Policy S11: Addressing Horticultural Needs

Large scale horticulture should be encouraged within easy access to the A27. Retaining Almodington and Sidlesham as small scale HDA sites makes sense. While these locations have significant transport/accessibility issues demand for small scale/sustainable/organic growing may increase in the future. There is also potential for combining green/environment/food related tourism activities in the peninsula with small scale food growing

Has the Tangmere HDA boundary been reviewed? The concrete 'Apron' needs to be re-designated for housing to reduce the pressure on the SDL. It will not be possible to build glass houses at this location ,now that the hangers have been developed for housing, because of light pollution. It should be noted that the new glasshouse access road has been set back from the housing line to prevent disturbance.

Large scale horticulture should be encouraged within easy access to the A27. Retaining Almodington and Sidlesham as small scale HDA sites makes sense. While these locations have significant transport/accessibility issues demand for small scale/sustainable/organic growing may increase in the future. There is also potential for combining green/environment/food related tourism activities in the peninsula with small scale food growing

But infrastructure and monitoring of the welfare of workers must be included. Light pollution/ pollution must also be monitored so it does not have a detrimental affect on the area.

This horticultural sector policy means small scale nurseries outside of the Horticultural Development Area are increasingly adversely affected and can no longer compete against the benefits of economies of scale afforded by the large scale horticultural development sites. This should irecognise an opportunity for small scale horticultural sites to provide housing given the pressure on housing for our communities. This opportunity should always take precedence compared to digging up greenfields which often takes prime agricultural land.I believe CDC planners are mindful of this - the promotion of development on brownfields is a well recognised policy and for good reason.

The wording of the policy which makes provision for glasshouses and polytunnels development has been interpreted to allow packhouse development on the Runcton HDA which is far in excess of that required to handle the produce grown on the HDA. This has led to a loss of valuable high-grade agricultural land which has been acknowledged as being in short supply, and has a severely detrimental effect on the landscape.

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.

The South Downs National Park occupies approximately 70% of the land area of Chichester District. The remaining 30% includes Chichester City with fairly limited opportunity for major housing sites. The remainder of CDC land area includes Chichester Harbour AONB, which is a RAMSAR site and SSI, Pagham Harbour which has SPA status and Medmerry which is designated as a potential SPA. For Government to require CDC to raise its Local Plan allocation from 435 dwellings p.a. to 609 dwellings p.a. (i.e. by 40%) and then expect CDC to accommodate a further 41 dwelling p.a. from the SDNP is wholly unreasonable. This is particularly so when many Parishes in the SDNP have expressed concern about the sustainability of their communities due to the lack of housing for their younger generation.

For the Manhood (3.11) "emphasis will be mainly upon protecting and enhancing the special qualities of the coast and its rural hinterland" and there is a "need to adapt to the potential impacts of climate change and sea level rise" (4.122).
The total housing numbers for the Manhood parishes is 950, and the plan also seeks to provide new employment opportunities "to reduce out-commuting". It also acknowledges the Manhood has "Significant areas at risk from coastal erosion and flooding, which is further accentuated by a high water table and poor land drainage" (4.121). Residents would add to this a barely adequate sewer system. In view of these factors it is hard to see how the plan's housing objectives can be achieved without building on a considerable area of prime agricultural/horticultural land which is surely one of the "special qualities of the coast and its hinterland" which the plan is "protecting and enhancing" (3.11). Development in East Wittering Parish is further constrained by its settlement area adjoining and spilling over into the parish of West Wittering whose allocation is just 25 dwellings.

The existing adopted plan recognised the problems of large-scale development on the Peninsula. The Western Mannhood's allocation of 330 homes (up to 1929) has already been exceeded. It is hard to see how a further 600 homes can be justified when the previously identified problems have not been mitigated and have been made worse by the development which has already taken place.

The plan acknowledges the "unique character" of the peninsula, and its tranquil nature. Each development lowers the physical attractiveness and uniqueness of the area, while the only road with "major" noise impact identified in the Peter Brett Transport Study is Bell Lane, passing through the Somerley Conservation Area. No significant deterioration of air quality is recognised; how can this be, even with an increase in the proportion of electric/hybrid private vehicles, if commercial development is envisaged, especially that south of the A27 close to residential Stockbridge?

