Policy S13: Chichester City Development Principles

Generally support but consider increasing housing numbers in the city and adjacent surrounds by allocation of more social housing and higher density housing, including more apartments. Object to the provision of a commercial development site and raised link road near Apuldram/Donnington as this area contains some of the most important cathedral views in the district from the harbour, marina, Salterns Way, and A286- views enjoyed by many visitors and residents.Also site is on flood plain and adjacent to internationally important habitat areas.This development would be better sited in the noise buffer zone to the south/west of the motor racing circuit

The Chichester Society welcome the minor changes proposed which include the protection of views of the cathedral. Please note the duplication of the policy on the city's existing heritage, arts and culture.

The policy relating to city centre housing density of at least 35dph was not considered to be particularly helpful, as it is arbitrary and, in practice, density depends very much on site constraints and surrounding context.

The policy relating to Chichester city centre was generally supported as relevant and positive.

There was significant concern about reduction of town centre parking provision. Concerns were that this may affect the vitality and viability of the city centre and that any parking changes may disproportionately affect older and less mobile residents as well those encumbered by purchases all of whom rely on close and convenient access to parking.

It was suggested that park and ride should be looked into, although it was noted that it had been investigated as part of the District Council's background documents. It was also noted that any changes to parking provision or restrictions should tie in with the road space audit.

Policy S 13
Third bullet is in part a repeat of the second bullet:.delete third bullet
There is no mention in the Policy or in the accompanying paragraphs of funding and support by others on which S 13 depends heavily-experience so far with Homes England is not encouraging

The minor changes proposed which include the protection of views of the cathedral is welcomed.

Support in general with specific support for the paragraph relating to the provision of "..... improved facilities for .... other social and community uses."

Retail Hierarchy and Sequential Approach.

We support this policy and commend the six bullet points in para 4.60. We strongly support in 4.66 the promotion of the city centre's retail offer and the restriction of further retail development in out-of-centre locations.

Chichester City Development Proposals.
Whilst this acknowledges need for new development to have special regard for the city's historic character by the use of Supplementary Planning Documents or Development Plan Documents, what faith can we have that they will be adhered to? The previous Southern Gateway Development Framework specified that buildings should be two storey with occasional three. Despite this the recent canal-side development, known as John Rennie Road, was permitted to be three storey with a lot of four, and is of such poor quality design it damages the approach to the city and the Conservation Area. Chichester Gate, as permitted, is an architectural disaster displaying as it does poor design and cheap materials. Furthermore the policy should make the point that the whole of the city centre is a conservation area and should be respected as such. A map shewing the Conservation Area boundary should be appended to the Local Plan

The Council must undertake to enforce the provisions of their SPDs etc otherwise they are worthless. The policy should make the point that the whole of the city centre is a conservation area and should be respected as such. A map shewing the Conservation Area boundary should be appended to the Local Plan.

Design
This acknowledges the historic environment, the need to create high quality buildings and the need for policies to drive this. All well and good - but policies need to be adhered to by CDC when determining applications and there is little evidence of this happening at present.
Policy S20 introduces the concept of 'Sense of Place' and the importance of getting scale, height density right. This is a laudable aspiration which has been ignored in the past.

Ensure the policy is enforced when determining all planning applications

Historic Environment.
This acknowledges the importance of Heritage Assets, the need for further Conservation Area Character Appraisals (CACA) and the importance of protecting Heritage Assets. Fine - but with no Conservation Officers on the staff preparation of CACAs is falling woefully behind. The revision to the Chichester CACA is still not completed over two years on.

Commit to filling the Conservation Officer posts and completing all the CACAs as a matter of urgency

Southern Gateway
This policy fails to acknowledge that a large part of the designated Southern Gateway area lies within the Conservation Area and includes several Designated and Non-Designated Heritage Assets, GII-listed buildings in Southgate and Basin Road, buildings on the Local List and others identified as positive in the latest Conservation Area Character Appraisal. The statements regarding the majority of the buildings in the SG area not making a positive contribution are misleading. The railway station, county court, Boys' High School and bus garage all do make a positive contribution. The bus garage is an important example of the early use of thin-shell pre-stressed concrete to give a clear span. It is an attractive building whose open space should be put to new uses (an open market for e.g.). Once again the need for high quality design is included in the policy but will it be enforced? The Southern Gateway has recently been defiled by two appalling permitted developments - John Rennie Road and Chichester Gate.
The ideas for traffic management and diverting all but buses along Basin Road are dubious.

Correct the policy by stating that the SG area is in the Conservation Area and include from the above about the heritage assets, listed buildings etc. Also commit to enforcing the design policy.

Chichester Centre Retail
We support paragraphs 1 to 4 of this policy and revision to the shopping frontages, especially with regard to Crane Street. The policy rightly acknowledges the constraints of the historic character of the city centre and the need to improve the visitor experience. Out-of-town retail developments such as Barnfield suck the life out of the city centre and should be resisted. 7.69 mentions the importance of considering the Council's Shopfront and Advertisement Design Guidance Note within the Conservation Area. This is a laudable aim but, sadly, shopfronts which patently do not conform are usually permitted. The Guide requires hand painted lettering on a painted timber fascia, yet metal or plastic fascias with raised lettering are invariably permitted without question. Case officers do not seem to know of the existence of the guide and one has to wonder whether applicants are made aware of it. It is not easy to find on the CDC website.

Ensure case officers are aware of the ship front guide and that it is enforced in their decisions. Strengthen enforcement to rule on unauthorised shopfronts

Historic Environment
7.154-7.166 acknowledges conservation areas, the existence of local lists and character appraisals and emphasises the need for further conservation area character appraisals (CACA) and the need to protect Heritage Assets. Fine words, but with no Conservation Officers on the staff all this is getting woefully behind. The revision to the Chichester CACA is still not completed over two years on. CCAAC have put forward in the past four years several proposals for additions to the local list whose scoring was agreed by the then Historic Buildings Advisor but which have still not been signed off, leaving those buildings with no protection Once again, with no conservation officers these aspirations cannot be met .
Policy DM27 itself includes conserving and enhancing the special interest and settings of designated and Non-Designated Heritage Assets but not about the need to protect these assets themselves. This omission should be corrected

Complete processing of outstanding Local List applications, appoint Conservation Officers, and reword the policy to provide for protecting the assets

The Goodwood Estates Ltd welcomes the opportunity to again participating in shaping the future of the District through this review of the local plan. The authority will be well aware of the Estate's firm view on the future scale, shape and form of Chichester to ensure that it retains the very special characteristics that underlie its economic success.

Development to meet the growing needs of the City and its environs must be accommodated if the District is to prosper and grow, but this should not mean a "free-hand" for developers on each and every undeveloped 'greenfield' around the City. Development of the next area of undeveloped land adjacent to the city's existing boundaries does not mean it is the most sustainable approach for the community as a whole. It is all too easy for landowners, at a time of acute housing demand, to promote sites as the next closest to available services (often 'as the crow flies') providing housing quickly to meet that undeniable need. The north and north-eastern edges of the city are vulnerable in this regard, an area for which the maintenance of openness is essential for the sustainable and sound interrelationship of Chichester with the neighbouring national park.

Up and down the country, the negative effects of suburban housing growth promoted on that basis are experienced; often without a true recognition of infrastructure needs and a consequential increase in car borne journeys and loss of greenspace. Equally the often, bland design and over-developed sub-urban layouts, tacked on to urban edges, may mathematically meet local needs and offer people an opportunity to own or rent a home, but consequentially erode the community and character of locations to the long-term detriment of its economic base, identity and community distinctiveness; this is particularly true of cities such as Chichester, where the overall character and ambience underpins much of its economic success.

The authority will be well aware of the "Cathedral Cities Initiative", which seeks to recognise the economic and heritage importance of protecting the form and context of the country's important cathedral cities and historic market towns. By providing clear, precise and 'joined up' planning policy protection, that directs new development and associated infrastructure appropriately to sites best able to accommodate it in terms of benefits to the community as a whole (offering benefits in excess of the provision of additional homes and not just the individual interests of the landowner 'dressed up' as offering wider local benefit) it will prevent inappropriate inner-urban and sub-urban development that will cumulatively destroy the true character and distinctiveness of the city.

Chichester is used as an exemplar in the Cathedral Cities initiative, promoted initially at the time of formulating the last local plan for the District, where there was a real threat unchecked urban expansion would undermine the very essence of the District's local economy. That threat has been reduced through this local plan by changes to strategic allocations, but the threat remains from unscrupulous developers and landowners who will continue to exploit the 'loop hole' provided by a lack of housing supply or incomplete planning policy position (potentially an acute situation until this plan is adopted). It is essential this plan not only makes provision to meet objectively assessed housing and employment needs but equally ensures that essential open areas, around and within the city, which contribute positively to its setting, character and economic vitality are given long-term protection through specific policy designation.

The NPPF is explicit that sustainability is a true balance of social, economic and environmental considerations. This means the plan must represent a true reflection of the suitability of a location to accommodate additional growth in a meaningful way. It must not apply the over simplified, developer led approach that the next piece of available land nearest the centre must be sustainable and developed for housing. A robust strategy will look at all sites within the district making use of all appropriate and available land within urban areas, surrounding settlements and along transport corridors, as well as the "easy pickings" on the urban edges. Development sites further from the city centre ,can often prove more sustainable in terms of the NPPF sustainability balance than sites that comprise the next undeveloped site on the urban edge. Any development promoted must, as a minimum, ensure that it demonstrates a positive response to the sustainability balance, not just meeting a mathematical housing need, and provide appropriately, not only for the infrastructure needs of the housing to be provided , but also for the community as a whole; too many development proposals focus simply on the needs of the individual site giving rise to the many real concerns of local people that the community does not have the capacity to absorb additional housing.

