Dark skies are important for the conservation of natural habitats, cultural heritage and astronomy. The plan area includes three 'Dark Sky Discovery Site' designations, all located within the Chichester Harbour AONB; Eames Farm on Thorney Island, Maybush Copse in Chidham; and north of the John Q Davis footpath in West Itchenor. Development within or directly impacting these areas will be subject to particular scrutiny in terms of their impact on dark skies. The entire SDNPA area is also declared as an International Dark Sky Reserve. Development directly impacting this area will be subject to similar scrutiny.
19. P96, Policy NE22 Air Quality
20. P97, Policy NE-23 Noise
21. P142, Para 6.29, Amenity: Private space, shared space and the design quality and construction of communal spaces all contribute to amenity
22. P155-6, Policy P11:Conservation Areas "protecting the setting (including views into and out of the area)"
23, P55, Para 4.26 - The council is under a legal duty to protect designated habitats, by ensuring that new development does not have an adverse impact on important areas of nature conservation, and by requiring mitigation to negate the harm caused.
24. P58, Para 4.33 The council is under a legal duty to protect their designated bird populations and supporting habitats
25. P95, Para 4.129 The council has a duty to review and assess air quality within the district
26. P301, Conservation Area: An area of special architectural or historic interest, designated under the Planning (Listed Buildings & Conservation Areas) Act 1990. There is a statutory duty to preserve or enhance the character, appearance, or setting of these areas.

We support the reference to the need for waste water service providers to work with regulators to ensure adequate provision for the delivery of the plan. However we fear that in reality the required infrastructure will not be deliverable in the timescale of the Plan delivery which will lead to the continued discharging of untreated effluent into Chichester Harbour and other water bodies, including the Lavant, which flows into the Harbour. This will lead to the continued ecological decline of the harbour and work directly against the ambitions to restore it to favourable condition.

Plan for an integrated public transport system

There is nothing in the Plan to show how a sustainable and integrated transport system is to be achieved . Where are the consultations with Southern Rail and Stagecoach? The highway improvements to the A27 west of Chichester will not be achieved until AFTER the housing is built. No highway improvements, cycling or walking routes are planned for the A259 which will be under severe pressure from increasing numbers of cars because the transport infrastructure is not adequate to move residents away from their cars.

The plan should indicate a clear and precise interrelationship between new development and the provision of supporting infrastructure and wider infrastructure improvements.

Greater emphasis must be placed through development and site-specific policies to ensure essential infrastructure is provided ‘up front’ before first occupation, and other infrastructure needs provided before the development is completed or the developer has meaningfully left the site.

Past developments have failed to achieve improvements to the A27 and its junctions, and the proximity of some has constrained future opportunities for improvement. The developments, particularly volume housebuilding have added to, rather than mitigated congestion, by following a blinkered, site-centric attitude to meeting housing numbers without responsibility for infrastructure impacts.

I refer to Chapter 8 (Transport & Accessibility), Section 8.8 and Policy T1, items 1-4.
Bus services in Chichester are sparse, infrequent and expensive eg no 47 every 2 hours, no 56 every 1.5 hours. So local residents - many of advancing age - are forced to use cars to access town-centre shops and retail parks leading to frequent gridlock. There are also no services to the many new outlying developments - some families on Shopwhyke Lakes have waited four years for a bus service. They are also forced to use cars. Finally many people moved here from larger cities after the pandemic; our public transport providers do not offer any hardcopy timetables or maps (only online); this disempowers residents and leads to widespread confusion - yet another cause of additional car traffic which blights the city and environs.
Evidence from existing public transport performance is that our public transport providers, Stagecoach and Compass, are currently providing an ineffective and inadequate service. If public transport systems are not improved significantly they will not be able to satisfy the needs of residents and the vision of the Local Plan.

The plan is unsound and ineffective because, based on the present status of the key infrastructure of Bus Transport, walking and cycling networks, will not be improved in a timely manner to support the magnitude and timetable of the developments in the plan.
Drinking water where already considerable improvements are necessary and the timely delivery of sustainable sourced water to support the the planned housing developments is just as important as sewerage.