A further disincentive to living, working, and holidaying on the Manhood is the difficulty of access, which gets worse as the A27 traffic increases, as it must do with further large-scale development along the East-West corridor. The planned mitigation in the form of a Stockbridge by-pass is at best a short-term solution, improving the problems with the Stockbridge Road roundabout. But any commercial development in the same area, south of the A27, would further raise traffic levels attempting to reach the A27 from the new route. So
at worst, if the proposed commercial development at AL6 is taken into consideration, the proposed new Link Road from the western end of the by-pass to Birdham Road is likely to create a new "Vinnetrow Road" situation at the Fishbourne roundabout.

The proposed industrial / housing development at AL6 is largely within an area of agricultural land prone to flooding: it is close to the R. Lavant and susceptible to further damage from rising sea-levels. AL6 does not mention these major risks, though AL4 specifically mentions the need to avoid the flood-plain of the Lavant in relation to Madgwick Lane. Further, such a development contradicts DM28, there being "adverse impact on the openness of the views in and around the coast, designated environmental areas and the setting of the South Downs National Park"; and the tranquil and rural character of the area. Salterns Way cycle route would be alongside the development; the much prized peacefulness of the route and the views of the cathedral and Downs would be destroyed. Furthermore, AL6 is adjacent to Chichester Harbour which as previously mentioned is not only an AONB but is a RAMSAR site and SSI. There is evidence of Winter grazing by migratory birds in the area designated as AL6.

Traffic levels within the Manhood are already such that heavy commercial vehicles choose to use country lanes which were not built for the capacity, while the transport of agricultural/horticultural produce, particularly on the B2145, and the movement of agricultural machinery has a significant impact on journey time. Further housing and commercial development will require mitigation on the Peninsula itself.

Turning to the Brett Transport Study and the Appendix dealing with Air Pollution, given what they say in 3.2.22 and particularly in 3.2.23, it is staggering that in 3.2.24 they make their glib 'standard' statement when we know already that 4.1% of deaths in Chichester are due to PM2.5 pollutants from vehicle emissions.

How can 3.2.24 consider future vehicle uncertainties ref 3.2.22, if they are uncertain? There is no risk analysis in the Brett report to support the assertion that: the report is 'an appropriately conservative assessment.' The real risk to lives in this area is too significant to be dealt with in this superficial way.

In considering alternative industrial / housing sites to AL6, AL4, which is included in the current CDC Local Plan, is ideal. It is recognised that this has been withdrawn from the HELLA; consideration should however be given to using compulsory purchase powers to acquire this site for industrial use. Most airports / airfields in the UK have industrial area on their boundaries.
The Peter Brett Transport Study estimates that the cost of mitigation measures at £68m, this level is clearly way beyond the level at which it could be funded by developer contributions. Without defined future funding plans, housing development should be phased in line with actual funding.

It is encouraging to see the proposed introduction of "wildlife corridors" to the east and west of Chichester linking the Downs with Pagham and Chichester Harbours respectively. However they should not be positioned where they conflict with 5.24 which addresses the possibility of an A27 northern relief road. They should also be wider at the coastal end: the two to the east of the city could even be joined to form one.

As the plan recognises the international importance of the two harbours and the Medmerry Realignment for wetland habitat (2.25), it would be a positive step to designate a protected area to link Chichester and Pagham Harbours in the same way.

Earnley Parish Council is pleased that small-scale Horticultural Development will still be focussed on the two former LSA sites in Almodington and Sidlesham, and applauds DM21, which sets out the conditions for redevelopment of buildings in the countryside, where currently there seems to be a presumption in favour of housing.

Currently there is a demographic imbalance on the Manhood and in CDC in general. Locally we are all aware of the need to provide accommodation which attracts younger people into the area and gives our own young people the opportunity to make their homes here. How can this happen? To use the term "affordable housing" is a deception. In an area with such high market-rate housing, "affordable" is simply not affordable. In a holiday area, the rental market is limited and distorted by the high number of holiday lets; there is no guarantee that new housing would not benefit tourists rather than prospective residents. The proposed Plan is, of course, moulded and constrained by government policy, but there is nothing in it which comes close to solving this part of our "housing crisis".

To sum up, Earnley Parish Council:
* Is opposed to the scale of development proposed for the Manhood Peninsula
o Believes this level of development to be unsustainable
o Believes it to be incompatible with maintaining the rural character of the area and the mixed nature of the local economy
* Finds the mitigaton propsed for the A27 to be insufficient and ineffective
* Is opposed to the AL6 development
* Is concerned by the increases in air and noise polution
* Urges CDC and WSCC to consider more closely the social housing needs of the area

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Spatial Vision
Portsmouth Water note that there are significant additional housing allocations to the west of Chichester and on the coastal strip. These sites will need to be assessed for water supply and funding included in the Infrastructure Charging scheme. (See Map 4.1 Key Diagram)

It is not clear what water storage capacity is being referred to in Section 3.19. Portsmouth Water will review the provision of Service Reservoirs, for day to day use, and has re-started development of a large raw water storage reservoir at Havant Thicket. The reservoir, when combined with Portsmouth Water's existing sources and enhancements to its groundwater sources, would create sufficient
surplus to support an additional flexible daily transfer of treated water from Portsmouth Water are to Southern Water without detriment to Portsmouth Water's resilience.