The Estate is therefore heartened to see the council taking a bold step through this Local Plan Review to reconsider previous development scenarios, while ensuring that a true level of housing need is accommodated. Paragraphs 4.30 to 4.33 recognise it is not sustainable to continue to rely on past sources of supply. We support this stance fully and encourage the council to take the initiative forward even at this early stage. As stated in the draft plan, there is a long lead in time to such a fundamental and complex change of direction in strategic development, but without a meaningful start now old habits will continue, resulting in an increasing unsustainable City and loss of the very factors that undermine its economic success. There is an inevitability that developers and landowners affected by the changes, will, through planning applications and appeals, do their utmost to ensure their individual interests are protected, over and above the long-term impacts of inappropriate developments on the community as a whole. To counter such proposals in the short term, this plan must set out a logical, precise and robust strategy that follows all up to date Government advice in a positive and sustainable manner

The Estate believes a sound planning strategy set out in this local plan review can deliver ample development land within the district in a manner that will meet housing and employment needs while protecting the very important transitional relationship offered by land between the urban edge and the SDNP boundary. This will involve a step change from past trends of allocating the next area of land as development locations, to be focussed more on evolving settlement hubs on good transport routes, such as around Tangmere, and allowing appropriate scales of development to sustain rural settlements that have to date be excluded from growth considerations. This will involve an on-going dialogue with adjoining authorities under the duty to co-operate to ensure future development is located in sustainable locations where it is most appropriate and not simply in locations of least (often political or subjective) resistance. The Estate will support the council in its emerging strategy and looks forward to working alongside it in the pursuit of a sustainable social, economic and environmental future.

The district is both fortunate but equally unfortunate to have a large part of its area within the National Park, a similarity it shares with the Estate. The purpose and objectives of the Park are acknowledged and supported, and the Estate continues to work with SDNP to establish a planning regime that recognises the true role of landed estates in establishing the character and form of the National Park. This includes the generation of planning policy and proposals through the emerging National Park Local Plan, that recognise the importance of allowing estates to continue to evolve such that the character of the National Park can be sustained. This includes an appropriate planning approach that allows justified estate development, which may at times appear 'at odds' with general national park objectives.

It is the Estate's belief the Park has not considered the true development capacity of its area and this will have unintended consequences on communities, not only within the Park itself, but also within surrounding districts. If the Park is to avoid development up to its boundary, in part a response to its own displaced needs, it is important the District retains existing open land to the north and north east of the city, permitting only new development and activity that are appropriate to a rural area, complement existing land uses and or which maintain the essential openness of the area.

Land between the city and National Park is an area that must be governed by landscape priorities that provide a crucial open, and where deliverable, accessible green space to the city community, but equally provides
(a) clear linkages to the national park,
(b) protects the integrity of the National Park boundary, and
(c) protects the important relationship and setting of city and Park.
Definition of the City Boundary (Plan SB1) should not simply be a red line on a plan, but supported by clear policies and proposals to encourage the boundary to be enhanced and defended.

The Estate owns a significant "buffer" area between the National Park and City (Goodwood Estate Plan 1) and will continue to work closely with both the Council and the SDNPA to achieve such an objective; to establish an appropriate planning policy regime for land between the city edge and National Park. A sound planning approach to the use of land south of Lavant Straight, between the A285 and A286, will ensure policy objectives within that area are complementary, and do not detract from the setting of either the historic city or national park. The land should be kept open primarily with the exception of appropriate development around the settlements of Westhampnett, Westerton, Strettington, and at Goodwood Aerodrome and Motor Circuit (as more specifically controlled through other policies of the plan). The land should be used for agriculture, countryside, forestry, public access and other landscape purposes.

Through representations to this local plan, set out in individual comments to policies and sections, the Estate seeks to demonstrate its commitment to the future sustainability of Chichester and its community through appropriate use of this "buffer area."

New policies proposed through the Local Plan, such as those proposed for the Goodwood Motor Circuit and Aerodrome, provide a positive response to the above objectives and are to be supported. Provision of a "Whole Estate Plan" for Goodwood as required by policies contained in the emerging National Park Local Plan, will provide a planning policy context that straddles the District/National Park boundary. The District Local Plan should acknowledge this approach and ensure that its policies do not conflict.

That part of the Goodwood Estate not falling within the National Park lies within the East-West corridor. While the planning justification for the corridor is understood, the Estate has held reservations about the scale, form and location of some development, particularly that falling within the north-east Chichester Strategic Allocation. It has been our long-held belief that the allocation was more for mathematical expediency and appeal defence than a sound planning strategy and we are encouraged by the change in direction to the strategic allocation and the long-term aspirations proposed through the draft plan.

Paragraph 4.88 should make it explicit that although it is a focus for growth to 2035, the corridor does not mean that any site within its parameters is suitable for development. The setting of the city, particularly it's relationship with the National Park, is to be protected and Policy S13 must be given more strength in this respect to ensure this matter is at the forefront of planning decisions. This can be done by expanding the bullet points as follows (in red):

Policy S13: Chichester City Development Principles
New development, infrastructure and facilities will be planned for Chichester City that enhance the city's role as a sub-regional centre and visitor destination, contribute to meeting local needs, and conserve and enhance the city's historic character, heritage and wider environs, particularly along the edge of the national park boundary. This will include provision for development and proposals that:
* Support and strengthen the vitality and viability of the city centre and its role as a shopping/visitor destination, employment centre and a place to live;
* Support and enhance the city's existing heritage, arts and cultural facilities;
* Enhance the city's existing heritage, arts and cultural facilities;
* Enhance the city's existing entertainment and leisure offer, including the 'evening economy' and major events;
* Reinforce and strengthen the city's office market;
* Protect views of the cathedral and the setting of the city from the surrounding landscape and adjoining National Park, including the provision of new green infrastructure and green space;
* Provide or contribute towards improved facilities for education, health and other social and community uses;
* Enhance the character and distinctiveness of the city's local neighbourhoods, including conserving their settings and features;
* Provide or contribute towards an enhanced network of green infrastructure, including additional parks and amenity open space, outdoor sport pitches, recreational routes and access to natural green space particular where these can be linked at landscape scale and or providing connectively with the SDNP ;
* Support and promote improved access to the city and National Park using sustainable modes of travel in accordance with the transport strategy for the city (see Policy S14); and
* Enhance the public realm, especially within the city centre and key routes in and out of the city.
All development will be required to have special regard to the city's historic character, setting and heritage. Development proposals should be underpinned by robust historic characterisation and impact assessments and make a positive contribution to the city's unique, setting, character and distinctiveness.
If necessary, the Council may prepare a Supplementary Planning Document(s) or Development Plan Document(s) which will set out a coordinated planning framework covering Chichester City centre and other areas of change in the city and its environs, which will identify development sites, transport and environmental improvements and define areas within which specific uses or means of protection are considered appropriate or and will be supported.

Southern Gateway for offices, commerce and more dwellings? Really?
We have a half empty high street and empty industrial units (Terminus Road).
We do not need these or the traffic and associated pollution that they bring.

We support these principles, in particular support for enhancement of Chichester's arts and cultural facilities and entertainment and leisure uses.

Para. 4.88 makes no mention of Public Rights of Way, etc - there are large volumes of pedestrians/cyclists on some routes, e.g. the footbridge which replaced the "Fishbourne" level crossing (from Fishbourne Road East to Westgate) and on Centurion Way. (There will be others, I just happen to live close to these so am more familiar with them.) It is not clear that anyone is capturing data on pedestrian movements to help inform infrastructure/development decisions.

I broadly support Policy S13, including the recognition of local neighbourhoods as places of character and distinctiveness (as is Parklands, the community where I live).
I would like the green infrastructure bullet point also to recognise the importance of nature in a utility setting, such as street trees and verges.

There seems to be a duplication of "enhance the city's existing heritage, arts and cultural facilities".

I would like an additional bullet point along the lines of:
"Enhance the street scene with public art appropriate to the setting" (I am thinking of things like the Minerva wall relief at Crane Street, street art, the Keats bench, the concrete "heads" on the bridge over the Lavant near the College underpass).

N.B. As a Committee member of Parklands' Residents' Association (PRA), please note that PRA may wish to pursue these subjects with CDC and with the Inspector at Examination in Public, if it is not adequately addressed.
Also, as a volunteer Chichester Tree Warden, Chichester Tree Wardens may wish to pursue the subject of policy relating to trees in the context of Chichester City Development Principles.

Para 4.88 should recognise the significant number of people who travel on foot and on bikes along this corridor.

Support Policy S13

4.88
The decision to develop along the East West corridor is short sighted and damaging to the area and will not enhance the villages. The infrastructure is not present. It will develop land too close to the AONB and create a housing corridor.

4.92
This area must be fully redeveloped with Hotel, Multi use centre for exhibitions, concerts and conferences with a site for community use. An area must also be created for young business leaders with gigabyte connectivity. Space should also be found for the University to incubate businesses. Housing should focus on young people wishing to live in the city.