Support – WGPC supports this approach but questions how it could be applied to Wisborough Green. WGPC has concerns that the claims made will be neither addressed nor achieved in Wisborough Green:
- Public or sustainable transport
- Education places
- Healthcare provision
- Water supply
- Wastewater treatment capacity
-
Within the plan it states that Loxwood, Plaistow and Ifold and Wisborough Green are served by the Loxwood WTW. Kirdford is served by the Kirdford WTW. This is incorrect. Wisborough Green has its own WTW.

WGPC supports this approach.

Supports SOSCA's Submission as attached.

Executive Summary

The Local Plan as written lacks ambition and vision, and will be detrimental to the landscape within which the district lies. It is a plan borne out of a need to produce a legal document which will satisfy the regulatory authorities. In terms of Urban Planning it fails “To meet the needs of the present without compromising the ability of future generations to meet their own needs” (NPPF).

The development that will consequentially arise from the deployment of such a made Local Plan is not sustainable. It will adversely affect the Character, Amenity and Safety of the built environment, throughout our district.

In particular, the Local Plan is inadequate for the needs of the people in the district both at present and in the future because –

1. It has been written in advance of the District having a properly formed and agreed Climate Emergency Action Plan. It is inconceivable that such a key document will not shape our Local Plan. It is this Action Plan that is needed first in order to provide the long-term strategic view as to how and what the District will look like in the future; this, in turn, will help form and shape the policies outlined in any prospective, Local Plan. The Plan as proposed is moribund, as a result of “cart before the horse” thinking.

2. The Local Plan as written does not adequately address how infrastructure, transport and services are going to be materially and strategically improved to meet the predicted growth and shift to a significantly ageing population. There is presently insufficient capacity to supply services and to have adequate people and environmentally friendly connectivity, as a direct result of decades of neglect towards investing in infrastructure and services to meet the needs of the District’s population. We are led to believe that developers through increased levies in order to gain permission to build will fulfil this need, but all that this will result in is an uncoordinated, dysfunctional mess completely lacking in any future-proof master planning approach. We contend that this will do nothing for the quality of life of Chichester District residents and it will create a vacuum whereby few if indeed any can be held accountable or indeed found liable for shortcomings in the future.

3. The Local Plan as written does not state how it will go about addressing the need to create affordable homes. The District Council’s record on this matter since the last made plan has been inadequate and now the creation of affordable homes has become urgent as political/economic/social factors drive an ever increasing rate of change within the District.

4. Flood risks assessments used in forming the Plan are out of date (last completed in 2018) and any decision to allocate sites is contrary to Environment Agency policy. Additionally, since March 2021 Natural England established a position in relationship to ‘Hold the Line’ vs. ‘Managed Retreat’ in environmentally sensitive areas, of which the Chichester Harbour AONB is a significant example. CDC have failed to set out an appropriate policy within the proposed Local Plan that addresses this requirement.

5. The A27 needs significant investment in order to yield significant benefits for those travelling through the East-West corridor; this is unfunded. Essential improvements to the A27 are key to the success of any Local Plan particularly as the city’s ambitions are to expand significantly in the next two decades. But any ambitions will fall flat if the A27 is not improved before such plans are implemented.. The A259 is an increasingly dangerous so-called ‘resilient road’ with a significant increase in accidents and fatalities in recent years. In 2011, the BBC named the road as the “most crash prone A road” in the UK. There is nothing in the Local Plan that addresses this issue. There is no capacity within the strategic road network serving our district to accommodate the increase in housing planned, and the Local Plan does not guarantee it.

6. There is insufficient wastewater treatment capacity in the District to support the current houses let alone more. The tankering of wastewater from recent developments that Southern Water has not been able to connect to their network and in recent months the required emergency use of tankers to pump out overflowing sewers within our City/District reflects the gross weakness of short-termism dominated thinking at its worst and is an indictment of how broken our water system is. The provision of wastewater treatment is absolutely critical and essential to the well-being of all our residents and the long-term safety of our built environment. The abdication by those in authority, whether that be nationally, regionally or locally, is causing serious harm to the people to whom those in power owe a duty of care and their lack of urgency in dealing properly with this issue is seriously jeopardizing the environment in which we and all wildlife co-exist.