Southern Water requires this transfer to help meet a significant deficit in its Southampton East, Southampton West and Isle of Wight resource zones. This deficit arose after Southern Water agreed to reduce its abstraction licences on the Rivers Test and River Itchen at a public inquiry in March 2018, to help protect the environment.

It is not clear that the water demands of the Horticultural Development Areas have been assessed. It is possible that these businesses will rely on rainwater harvesting and storage but changes in licencing regulations mean that 'Trickle Irrigation' is no longer exempt from abstraction licencing.

Groundwater abstraction in the coastal plain will require an impact assessment under the Habitats Regulations. (Section 4.75)

Spatial Strategy

Policy S12 sets out how development can make effective use of existing infrastructure. Portsmouth Water agree that the siting and timing of development can assist with the economic provision of water resource infrastructure. It also states that safeguarding existing infrastructure, such as water mains and aquifers, is important. Portsmouth Water would urge developers to check for existing infrastructure and for source protection zones that may limit development options.
Water infrastructure is not funded through CIL but a separate 'Infrastructure Charge' payable for each individual house. This is designed to pay for all off-site water infrastructure such as mains reinforcements, service reservoirs and supply. Development to an agreed program will help this system work effectively.

Strategic Policies

Policy S27 'Flood Risk Management' refers to Sustainable Drainage Systems (SuDS) and the need to control surface water run-off. It should also refer to aquifer protection and the need for caution when using infiltration systems especially deep bore systems. This applies particularly when the site is in, or close to, a source protection zone.

Policy S31 'Wastewater Management and Water Quality' refers to higher standards in the Building Regulations for water consumption to reduce pollution in the harbours. Portsmouth Waters 'Water Resources Management Plan' is based on lower per capita consumption and we have an aspiration for all customer to reach 100 litres/head/day by 2050. This is no substitute for reducing overall flows
to sewage treatment works by the control of groundwater infiltration and surface water drainage.

Strategic Site Allocations

Policy AL1 'West of Chichester' does not mention water supply so we assume that the site has reverted to a conventional system with sewerage pumped to Tangmere WWTW and water supplied by us. Portsmouth Water has provided provisional designs for this system and there are no existing large diameter water mains on the site. Costs for reinforcement of the water mains will be recovered by the new Infrastructure Charge and on site mains are likely to be provided by a third
party. Information on how reinforcement of the water mains is recovered by the Infrastructure Charge can be found in Portsmouth Water's Developer Charging Arrangements on our website under https://www.portsmouthwater.co.uk/developers/.

Policy AL2 'Shopwyke' is already under construction and has a conventional water supply system with all elements provided by us. Costs are being recovered via the Infrastructure Charge and on-site charges.

Policy AL3 'East of Chichester' is a new strategic site and there are no large diameter mains crossing it. This is an old landfill and may contain material that can damage plastic pipes. On site mains may need to be protected or be more expensive to ensure water quality is maintained.

Policy AL4 'Westhampnett' Phase 1 is already under construction and account has been taken of the large diameter main that crosses the site. Phase 2 is an extension of the existing Greylingwell site but it is not clear if this has been allowed for in the design of this 'Inset Appointment'. Portsmouth Water do not own the mains and there may be a single point of supply.

Policy AL5 'Southern Gateway' is an inner city development with a good water supply system. The reference to the 'efficient use of water' is confusing because many of the other strategic development sites also drain to Apuldram WWTW. All sites need to be water efficient but not follow the example of the 'Code for Sustainable Homes'. Sites were developed in Chichester that used rainwater harvesting to meet the Code objectives but were able to use higher water use fittings such as power showers. This led to properties producing more sewage than equivalent water efficient homes. This did not achieve the objective at Apuldram. An alternative provision might be to reduce infiltration but it is not clear how this would be funded or who would carry out the work.

Policy AL6 'South West Chichester' is crossed by a large diameter main that will have to be reflected in the road layout or diverted. The proposed link road may offer an alternative route for the main.

Policy AL7 'Bosham' is situated on the old A27 and there are no large diameter mains in the area.