Policy S13 Chichester City Development Principles
I support the protection of the views of the Cathedral

Policy S14 Chichester City Transport Strategy
I propose the following aspects are added in:-
a) Replacement of the level crossings in Basin Road and Stockbridge Road by a height limited underpass capable of taking single decker busses and being accommodated between the Kingsham Road junction and extended Avenue de Chartres junction on Basin Road. This would also incorporate a grade separated cycle and footway.
b) Safeguarding of land to enable the expansion of Chichester Railway Station from its present 2 platforms to 4 as envisaged by Network Rail to enable a faster service from Portsmouth to Brighton, and to allow for a fully integrated transport hub for bus and rail services.
c) Safeguarding of land close to the A27fora future "park and ride".
d) Safeguarding of land close to the A27for a "consolidation centre "for break bulk delivery to city centre retail units.

Policy S20; Design
I welcome this proposed additional policy to be used positively to protect our City against the creep of dumbing down with the poor design quality of new housing estates and ill-considered extensions and alterations to existing housing.

Policy S23; Transport and Accessibility
a) This additional policy is welcomed
b) I particularly welcome the proposed new road connecting Birdham Road to the A27 at Fishbourne roundabout. This was known as the Stockbridge Link Road as part of Highways England Option 2in their 2016 ill-fated consultation. I feel other aspects of Option 2 should be allowed for future inclusion particularly the flyovers for the A27 at the Fishbourne and Bognor Road roundabouts.

Policy AL5; Southern Gateway

a) In site specific requirement number 3 I propose " Respect for the historic context, have regard to that part of Southern Gateway that lies within the Conservation Area and to the Listed Buildings and Heritage Aspects and make a positive contribution towards protecting and enhancing the local character and special heritage of the Aareaand important historic viewsespecially those from the Canal and its Basin towards the Cathedral,"
b) I propose you site specific requirement number 4 "provision of a height limited underpass on Basin Road to allow removal of the level crossings on Stockbridge Road and Basin Road.
c) I propose the removal of paragraph 7

Policy AL6; Land South -West of Chichester (Apuldram and Donnington Parishes.
I support this new policy and its land allocation. There should be allocation on this Land for relocating the Bus Garage and Royal Mail Postal Distribution Depot to allow the early freeing up of the existing sites within the Southern Gateway Masterplan.

We welcome the opportunity to comment on the councils Local Plan. As a local residents association situated at the northern extremities of the Chichester Settlement area we feel that we should comment on the items that affect our locality rather than discussing other residential development areas.

We should firstly congratulate the CDC officers on producing an excellent and comprehensive review. We support virtually all the policies that affect our area. We were naturally disappointed that such a large development is to be built immediately to the west of our community at White House Farm but are heartened by the statements assuring the no development occurs to the north of the B2178. Whilst we welcome the local amenities mentioned and also some business uses, we would also welcome a provision for a health centre as Chichester is crying out for more doctor surgery capacity. Although there is provision in the plan for traffic calming measures in Parklands we would also like to see in the document a sentence on CDC desire to limit the impact of that development on the country lanes to the north of the B2178. There was an intention in the planning agreement to partially close Brandy Hole Lane which does not get mentioned.

With regards to Policy S16 development within the vicinity of Goodwood motor circuit and airfield we believe that the 400m buffer should be maintained from now onwards, without exception. We recognise that some new development may have encroached into the buffer and that is unfortunate, but planning permission has already been granted for that development. I understand that some of the Summersdale area is also within the 400m buffer zone. However, having been involved with the SRA for many years the noise from the motor circuit and the overflying of aircrafts continues to be a perennial problem for our members. We strongly support the motor circuit as we appreciate the enjoyment a lot of local people get from visiting the events and also the benefits it brings to the local economy. It is for those reasons that the 400m buffer zone must be protected. There is a danger that if encroachment occurs those residents may also start complaining about the activities at Goodwood, somuchso that the activities cease and the land is sold off for yet more housing, which would be a great shame.

Policy S13 whilst is further afield we do strongly support protecting the views of the cathedral. Regardless of any religious persuasion it is a beautiful building and the views of it are worth protecting. The building was designed to stand out and to sit visibly within its surroundings. Those views have been protected for many hundreds of years and should be protected into the future.

Policy S14 Chichester City Transport Strategy.

We welcome the concept of improving the A27 at grade rather than as grade separated monoliths. The transport technology is changing so rapidly that there may come a time, in the not too distant future, that the way transport currently operates is out moded. The growth of electric cars seems to be the accepted way forward which could greatly reduce emissions. It is likely, as a result of the health problems that seem to be resulting from car borne pollution that the government may act to accelerate the reduction in pollutants. An example of this may be re-introducing car buy back schemes. Autonomous vehicle technology may result in additional capacity being squeezed out of the existing infrastructure and therefore negate the need for large scale A27 works other than those detailed in the plan. None of us has a crystal ball where we can look to see what the future will be like. It is important to plan for what is likely to come about as a result of local development contained in the plan rather than looking too far into the future regarding the need to accommodate regional changes to transport patterns as we believe they are too much in flux.

A number of southern gateway supporters call for an underpass or bridge over the railway crossings. This is a detrimental solution to the queuing problems and should be resisted. It is likely only to move the queues elsewhere and result in an ugly structure that creates severance of communities. Chichester currently enjoys at grade solutions to transport problems in the central area and that should be maintained into the future.

The comment on CDCs willingness to revisit park and ride if the parking level reach a certain occupancy is welcomed but it is an expensive option. Hopefully the parking management strategy for Chichester will push back the day when that is required.

Policy S23 Transport and Accessibility

The SRA welcomes the additional policy however, we feel that the construction of the Stockbridge relief road is likely to be unnecessary because the proposals for the A27 works together with the changes in vehicle use is likely to make that redundant before it is constructed. That proposal has been mentioned for the past 30 years. It was not necessary then and it is not necessary now.


Lastly, we notice and greatly appreciate that CDC has gone out of its way to try to protect many things that make Chichester such a pleasant place to live. Protecting the green spaces is particularly important as is maintaining the vitality and viability not only of Chichester as a regional centre but also of the small parades of shops and services that are vital to many residents young and old. Protecting these will also help to reduce the need for travel. It is important that businesses thrive in the area so that there are jobs for people moving into the area as that creates economic independence. The plan has protected and allocated space for that. We feel that this plan gives officers a document that will help them protect our environment for the enjoyment of future generations. Hopefully actions will follow the good words.

West Sussex County Council Officer Level Response
Introduction
The Chichester Local Plan Review Preferred Approach sets out how the future development in the District will be shaped, excluding the area within the South Downs National Park, up to 2035. It includes the overall development strategy as well as relevant strategic policies to meet the future needs of the area and development management policies to help guide development over the plan period. The Local Plan helps to:
* choose where the development goes;
* protect the character and beauty of the area;
* provide job and housing opportunities so that children can continue to work and live locally;
* support and help to boost the local economy;
* help residents to maintain healthy and active lifestyles; and,
* make sure that there is adequate services, travel options and community facilities.

The Chichester Local Plan was adopted in July 2015. At that time, the Local Plan was approved, but the Government Inspector said that it had to be reviewed again within five years, to make sure that sufficient housing was planned to meet the needs of the area.

The first part of the review process was carried out in June 2017 with an Issues and Options consultation, in which comments were invited regarding the overall development strategy and possible development locations. The Local Plan Review: Preferred Approach is the second stage of the process. It sets out the proposed development strategy and policies for the area to meet future needs.


West Sussex County Council Officer Level Comments
This note sets out West Sussex County Council's (WSCC) officer response to the consultation on the draft Chichester Local Plan Review Preferred Approach. It highlights key issues and suggested changes to which Chichester District Council (CDC) is requested to give consideration. We will continue to work with CDC in preparation of the Local Plan Review and the Infrastructure Delivery Plan regarding WSCC service requirements in order to mitigate planned development.


Minerals and Waste
A steady and adequate supply of minerals and the achievement of sustainable waste management can help to achieve a District or Borough Council's goals in relation to the economy, housing, transport, communications, strategic infrastructure and the environment. Therefore, District and Borough Local Plans should recognise the importance of minerals and waste issues as relevant to the scope of their overall strategies.

We welcome the reference to the adopted Minerals and Waste Local Plans and safeguarding in the document and the requirements in policies where a site is located within a minerals safeguarding area, or near to a safeguarded waste site. There are some missing references to safeguarding of minerals and waste sites for some of the proposed allocations, set out below and request that these references are added. It is also requested that 'Joint' is added into the references for the Joint Minerals Local Plan through the document.

Policy W23 of the Waste Local Plan applies to all Districts & Boroughs, regarding waste management within development and should be referenced in the Chichester Local Plan Review.

AL3 East of Chichester
The site is to the north of the Fuel Depot site allocation in the Waste Local Plan (Policy W10) for a built waste facility as part of a comprehensive redevelopment of the site (including complimentary non-waste uses). The East of Chichester allocation is the land to the north, bisected by the railway line, of the Fuel Depot. Reference should be made to giving consideration to the allocation, and therefore its safeguarding.

AL4 Westhampnett/North East Chichester
Reference should be made to minerals safeguarding, for consistency with other allocations, as within the sharp sand and gravel safeguarding area.

AL5 Southern Gateway
Reference should be made to the mineral infrastructure safeguarding policy M10 as within 200m of the Chichester Railhead.