7. Settlement Boundaries should be left to the determination of Parish Councils to make and nobody else. The proposed policy outlined in the Local Plan to allow development on plots of land adjacent to existing settlement boundaries is ill-conceived and will lead to coalescence which is in contradiction of Policy NE3.

8. All the sites allocated in the Strategic Area Based Policies appear to be in the majority of cases Greenfield Sites. The plan makes little, if any reference to the development of Brownfield sites. In fact, there is not a Policy that relates to this source of land within the Local Plan as proposed. Whilst in the 2021 HELAA Report sites identified as being suitable for development in the District as being Brownfield sites were predicted to yield over 4000 new dwellings. Why would our Local Plan not seek to develop these sites ahead of Greenfield sites?

9. The Local Plan does not define the minimum size that a wildlife corridor should be in width. What does close proximity to a wildlife corridor mean? How can you have a policy (NE 4) that suggests you can have development within a wildlife corridor? These exceptions need to have clear measures and accountability for providing evidence of no adverse impact on the wildlife corridor where a development is proposed. Our view is quite clear. Wildlife and indeed nature in the UK is under serious and in the case of far too many species, potentially terminal threat. Natural England has suggested that a Wildlife Corridor should not be less than 100metres wide. The proposed Wildlife Corridors agreed to by CDC must be enlarged and fully protected from any development. This is essential and urgent for those Wildlife Corridors which allow wildlife to achieve essential connectivity between the Chichester Harbour AONB and the South Downs National Park.

10. Biodiversity Policy NE5 - This is an absolute nonsense. If biodiversity is going to be harmed there should be no ability to mitigate or for developers to be able to buy their way out of this situation. This mindset is exactly why we are seeing a significant decline in biodiversity in the District which should be a rich in biodiversity area and why the World Economic Forum Report (2023) cites the UK as one of the worst countries in the world for destroying its biodiversity.

11. In many cases as set out in the Policies the strategic requirements lack being SMART in nature – particularly the M Measurable. These need to be explicit and clear: “you get what you measure”.

12. 65% of the perimeter of the District of Chichester south of the SDNP is coastal in nature. The remainder being land-facing. Policy NE11 does not sufficiently address the impact of building property in close proximity to the area surrounding the harbour, something acknowledged by the Harbour Conservancy in a published report in 2018 reflecting upon how surrounding the harbour with housing was detrimental to it long-term health. And here we are 5 years on and all of the organizations that CDC are saying that they are working in collaboration with, to remedy the decline in the harbour’s condition, are failing to implement the actions necessary in a reasonable timescale. CDC are following when they should be actually taking the lead on the issue. Being followers rather than leaders makes it easy to abdicate responsibility. There must be full and transparent accountability.

13. The very significant space constraints for the plan area must be taken into account. The standard methodology need no longer apply where there are exceptional circumstances and we are certain that our District should be treated as a special case because of the developable land area is severely reduced by the South Downs National Park (SDNP) to the north and the unique marine AONB of Chichester Harbour to the south. A target of 535dpa is way too high. This number should be reduced to reflect the fact that only 30% of the area can be developed and much of that is rural/semi-rural land which provides essential connectivity for wildlife via a number of wildlife corridors running between the SDNP and the AONB. Excessive housebuilding will do irretrievable damage to the environment and lead to a significant deterioration in quality of life for all who reside within the East / West corridor.

14. Many of the sites identified in the Strategic & Area Based Policies could result in Grade 1 ^ 2 farmland being built upon. The UK is not self-sufficient in our food security. It is short-sighted to expect the world to return to what we have come to expect. Our good quality agricultural land should not all be covered with non-environmentally friendly designed homes.

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.

Natural England advise the inclusion of the phrase “and that nature-based solutions are incorporated into new development”, as this will provide multifunctional benefits such as managing surface water and grey waste, contributing to biodiversity and proving natural cooling from the effects of climate change.