Policy AL8 'East Wittering' is at the extremity of the distribution system and may be expensive to supply.

Policy AL9 'Fishbourne' allocation is not site specific and it is difficult to comment on the feasibility of water supply. Any off site costs will be recovered via the new Infrastructure Charge. Portsmouth Water have public water supply abstractions in the area and development is likely to be located in a source protection zone for our Fishbourne public water supply abstraction. Under this policy, where development is in a source protection zone, the policy should also refer to groundwater quality
protection and the additional requirements when using infiltration systems in particular deep bore systems. Further guidance on Portsmouth Water's preferred approach to development relating to groundwater quality within our catchments can be found within 'Portsmouth Water's Groundwater Protection Guidance notes' which are attached to this response and also available to view on our website under https://www.portsmouthwater.co.uk/developers/groundwater-protection/.

Policy AL10 'Chidham and Hambrook' is a large site and may need to be considered in combination with 'Southbourne' and 'Bosham'. There are no large diameter mains in the area and mains reinforcements may be required.

Policy AL11 'Hunston' allocation is not site specific.

Policy A12 'Selsey' is at the extremity of the distribution system and has seen previous housing growth. Reinforcement of the water mains may need to be provided.

Policy AL13 'Southbourne' is supplied from a different distribution system to Chichester. This is a very large housing allocation and this may need to be considered in combination with 'Hambrook' and 'Bosham'. There are sufficient water resources for all the housing allocated to Portsmouth Water's area of supply. It is the location of the housing site in relation to existing trunk mains and
service reservoirs that determines the cost to supply. Local reinforcement of the water mains may be required.

Policy AL14 'Tangmere' housing allocation has increased by 30% and we may need to repeat the modelling that has already been done. There is also uncertainty about the water supply to the HDA which seems to rely on rainwater harvesting for future growth. The housing development and the HDA could have an impact on our source protection zone. Under this policy, where development is in a source protection zone, the policy should also refer to groundwater quality protection and the
additional requirements when using infiltration systems in particular deep bore systems. Guidance should be sought from Portsmouth Water's Groundwater Protection Guidance for development.

Policy AL15 'Land at Chichester Business Park, Tangmere' Portsmouth Water have public water supply abstractions in the area and the site allocation is likely to be within a source protection zone for our Aldingbourne public water supply abstraction. As above, where development is in a source protection zone, the policy should also refer to groundwater quality protection and the need for caution when using infiltration systems in particular deep bore systems. Please refer to Portsmouth Water's Groundwater Protection Guidance for further information.

Development Management

Policy DM10: 'New Employment Sites' Development proposal should be compatible with other policies in the Plan, in particular DM9 'Existing Employment Sites' to ensure that the development is otherwise acceptable. Policy DM9 states that development should 'not generate unacceptable levels of water pollution' and this should include groundwater pollution. This requirement should also be applied to Policy DM10, especially when the site is in, or close to, a source protection zone.

Policy DM15 'Horticultural Development' Developments at Tangmere HDA have relied on infiltration to dispose of excess surface water. This policy states that development should 'not generate unacceptable levels of water pollution' and this should include groundwater pollution. Portsmouth Water have public water supply abstractions in the area and the potential impacts must be assessed for any SUDS. The EA 'Abstraction Licencing Strategy' (ALS) may give an indication about the
availability of groundwater but it does not cover the derogation of existing supplies.

Policy DM16 'Sustainable Design and Construction' covers the use of Building Regulations to control water use. Portsmouth Water have an aspiration to reduce overall water use to 100 litres/head/day and this policy will help to achieve that aim.

Policy DM18 'Water Management' using SUDS needs to take account groundwater quality and should avoid direct infiltration into the chalk aquifer. This is especially important within the source protection zones.

Policy DM29 'Biodiversity' Portsmouth Water has legal duties to protect and where practical enhance biodiversity and has an active program of work on it's own land. This work is now expanding to include projects on other people's land in association with 'Catchment Management' activities. We would look to CDC for support in areas such as Bosham Stream, Lavant Stream and Fishbourne Stream where schemes could be developed in partnership with local housing developments.

Policy DM35 'Equestrian Development' can have a direct impact on water quality including groundwater quality. Portsmouth Water support the protection of water courses and aquifers.

Appendix 'E' Monitoring Framework

Policy S12 covers the provision of infrastructure but it is not clear how records of completed projects will be collected or stored.

Policy S26 covers biodiversity improvements and Natural England should be consulted on priorities and record keeping.

Policy S31 covers water consumption which is only available for the whole Company area in the WRMP Annual Review.