AL6 South-West of Chichester
Reference should be made to the mineral infrastructure safeguarding policy M10 as within 300m of the Chichester Railhead.

AL7 Highgrove Farm Bosham
Remove reference to minerals safeguarding as the site is not within the safeguarding or consultation area.

AL12 Park Farm Selsey
Reference should be made to minerals safeguarding as site is within the sharp sand and gravel safeguarding area.

Neighbourhood plan allocations
Sites are yet to be allocated though neighbourhood plans. It is considered that the Joint Minerals Local Plan and Waste Local Plan are referenced, particularly with regards to safeguarding policies (M9, M10 and W2) and these documents and policies are given detailed consideration when allocating sites. Development at, adjacent or proximal to existing waste or mineral sites / infrastructure should be the subject to consultation with WSCC.


Connectivity and Sustainable Travel
The County council has worked with the District Council on the preparation of the transport evidence base study undertaken by Peter Brett Associates for the District Council. The recommended transport mitigation strategy, as assessed using the Chichester Area Transport Model has been demonstrated to be capable in principle to prevent the development from resulting in severe residual cumulative impacts on the highways and transport network. However, the recommended strategy has several risks to deliverability and acceptability associated with it, which require further work to be undertaken to demonstrate that the strategy can be implemented in its current form to provide the forecasted mitigation to travel conditions.

There are three locations where new highway alignments are proposed outside of existing highways boundaries. Two of these may include significant earthworks or structures to be delivered, being Stockbridge Link Road and Terminus Road diversion. The cost of the mitigation strategy exceeds a figure which could reasonably be supported by the value of the proposed development developer contributions alone, therefore the delivery of the strategy will depend upon securing of external grant funding to top up developer contributions. WSCC will work with the District Council in supporting and or applying for funding, the District Council needing to secure Highways England to support funding applications for A27 improvements. The proposed junction designs for the A27 Stockbridge and Whyke roundabouts include bans to well used right turn movements off the Chichester A27 bypass which result in significant forecast changes to traffic flows on local roads in the south of Chichester and on the Manhood Peninsular.

There is a need to ensure the land outside the highway boundary is available and the plan should set out how this land will be acquired to deliver the measures, it may be that a commitment to use, if required, and therefore reference to CPO be made in the policy.

Funding for the mitigation strategy is uncertain. It is considered that the Plan should set out how it will deal with this uncertainty. This could include trigger points in the monitoring framework to trigger a change of approach or alternative options to deliver the required development.

These factors mean that feasibility work is necessary to be undertaken prior to Plan submission, to reduce as far as practicable risks to costs, land take, impacts and deliverability of the proposed transport strategy in order to show that the strategy can be implemented within the plan period and that the funding strategy will be sufficient to meet the design requirements. In particular the following will need to be addressed:

* Statutory undertakers equipment under the roads junctions to be impacted.
* Extent of earthworks required to create a vertical and horizontal alignment compliant with design standards. Design audit to identify any required departures from standard.
* Designing for drainage and flooding issues, including compliance with the WSCC LLFA Policy for the Management of Surface Water, November 2018.
* Designs for structures to cross watercourses - Stockbridge Link Road
* Design should include suitable provision for rights of way and footway crossings
* Scoping for whether and at what level further Environmental Impact Assessment will be required.
* Stage 1 Road safety Audit, designers response report and resulting amendments to designs.
* Land take required after feasibility level designs have been developed and availability of required land.
* Wophams Lane - impacts of forecast changes to flow patterns to take B2201 southbound traffic on requirements for highway width, alignment, footway provision and junctions with A286 Birdham Road and B2201 Selsey Road; design solution required.
* Quarry Lane, Kingsham Avenue /Road, Terminus Road; impacts of forecast flow changes on highway users, residential and commercial frontagers and measures to manage through traffic whilst maintaining local access

Sustainable transport measures will also be required to mitigate planned development. These will be identified through more detailed assessments of sites including pre-application consideration. Funding will need to be identified through development and other sources as well in some cases.

Public Rights of Way
There is support for the Local Plan Review's approach to Public Rights Of Way (PROW), not just for the potential to impact on existing public off-road access but also the opportunity it brings to enhance this access for the benefit of future residents, communities and visitors. PROW deliver benefits for personal health and wellbeing; sustainable transport; reduction of air pollution and road congestion; are able to support local economies; and they connect communities.
WSCC PROW welcomes several aspects of the Vision statement, which give support to the protection and enhancement of the PROW network, and provision of safe and convenient off-road access opportunities for residents and visitors:

* Pursue a healthy lifestyle and benefit from a sense of well-being supported by good access to education, health, leisure, open space and nature, sports and other essential facilities;
* Live in sustainable neighbourhoods supported by necessary infrastructure and facilities;
* Move around safely and conveniently with opportunities to choose alternatives to car travel.

The Local Plan Strategic Objectives offer further support to enhance off-road access, particularly to 'Encourage healthy and active lifestyles for all, developing accessible health and leisure facilities and linked green spaces'. However, the objective to 'Achieve a sustainable and integrated transport system through improved cycling networks and links to public transport' should recognise walking also as an important mode for many people; some strategic enhancements will significantly improve walkers' safety and convenience.

It is considered that West of Chichester the A259 could act as a corridor for increased volumes of non-motorised access, particularly cycling. Improvement of the existing on-road facility and development of a various 'feeder' routes to connect with the many settlements, perhaps using quiet lanes in places, would encourage cycling particularly to be a natural alternative to vehicle use. Policy S18: Integrated Coastal Zone Management for the Manhood Peninsula, gives regard to such an ambition in stating it will 'Improve infrastructure to support sustainable modes of transport, especially cycle ways, bridleways and footpaths, including the National Coastal Footpath'.

The National Planning Policy Framework (NPPF) Open Space and Recreation, para 97b) states:
the loss resulting from the proposed development would be replaced by equivalent or better provision in terms of quantity and quality in a suitable location.
The NPPF para 98 also states:
Planning policies and decisions should protect and enhance public rights of way and access, including taking opportunities to provide better facilities for users, for example by adding links to existing rights of way networks including National Trails.'
There is support for Policy S20: Design, that recognises these requirements in stating development 'is well connected to provide safe and convenient ease of movement by all users, prioritising pedestrian and cycle movements both within the scheme and neighbouring areas and ensuring that the needs of vehicular traffic does not dominate at the expense of other modes of transport, or undermine the resulting quality of places' and 'incorporates and/or links to high quality Green Infrastructure and landscaping to enhance biodiversity and meet recreational needs, including public rights of way'.


Education
As the local education authority, WSCC has the statutory duty to ensure that there is a sufficient supply of suitable school places to meet statutory requirements for early years, primary, secondary and sixth form provision (including up to age 25 for those with special educational needs and/or disabilities). Education infrastructure, or contributions to provide infrastructure, will be required in order to mitigate proposed development. We will continue to work with CDC in preparation of the Local Plan Review and the Infrastructure Delivery Plan regarding education and other service requirements in order to mitigate planned development.

The table below sets out the primary, secondary school and sixth form requirements to mitigate proposed development. SEE ATTACHMENT FOR TABLE

AL1 Land West of Chichester

It should be noted that phase one of this development will provide the primary school with the core of the building being built to the specification for a 2 form entry (FE) school and 1FE teaching accommodation. Phase 2 as per 6.10 on page 93 should include expansion of the primary school for the further 1FE of teaching accommodation.

AL2 Land at Shopwhyke (Oving Parish)

No update to original response for this allocation is required.

AL3 Land East of Chichester - previously South of Shopwhyke

At the current time pupil place planning indicates that there is insufficient space within the primary schools that serve this proposed development. Further capacity would be required to accommodate the development. Land for a 1 FE expandable to 2FE and pro rata share of the build costs would be required.

If numbers were to increase on the east side of the city, education provision will need to be reviewed, potentially a further 1FE may be required including land provision, this could be in the form of an expansion or a new school being built capable of expansion to 3FE.

At the current time pupil place planning indicates that there would be expansion capacity to accommodate the child product from this proposed development for secondary aged pupils. Contributions would be required for expansion of secondary schools if feasible and required.

At the current time pupil place planning indicates that there would be expansion capacity to accommodate the child product from this proposed development for sixth form pupils. Contributions would be required for expansion of the provision if feasible and required.

AL4 Land at Westhampnett / North East Chichester

The remaining 200 dwellings will impact on the education provision in the area, financial contributions towards expansion of existing or pro rata costs towards the expansion of the school within AL3.

At the current time pupil place planning indicates that there would be expansion capacity to accommodate the child product from this proposed development for secondary aged pupils. Contributions would be required for expansion of secondary schools if feasible and required.

At the current time pupil place planning indicates that there would be expansion capacity to accommodate the child product from this proposed development for sixth form pupils. Contributions would be required for expansion of the provision if feasible and required.

AL5 Southern Gateway

At the current time pupil place planning indicates that there would be sufficient space or expansion capacity to accommodate the child product from the strategic allocation of 350 dwellings in the Southern Gateway. However, consideration should be given to the cumulative impact of housing in the area Land South West of Chichester (AL6) to allocate land within the area for a 1FE expandable to 2FE primary school. Pro rata financial contributions towards the build costs would be sought from developers to mitigate their impact.