Summary of advice
While we have raised some queries and recommended some further modifications to certain policies we do not find the Plan unsound on any grounds relating to our remit.
Natural England has reviewed the Proposed Submission Local Plan and accompanying appendices together with the Habitats Regulations Assessment (HRA) and Sustainability Appraisal (SA). Our detailed comments on the policies and site allocations are provided as follows:
• Annex 1 - Chapter 2 – Vision and Strategic Objectives
• Annex 2 - Chapter 4 – Climate Change and the Natural Environment
• Annex 3 - Chapter 5 (Housing) and Chapter 6 – (Place-making, Health and Well-being)
• Annex 4 - Chapter 7 (Employment and Economy) and Chapter 8 (Transport and
Accessibility)
• Annex 5 - Chaper 10 – Strategic and Area Based Policies
Please note that we have not provided comments on all policies but those which have most influence on environmental issues. Natural England has no comment to make on the policies not covered in this response. Other than confirming that we have referred to it when considering our advice on specific policies and site allocations Natural England has no general comments to make on the SA.
Unfortunately due to unforeseen resourcing issues while we have reviewed the associated HRA we are not in a position to provide detailed comment on it as part of this response. We will rectify this as soon as possible and can confirm that we have seen nothing in it that raises any major concerns.
The Plan has many positive aspects including standalone policies on Green Infrastructure (GI) and
wildlife corridors and an incredibly extensive suite of natural environment policies more generally.
We are hugely appreciative of the opportunity that we were given to work with you on shaping key policies post-Regulation 18. However, we believe that the plan needs to go further in it’s recognition of coastal squeeze as a key issue for the district, should include policy hooks for the forthcoming Local Nature Recovery Strategy (LNRS) and make up to date references to both the Environment Act (2021) and the Environmental Improvement Plan (EIP, 2023). Given how recent the publication of the EIP is we would be happy to discuss with your authority how this could best be achieved but
we believe given the wealth of natural capital within Chichester District it is vitally important that this latest iteration of the Local Plan is set in its full policy and legislative context.
We have suggested a significant number of amendments and additions to both policies and
supporting text throughout the Plan. In our view these could all be taken forward as minor modifications but if they were all acted upon they would leave the Plan much stronger and more coherent in delivering for the natural environment, one of the three central tenets of genuinely
sustainable development as set out in the National Planning Policy Framework (NPPF 2021,
paragraph 8c).

See attachment for representations on paragraphs/policies.

Amend objective to be to identify and deliver the infrastructure required to deliver the spatial strategy.

See attachment.

See attached representation.

Replace “the Local Plan will include improvements to transport….” With “the Local Plan will include improvements to active travel infrastructure, public transport……”

Replace “Highway improvements….” With “Highway capacity will be reallocated to design in Hierarchy for Road User, with priority for people walking, cycling, public transport so that people choose active travel or active travel combined with public transport as the obvious way to access what they need. This will eliminate congestion and remove the need to expand the A27.

See attached.

I support the objective, but am concerned that without establishing achievable improvements to the A27 and ensuring the New Climate change map is sound it would be premature to propose to centre development in relatively small settlements along the West/east corridor. This could result in more congestion as Chichester will be the core settlement, without delivering the necessary infrastructure improvements. .

See attached.

Within the plan it states that Loxwood, Plaistow and Ifold and Wisborough Green are served by the Loxwood WTW. Kirdford is served by the Kirdford WTW. This is incorrect. Wisborough Green has its own WTW.

Support – WGPC supports this approach but questions how it could be applied to Wisborough Green. WGPC has concerns that the claims made will be neither addressed nor achieved in Wisborough Green:
- Public or sustainable transport
- Education places
- Healthcare provision
- Water supply
- Wastewater treatment capacity
-
Within the plan it states that Loxwood, Plaistow and Ifold and Wisborough Green are served by the Loxwood WTW. Kirdford is served by the Kirdford WTW. This is incorrect. Wisborough Green has its own WTW.

See attachments.