At the current time pupil place planning indicates that there would be expansion capacity to accommodate the child product from this proposed development for secondary aged pupils. Contributions would be required for expansion of secondary schools if feasible and required.

At the current time pupil place planning indicates that there would be expansion capacity to accommodate the child product from this proposed development for sixth form pupils. Contributions would be required for expansion of the provision if feasible and required.

AL6 Land South West of Chichester (Apuldram & Donnington Parishes)

It should be noted that the primary education provision in this area is either in Chichester City Centre which means crossing the main A27 or by travelling south towards the peninsula. Consideration should be given to the cumulative impact of further housing in the area along with the Southern Gateway allocation (AL5) to allocate land within the strategic allocation site for a 1FE expandable to 2FE primary school. Pro rata financial contributions towards the build costs would be sought from developers to mitigate their impact.

At the current time pupil place planning indicates that there would be expansion capacity to accommodate the child product from this proposed development for secondary aged pupils. Contributions would be required for expansion of secondary schools if feasible and required.

At the current time pupil place planning indicates that there would be expansion capacity to accommodate the child product from this proposed development for sixth form pupils. Contributions would be required for expansion of the provision if feasible and required.

AL7 Bosham

The current primary provision serving the area is at capacity, expansion of the school on its existing site is not possible. As part of the strategic allocation, it is proposed that land for a 2FE primary school be provided. The strategic allocation of 250 dwellings in isolation does not require a new school to be built. Certainty over the land allocation and sufficient funding will be key drivers in realising this proposal.

AL7, AL10 and AL13 are all within the same school planning area, the cumulative total of the strategic allocations brings forward a requirement for c3 forms of entry additional school places. The Local Plan, as currently drafted, indicates an oversupply of school places which could affect the viability of all the schools in the planning area.

Expansion of the secondary school may be possible. Contributions would be required for expansion of secondary schools if feasible and required.

AL9 Fishbourne

The primary school serving the area is currently at capacity, expansion of the school may be possible, feasibility / options appraisals would need to be undertaken.

At the current time pupil place planning indicates that there would be sufficient space or expansion capacity to accommodate the child product from this proposed development for secondary aged pupils. Contributions would be required for expansion of primary and secondary schools and sixth form if feasible and required.

AL8 East Wittering

At the current time pupil place planning indicates that there would be sufficient space or expansion capacity to accommodate the child product from this proposed development.

Contributions would be required for expansion of primary and secondary schools if feasible and required.

AL10 Chidham and Hambrook area

The current primary provision serving the area is at capacity, expansion of the school on its existing site is not possible. As part of the strategic allocation, it is proposed that land for a 2FE primary school be provided. Certainty over the land allocation and sufficient funding will be key drivers in realising this proposal.

AL7, AL10 and AL13 are all within the same school planning area, the cumulative total of the strategic allocations brings forward a requirement for c3 forms of entry additional school places. The Local Plan, as currently drafted, indicates an oversupply of school places which could affect the viability of all the schools in the planning area.

Expansion of the secondary school may be possible. Contributions would be required for expansion of secondary schools if feasible and required.

AL11 Hunston

Any development within this area cannot currently be accommodated in the existing primary school at North Mundham. Further capacity would be required to accommodate the development, CDC will need to work with WSCC to determine how additional capacity in the area could be accommodated if land is to be allocated.

At the current time pupil place planning indicates that there would be sufficient space or expansion capacity to accommodate the child product from this proposed development for secondary aged pupils. Contributions would be required for expansion of secondary schools and sixth form if feasible and required.

AL12 Selsey

Further capacity would be required to accommodate the development. Contributions (and possibly land if required) would be sought to meet the pupil product from the development in the most appropriate form once this can be clarified.

At the current time pupil place planning indicates that there would be sufficient space to accommodate the child product from this proposed development for secondary aged pupils. Contributions would be required for expansion of secondary schools if feasible and required.

AL13 Southbourne

At the current time pupil place planning indicates that there is insufficient space within the primary schools that serve this proposed development. Further capacity would be required to accommodate the development. Land for a 2form entry expandable to 3FE primary school and pro rata share of the build costs would be required.

AL7, AL10 and AL13 are all within the same school planning area, the cumulative total of the strategic allocations brings forward a requirement for c3 forms of entry additional school places. The Local Plan, as currently drafted, indicates an oversupply of school places which could affect the viability of all the schools in the planning area.

Expansion of the secondary school may be possible. Contributions would be required for expansion of secondary schools if feasible and required.

AL14 Tangmere

The current allocation of 1,300 dwellings will bring forward the requirement for land for a 1FE expandable to 2FE and financial contributions would be sought to meet the pupil product from the development in the most appropriate form once this can be clarified.

At the current time pupil place planning indicates that there would be sufficient space or expansion capacity to accommodate the child product from this proposed development for secondary aged pupils. Contributions would be required for expansion of secondary schools and sixth form if feasible and required.

Footnote: - if all of the proposed sites were to come forward the secondary school and sixth form provision would be full in the Chichester Planning Area. Expansion of the secondary schools in the Chichester Planning Area to cater for the increased demand would need to be sought from the academy sponsors, where appropriate and the Local Authority.


Lead Local Flood Authority
The Lead Local Flood Authority (LLFA) is concerned about the approach being taken with regard to ensuring potential wastewater treatment for proposed new sustainable development.

Paragraph 8 of the NPPF states:
8. Achieving sustainable development means that the planning system has three overarching objectives, which are interdependent and need to be pursued in mutually supportive ways (so that opportunities can be taken to secure net gains across each of the different objectives):

a) An economic objective - to help build a strong, responsive and competitive
economy, by ensuring that sufficient land of the right types is available in the
right places and at the right time to support growth, innovation and improved
productivity; and by identifying and coordinating the provision of infrastructure;

Paragraph 20 of the NPPF states:
20. Strategic policies should set out an overall strategy for the pattern, scale and quality of development, and make sufficient provision for:
a) housing (including affordable housing), employment, retail, leisure and other commercial development;
b) infrastructure for transport, telecommunications, security, waste management, water supply, wastewater, flood risk and coastal change management, and the provision of minerals and energy (including heat);

In the LLFAs view, the Local Plan Review is not setting out an overall strategy for the pattern, scale and quality of development in relation to arrangements for wastewater management. The LLFA considers that CDC needs to go further in incorporating within the Local Plan Review how this provision is being made.


Additional Policy Comments

Policy S12: Infrastructure Provision
Support the requirement that all development must provide or fund new infrastructure, facilities and services required, both on and off-site (including full fibre communications infrastructure) as a consequence of the proposal. The explicit reference to full fibre communications infrastructure is supported as this will provide gigabit-capable and future-proofed services to all development, existing and new. The reference to provision of facilities and services on and off-site is also supported as in the case of broadband for example, all development will be adequately equipped with the necessary infrastructure installed for the purposes of connecting to full fibre gigabit-capable broadband services. This policy supports the County Council's aim for increased digital infrastructure that will provide for gigabit-capable broadband and future technologies such as 5G.

Support the reference to safeguarding educational facilities under section 3 of the policy.

The policy includes the requirement to 'Facilitate accessibility to facilities and services by a range of transport modes'. PROW can offer vital access means for walkers and cyclists, such as for employment land use (e.g. commuting by bicycle) and in support of the high street, both for employees and customers. IT is considered that this Policy, also Policy S13: Chichester City Development Principles, should aim to encourage such access to be the natural and preferred modes of access, thereby helping achieve the benefits previously described. It is noted Policy S14: Chichester City Transport Strategy, does acknowledge cycling and walking and lends support to their improvement.

The supporting text, paragraph 4.81 makes reference to the Strategic Infrastructure Package (SIP). It is requested that this wording is removed and replaced with West Sussex County Council identifies service infrastructure requirements necessary to support new and existing communities, where strategic development and growth is proposed in Local Plans. These are required to deliver the County Council's statutory responsibilities, strategic objectives and current policy and feed into the preparation of the Infrastructure Delivery Plan.


Policy S13: Chichester City Development Principles
This policy, like policy S12, it is considered should aim to encourage such access to be the natural and preferred modes of access, thereby helping achieve the benefits previously described. It is noted Policy S14: Chichester City Transport Strategy, does acknowledge cycling and walking and lends support to their improvement.


Policy S23: Transport and Accessibility
The policy and supporting text paragraphs 5.15 - 5.33 refer to Transport Infrastructure. Understandably much consideration is given to the A27 around Chichester; however, in addition to seeking new infrastructure from new development, it is recommended support in principle is given to maximising the value of existing infrastructure so as to facilitate off-road user modes accessing either side of the A27.


S24: Countryside
Supporting text paragraphs 5.34 - 5.43, acknowledges 'it is necessary to provide for the social and economic needs of small rural communities, and enable those who manage, live and work in the countryside to continue to do so'. It is recognised in para 7.205, supporting text to policy SM35 Equestrian Development, the high numbers of liveried and stabled horses. A considerable network of businesses are supported by such a high equine population, and in addition to financial value within the local community there is considerable benefit in terms of health and wellbeing of individuals. It is suggested that Policy S24: Countryside, could recognise this specifically.


S27: Flood Risk Management
Supporting text paragraph 5.54, requested amendments underlined - as a consequence of the rise in sea levels and storm surges, parts of the plan area will be at increased risk from coastal erosion, groundwater, fluvial and/or tidal flooding. Hard defences may not be possible to maintain in the long term, therefore development needs to be strongly restricted in areas at risk to flooding and erosion, whilst ensuring that existing towns and villages are protected by sustainable means that make space for water in suitable areas. Development must take account of the policies of the relevant shoreline management plan

Supporting text paragraph 5.58, requested amendments underlined - Built development can lead to increased surface water run-off; therefore new
development is encouraged to incorporate mitigation techniques in its design, such as permeable surfaces and Sustainable Drainage Systems (SuDS). Where appropriate, SuDS should be used as part of the linked green infrastructure network to provide multiple functions and benefits to landscape quality, recreation and biodiversity. This can be achieved through habitat creation, new open spaces and good design. SuDS should be designed to help cope with intense rainfall events and to overcome any deterioration in water quality status. In determining the suitability of SuDS for individual development sites, developers should refer to guidance published by the Lead Local Flood Authority (LLFA): West Sussex LLFA Policy for the Management of Surface Water: https://www.westsussex.gov.uk/media/12230/ws_llfa_policy_for_management_of_surface_water.pdf and, if necessary, seek further advice from the Lead Local Flood Authority LLFA.

S27 policy text requested amendments underlined for section 1 - a. through a sequential approach, taking into consideration all forms of flooding, it is located in the lowest appropriate flood risk location in accordance with the NPPF and the Chichester Strategic Flood Risk Assessment (SFRA); and

S27 policy text requested amendments underlined for section 2. Sustainable drainage systems (SuDS) will be required on major developments (10 or more dwellings or equivalent) and encouraged for smaller schemes. SUDS should be designed into the landscape of all new development and should be included as part of a District wide approach to improve water quality and provide flood mitigation. A site-specific Flood Risk Assessment will be required for sites within or adjacent to areas at risk of surface water flooding as identified in the SFRA. There should be no increase in either the volume or rate of surface water runoff leaving the site.

S27 policy text requested additional bullet point as number 4 - Clear management arrangements and funding for their ongoing maintenance over the lifetime of the development should be proposed. Planning conditions and / or obligations will be used to secure these arrangements.

S27 policy text requested amendments underlined for section 2, but would be section 5 - Development should not result in any property or highway, on or off site, being at greater risk of flooding than the 1 in 100 year storm return period, including an allowance for climate change.


Policy S29: Green Infrastructure
The Green Infrastructure policy is welcomed, including provision of new Green Infrastructure as an integral part of the development at Strategic Development Locations. It is recommended that measures are put in place to secure the long term management of such Green Infrastructure.


Policy S30: Strategic Wildlife Corridors
The identification of Strategic Wildlife Corridors and inclusion of a policy to safeguard them from development is welcomed. It is recommended that CDC promotes positive conservation management within these corridors to maximise their contribution to maintaining and enhancing biodiversity. As stated in Section 5.66, 'These corridors do not stop at the plan area boundaries.' Thus, it is recommended that CDC works in partnership with Chichester Harbour Conservancy and The South Downs National Park Authority to ensure that these Strategic Wildlife Corridors continue to provide effective corridors and connectivity across the wider landscape.

Section 5.66 refers to four Strategic Wildlife Corridors connecting Chichester Harbour with the South Downs National Park but it is noted that there is no mention of the Strategic Wildlife Corridors to the east of Chichester which connect Pagham Harbour with the South Downs National Park (as seen in Policy Map S30b). It is also noted that the maps referred to in Section 5.66, Maps 5.1 & 5.2 are missing.

WSCC and CDC promoted a Mitigated Northern Route for the A27 at Chichester as the preferred option, subject to the inclusion of important mitigation measures that are needed to make the scheme acceptable in environmental terms and the 'full southern route' as a reasonable alternative. Both routes could impact on the identified Strategic Wildlife Corridors. As currently drafted, Policy S30 would seem to prevent a mitigated northern route from coming forward in the future. Therefore, the District Council should consider whether the policy is overly restrictive (for example should it refer to 'significant adverse impacts' or 'unacceptable adverse impacts'?) and how it would be applied if a northern route for A27 were to come forward in the future.


Policy S31: Wastewater Management and Water Quality
S27 policy text requested amendments underlined for section 3, this - Where appropriate, development should contribute to the delivery of identified actions to deliver infiltration reduction across the catchment. Where appropriate development should contribute to the delivery of identified actions to deliver a reduction in the level of infiltration of groundwater into the sewer system.


Policy AL1: Land West of Chichester
AL1 policy text requested additional bullet point as number 8 - Increase capacity to attenuate surface water on site, thereby reducing the discharge flows off the site below current rates and reducing the risk of flooding to residential areas downstream.

AL1 policy text requested additional bullet point under 15 as 15 b- Provide mitigation for any loss of watercourse habitat resulting from culverting for highway provision in the development;

AL1 policy text in supporting 'improved cycle and pedestrian routes linking the site with the city, Fishbourne and the South Downs National Park', a new key link for cycling will be to Salthill Road, thereby enabling cyclists to benefit from the existing bridge crossing of the A27 for journeys to and from the west.


AL2: Land at Shopwyke (Oving Parish)
The policy acknowledges need 'for foot/cycle bridge across A27 to Coach Road'. There is also need for equestrian users to cross the A27 and WSCC PROW has received several enquiries seeking support for such infrastructure. Consideration could be given to the proposed bridge providing for all three modes.


AL3: East of Chichester (Oving Parish)
AL3 supporting text requested amendments underlined for paragraph 6.22 - The site is identified for 600 dwellings, however, there may be potential to deliver a large strategic development of 1000 dwellings, subject to further evidence, including the testing of additional growth on the local highway network and capacity of the site to provide flood risk attenuation for the increased housing density. The site should be master planned as a whole, and delivered through a phased development over a ten year period. Although the site is physically separated from the city by the A27 Chichester Bypass, the development should form a planned extension to the city, forming a new neighbourhood. This will involve opportunities to provide new facilities to serve the wider local community with good off-site access, particularly by walking and cycling to existing local facilities and facilities in the city.

AL3 policy requires exploring integrated green infrastructure with other strategic sites to the north east of the city, Tangmere and the wider countryside. It is considered that future residents will have expectations for provision of safe and convenient links towards Oving and also across the railway to link to the A259 cycle path and PROW south of the A259. It is considered that the policy should be strengthened to ensure such provision.


Policy AL4: Land at Westhampnett/North East Chichester
AL4 policy text requested amendments underlined for section 3 - Open space and green infrastructure, including a linear greenspace with public access along the Lavant Valley.

Taking into account the site-specific requirements, proposals for the site should satisfy the following requirements:

Policy AL4 policy, it is welcomed that 'provision should be made for green links to the South Downs National Park and Chichester City.' Safe and convenient walking and cycling to Lavant, from where people will access the South Downs, will provide for sustainable transport use.


Policy AL5 Southern Gateway
AL5 supporting text requested amendments underlined for paragraph 6.38 - The area has been identified as suitable for comprehensive regeneration with the aim being to make it a more attractive and welcoming gateway for the city, providing new housing, business and retail space and leisure and tourism facilities. Opportunities will be identified to improve transport links with a focus on cycling, walking and public transport and the removal of non-essential traffic from the area. There is also scope for significant public space enhancements and new landscaping incorporating blue / green infrastructure delivering multi-functional benefits.

AL5 policy text requested amendments underlined for section 5 - Provision of open space that:
* Is in accordance with Policy DM34, including retention of the existing playing pitch unless suitable re-provision is provided;
* Reinforces / enhances green and blue infrastructure consistent with Policy S29 and fully exploits the opportunities for sustainable drainage.


AL5 policy text requested amendments underlined for section 8 - Provision of both a surface and waste water management plan which demonstrates no net increase in flow to Apuldram Waste Water Treatment Works would result from this development, unless suitable alternative provision is agreed;


Policy AL6: Land South-West of Chichester (Apuldram and Donnington Parishes)
The LLFA has concerns regarding the lack of reference to flood risk constraints of the site in Policy AL6. There is reference to flood risk in paragraph 6.47. However, the policy itself makes no reference to these constraints.
The constraints arise from a combination of the following:

* Current tidal /fluvial flood risk extending from Chichester harbour to the west and up the River Lavant floodplain; (Map 1)
* Future tidal /fluvial flood risk associated with climate change; (Map 1)
* Constraints on infiltration of surface water run off because of high seasonal groundwater levels (<0.025m below the surface) (Map 2); and
* Constraints on gravity outfalls because of the low relief and long-term reduction in tidal window for discharge.

The above limits the options for how the site can be effectively drained without a step change from typically employed methods to embrace more innovative and currently expensive options e.g. blue roofs and rainwater harvesting.

The LLFA recommends that the policy sets out both the above constraints and the type of innovative drainage that will be required to achieve the development objectives for the site.



Key: Projected medium projection extent of SLR based upon 4m contour

AL6 extent

Current Flood Zone 3 extent.

Current Areas of high (1:30) surface water flood risk

Map 1 Existing and projected Tidal and surface water flood risk for AL6.

Consistent with paragraph 3.2 of the SFRA, given the high risk of flooding both now and into the future for this site, it is recommended that CDC gives consideration to the climate change maps to understand how the flood zones are predicted to change over the lifetime of the development.


Key:
AL6 boundary.

Groundwater levels are either at very near (within 0.025m of) the ground surface.

Groundwater levels are between 0.025m and 0.5m below the ground surface

Map 2 Groundwater flood risk JBA

Policy AL6 WSCC PROW considers 'necessary highway improvements to adequately mitigate the likely impacts on the highway network' to include a bridge crossing of the A27 for convenient walking and cycling access to the Terminus Road industrial estate and the city. There is an existing public footpath but, as this crosses the A27 at-grade, this will not provide the safest facility and not encourage people to minimise use of vehicles for local access. Provision of a bridge and access through the site could also establish a valuable link to the popular Salterns Way walking and cycle path. An additional link to Salterns Way should also be provided off the A286 for the benefit of Stockbridge residents as a safer alternative to the A286.


AL 7 Highgrove Farm, Bosham
The LLFA notes that the above site has the potential for a moderate risk of groundwater flooding. It is likely that this is perched groundwater draining from higher ground / springs to the north that lies in the superficial mixed sediments underlain by Lambeth Clay.


Policy AL8: East Wittering Parish
Due to no information on where housing is going to be located so the LLFA is not in a position to comment on proposed housing allocation sites at this stage.

The policy requires 'Opportunities ... for the expansion and provision of green infrastructure into the wider countryside including between settlements and facilities'. Existing and future residents and the local visitor economy would benefit by delivery of an off-road route for walkers, cyclists and horse riders to and from the Medmerry development and towards Selsey. It is considered that Policy AL8 should aim to deliver this enhancement specifically.


Policy AL9: Fishbourne Parish
Due to no information on where housing is going to be located so the LLFA is not in a position to comment on proposed housing allocation sites at this stage.

It is considered that off-road cycling links to land West of Chichester (off Salthill Road) and to Bosham (off Park Lane) would benefit this community with enhanced sustainable connectivity.


Policy AL10: Chidham and Hambrook Parish
Due to no information on where housing is going to be located so the LLFA is not in a position to comment on proposed housing allocation sites at this stage.

The policy requires 'opportunities' to develop green infrastructure and links to other communities. An opportunity, in conjunction with Highways England, exists to maximise the value of existing infrastructure by creating a new bridleway (for walkers, cyclists and horse riders) on a path using an existing A27 overbridge.


Policy AL11: Hunston Parish
Due to no information on where housing is going to be located so the LLFA is not in a position to comment on proposed housing allocation sites at this stage.

The village is already well connected for walkers to access the surrounding countryside but there are presently no local cycling or horse riding facilities on the PROW network. A bridleway link to South Mundham (with the potential for future cycle links to Pagham and towards Bognor Regis) and to Sidlesham via the golf course and Brimfast Lane would provide residents and visitors with improved access to the countryside and services.


Policy AL12: Land North of Park Farm, Selsey
It is unclear why the policy map shows the proposed strategic allocation lies outside of the Neighbourhood Plan proposed settlement boundary. Some explanation for this anomaly would be helpful in the text.


Groundwater flood risk as depicted by JBA mapping (Brown = seasonal groundwater level lies between 0.025 and 0.5m below the surface).

The principle concern that the LLFA wishes to highlight is the need to ensure that the necessary foul sewerage infrastructure to support development is in place. It is the LLFA understanding that the Siddlesham WWTW experiences capacity issues currently, in part exacerbated by groundwater infiltration. While Policy AL12 states: Development proposals will need to demonstrate that sufficient capacity will be available within the sewer network, including waste water treatment works, to accommodate the proposed development in accordance with Policy S31.

The policy proposes only to provide 'pedestrian links between the site and new development south of Park Lane'. It is considered that cycling links should also be provided.


Policy DM8: Transport, Accessibility and Parking
The PROW network can provide vital means for communities to interact and encourage sustainable local access. The policy requirement to create 'links between new development and existing pedestrian, cycle and public transport networks' is welcomed. However, establishing links into surrounding existing development should not be overlooked also - the greater the permeability, the greater the use.


Policy DM10: New Employment Sites
Whilst mentioned earlier in the Plan in respect of a number of specific sites, this policy should specifically aim to provide, as a matter of course, suitable walking and cycling infrastructure to encourage local sustainable access. This infrastructure may need to extend outside a site boundary so as to provide safe and convenient connection to existing infrastructure. This principle should apply also to Policy DM13: Built Tourist and Leisure Development and Policy DM14: Caravan and Camping Sites.


Policy DM32: Green Infrastructure
Whilst it is recognised the policy proposes support subject to not 'dissect[ing] ... the linear network of cycle ways, public rights of way, bridleways ...', the policy could lend support to establishing new routes as part of the Green Infrastructure network itself.


Policy DM35: Equestrian Development
It is appreciated why the Plan would wish to require future equine development to be 'well related to or has improved links to the existing bridleway network'. However, this will add to the pressure of use on the existing bridleway network, which is not extensive outside of the South Downs, so will increase degradation of paths. Future developments must, therefore, accept to contribute in some way, acceptable to the local highway authority, to mitigate the additional impact to be created so all lawful users are not disadvantaged.


Policy DM29: Biodiversity
The measures to safeguard and enhance the biodiversity value of development sites are welcomed, including seeking net biodiversity gain.


Schedule of proposed changes to the policies map
S30a West of City Corridors -suggest title should be West of City Strategic Wildlife Corridors (to match S30b: East of City Strategic Wildlife Corridors. The Strategic Wildlife Corridors are depicted in different colour patterns on the two plans which is somewhat confusing.


Strategic Wildlife Corridors Local Plan Review Background Paper
Proposed Hermitage to Westbourne Strategic Wildlife Corridor
A large area depicted as Biodiversity Opportunity Area (BOA) in Fig. 1 (immediately to the south of the Rivers Ems & Meadows Local Wildlife Site, Westbourne) is in fact housing and forms part of the settlement of Westbourne. You should consider if this land should be included as having potential for biodiversity enhancement.


Glossary
Includes Sites of Nature Conservation Importance (SNCIs) but not Local Wildlife Sites (LWSs). SNCIs are now known as LWSs.

Paragraph 1.5 of the Local Plan Review states "This Plan seeks to balance the economic, social and environmental dimensions of sustainable development". "Balance" implies some gains and some losses. However, this does not reflect the four bullet points that follow this sentence.
In addition, Paragraph 8 of the National Planning Policy Framework explains that;
"Achieving sustainable development means that the planning system has three overarching objectives, which are interdependent and need to be pursued in mutually supportive ways (so that opportunities can be taken to secure net gains across each of the different objectives)".

We therefore suggest that "balance" is not the most appropriate word.

The three overarching objectives include; "c) an environmental objective - to contribute to protecting and enhancing our natural, built and historic environment......". We therefore welcome the fourth bullet point of paragraph 1.5; "Protecting and enhancing the unique and special qualities of our environment".

Reword the first sentence of paragraph 1.5 as; "This Plan seeks to deliver the economic, social and environmental dimensions of sustainable development in mutually supportive ways".

Paragraph 1.16 explains that the National Planning Policy Framework reiterates the importance of significantly boosting the supply of new dwellings, whilst ensuring provision for other development needs including economic growth.
Whilst not untrue, we consider that this does not fully represent the Government's objectives and policies as set out in the Framework and therefore gives the misleading impression that the Framework is only about housing supply and economic development.
In fact, the protection and enhancement of the natural, built and historic environment is also identified as important in the Framework e.g. in the environmental overarching objective for the planning system as set out in paragraphs 8, 11b)i and 20 d).
Reword the final sentence of paragraph 1.16 as:
"The importance of significantly boosting the supply of new dwellings is reiterated, whilst ensuring provision for other development needs including economic growth and protecting and enhancing the natural, built and historic environment".
Paragraph 31 of the National Planning Policy Framework requires "The preparation and review of all policies should be underpinned by relevant and up-to-date evidence". We previously expressed our concerns about the historic evidence base for the policy framework for the district when commenting on the Issues and Options stage of the Local Plan Review;
"We are aware of the Council's series of Conservation Area Character Appraisals, The Future Growth of Chichester Study and the Landscape Capacity Studies. However, the Council's "Supporting documents" webpage has no historic environment documents and we are not clear if the Council has other historic environment evidence e.g. is there an extensive urban survey of Chichester or other townscape or characterisation study ? Is there an urban archaeological database ? Is there a list of locally important heritage assets ? Has the Council undertaken a survey of grade II buildings at risk ?".
However, looking at the Council's Local Plan Review Preferred Approach Plan - Evidence Base - December 2018 webpage, the only specific historic environment evidence base document identified is the Chichester Historic Environment Strategy and Action Plan. Whilst we welcome the Strategy, we have previously expressed the view that we do not consider that it forms, by itself, an adequate historic environment evidence base for the Local Plan Review.
We are aware that the Council has a list of locally important buildings, but that Chichester was not covered by the West Sussex Extensive Historic Town Surveys - perhaps as it was thought a candidate for the more intensive approach of an Urban Archaeological Database (UAD). However, we are not aware that such a UAD exists, and whilst we are aware of the Council's Historic Environment Record (the availability of which accords with paragraph 187 of the National Planning Policy Framework), we do wonder if the archaeological evidence and significance of the city is fully understood and readily available. We suggested that the Historic Environment Strategy could set out actions to enhance understanding and management of the archaeological resource of the historic city and we would be pleased to discuss how we might be able to assist with this.
We will expect the Council to have an adequate, up-to-date and relevant historic environment evidence base and to demonstrate in the Pre-Submission Local Plan how that historic evidence base has informed and influenced the Plan's policies and site allocations.
The historic environment evidence base for the Local Plan Review should be set out on the Council's Evidence Base webpage. If there are indeed gaps in that evidence base, then these should be filled and that evidence taken on board in preparing the Pre-Submission Local Plan Review document.
Historic England welcomes and supports the reference to the historic environment of Chichester district, and the heritage assets therein, in paragraphs 2.27 and 2.28 as part of the positive strategy for the conservation and enjoyment of the historic environment required by paragraph 185 of the National Planning Policy Framework.

Historic England welcomes and supports, in principle, the identification of "Protect the area's valuable heritage and historic assets" as one of the challenges faced by the Plan.
However, the National Planning Policy Framework requires local plans to deliver an environmental overarching objective which includes "to contribute to conserving and enhancing our natural, built and historic environment" (paragraph 8 c)) and to include strategic policies to make sufficient provision for "conservation and enhancement of the natural, built and historic environment" (our underlining).
The Framework therefore requires local planning authorities, through their local plans, to do more than just conserve the historic environment i.e. to enhance it as well. This should be identified as a challenge (although it is also an opportunity).
Reword the last bullet point of paragraph 2.28 as; "Protect and enhance the area's valuable heritage and historic assets".
Historic England welcomes, in principle, as part of the positive strategy for the conservation and enjoyment of the historic environment required by paragraph 185 of the National Planning Policy Framework, the reference to the historic environment in paragraph 3.1;

"It is the intention of the Council to enable the delivery of infrastructure, jobs, accessible local services and housing for future generations while supporting the historic and natural environment".

However, the National Planning Policy Framework refers to "conserving and enhancing our natural, built and historic environment" (paragraph 8 c)) and the "conservation and enhancement of the natural, built and historic environment". We therefore suggest that "supporting" should be "conserving and enhancing" as terminology more consistent with the Framework and possibly ambiguous than "supporting".

Reword the first sentence of paragraph 3.1 as;
"It is the intention of the Council to enable the delivery of infrastructure, jobs, accessible local services and housing for future generations while conserving and enhancing the historic, built and natural environment".
Historic England welcomes the inclusion of "Have a quality of life that is enriched through opportunities to enjoy our local culture, arts and a conserved and enhanced heritage;" in the Vision as part of the positive strategy for the conservation and enjoyment of the historic environment required by paragraph 185 of the National Planning Policy Framework.
Historic England welcomes "As an historic walled cathedral city, its rich cultural and architectural heritage will be conserved, enhanced and promoted together with the views and landscape value afforded by its setting" in paragraph 3.4 as part of the positive strategy for the conservation and enjoyment of the historic environment required by paragraph 185 of the National Planning Policy Framework.
Historic England welcomes and supports "The conservation and enhancement of the historic environment, the high quality landscapes and the agricultural and other rural activities that support it will remain paramount" in paragraph 3.14 as part of the positive strategy for the conservation and enjoyment of the historic environment required by paragraph 185 of the National Planning Policy Framework.
Historic England welcomes and supports, in principle, the Strategic Objective "Conserve and enhance landscape and heritage" as part of the positive strategy for the conservation and enjoyment of the historic environment required by paragraph 185 of the National Planning Policy Framework. However, we suggest that it could be rather more ambitious e.g. "Conserve, enhance, increase appreciation and enjoyment of and access to heritage"
Paragraph 4.2 states that; "New development must achieve sustainable development principles and must not adversely affect the character, quality, amenity or safety of the built environment, wherever it occurs". The implication is that this is a requirement of the National Planning Policy Framework, but we cannot find this exact wording in the Framework.

However, paragraph 127 of the Framework does set out what planning policies and decisions should ensure of developments, including "are sympathetic to local character and history" and "establish or maintain a strong sense of place". In addition, paragraph 185 of the Framework requires plans to set out a positive strategy for the conservation and enjoyment of the historic environment, which should take into account "the desirability of new development making a positive contribution to local character and distinctiveness".

We therefore consider that the final sentence of paragraph 4.2 should be revised to more closely reflect the requirements of the National Planning Policy Framework.

Reword the final sentence of paragraph 4.2 as ""New development must achieve sustainable development principles, must not adversely affect the history, quality, amenity or safety of the natural, built and historic environment and should make a positive contribution to local character and distinctiveness and establish or maintain a sense of place". (Alternatively, these could be set out as bullet points for clarity).
Historic England welcomes and supports "enhance the quality of the built, natural, historic, social and cultural environments" in Policy S2 as part of the positive strategy for the conservation and enjoyment of the historic environment required by paragraph 185 of the National Planning Policy Framework.
Although the historic environment is not identified as a constraint or as an opportunity for enhancement in paragraph 4.12 as a factor in the definition of the Settlement Hierarchy, we note that paragraph 4.14 does explain that consideration has been given to other factors in determining whether a settlement is a suitable location for additional housing growth. We would like to think that these other factors include the potential effects on the historic environment.
Historic England welcomes and supports "where possible enhances the character, significance and setting of heritage assets" as one of the considerations to guide potential discussions on a possible site for a new settlement in paragraph 4.33 as part of the positive strategy for the conservation and enjoyment of the historic environment required by paragraph 185 of the National Planning Policy Framework.
Historic England welcomes and supports "it is acknowledged that new development needs to be planned sensitively with special regard to the unique character of the city's historic environment and setting, and should be underpinned by historic characterisation assessments" in paragraph 4.90 as part of the positive strategy for the conservation and enjoyment of the historic environment required by paragraph 185 of the National Planning Policy Framework.
Nevertheless, we suggest that reference should also be made to heritage impact assessments to underpin the planning of new development.
Reword paragraph 4.90 to read;
"it is acknowledged that new development needs to be planned sensitively with special regard to the unique character of the city's historic environment and setting, and should be underpinned by historic characterisation assessment and heritage impact assessments".
Historic England welcomes and supports "such development will need to be sensitive to the
historic character of the city" in paragraph 4.91 as part of the positive strategy for the conservation and enjoyment of the historic environment required by paragraph 185 of the National Planning Policy Framework.
Historic England welcomes and supports "conserve and enhance the city's historic character and heritage", "Enhance the city's existing heritage, arts and cultural facilities", "Protect views of the cathedral" and "All development will be required to have special regard to the city's historic character and heritage. Development proposals should be underpinned by historic characterisation assessments and make a positive contribution to the city's unique character and distinctiveness" in Policy S13 as part of the positive strategy for the conservation and enjoyment of the historic environment required by paragraph 185 of the National Planning Policy Framework.
Nevertheless, we would like to see a reference to heritage impact assessments to underpin development proposals.
We also wonder if it would be helpful to have a specific policy to protect important views, allied to or combined with a policy for tall buildings in the historic city ?
Reword Policy SP13 to read "Development proposals should be underpinned by historic characterisation assessment and a heritage impact assessment......".
Historic England welcomes and supports "Any development proposals within the vicinity of the site must clearly demonstrate how the development would protect, and where possible enhance, the operation and heritage of the site as a motor-circuit and airfield" in Policy S15 as part of the positive strategy for the conservation and enjoyment of the historic environment required by paragraph 185 of the National Planning Policy Framework.
Historic England welcomes and supports "All proposals must ensure that the cultural and historical significance of the military facilities (and any other significant archaeological assets) located on the site, are understood and inform the scope of future development of that site" in Policy S17 as part of the positive strategy for the conservation and enjoyment of the historic environment required by paragraph 185 of the National Planning Policy Framework.
However, we would prefer "significant archaeological assets" to be retained in situ.
Reword Policy S17 as;
"All proposals must ensure that the cultural and historical significance of the military facilities (and any other significant archaeological assets) located on the site, are understood and inform the scope of future development of that site, with any significant archaeological assets retained in situ".
Paragraph 2.2 of the Plan notes that the North of the Plan Area has "rich cultural and heritage assets". We are surprised, therefore, that paragraph 4.128 has no mention of these assets.
Reword paragraph 4.128 "This part of the plan area is predominantly rural with few sizeable settlements, characterised by undulating countryside with a high proportion of woodland, typical of the Low Weald landscape. Conserving the rural character of the area, with its high quality landscape and natural and historic environment, is a key objective".
Historic England welcomes and supports "Conserve and enhance the rural character of the area, the quality of its landscape and the natural and historic environment;" in Policy S19 as part of the positive strategy for the conservation and enjoyment of the historic environment required by paragraph 185 of the National Planning Policy Framework.
Historic England welcomes paragraph 5.1 as part of the positive strategy for the conservation and enjoyment of the historic environment required by paragraph 185 of the National Planning Policy Framework.
Strictly-speaking, historic parks and gardens are registered for their special historic interest rather than their protection per se, but one of the purposes of Registration is to encourage appropriate protection and inclusion on the Register is a material consideration in the determination of planning applications.
Historic England welcomes paragraph 5.5 as part of the positive strategy for the conservation and enjoyment of the historic environment required by paragraph 185 of the National Planning Policy Framework.
Historic England welcomes and supports Policy S20, particularly the references to history, historic character and local identity in clause 1, sense of place in clause 2, character in clause 8 and high quality public realm in clause 11 as part of the positive strategy for the conservation and enjoyment of the historic environment required by paragraph 185 of the National Planning Policy Framework.
However, we would also like to see a specific clause relating to heritage assets.
Add a new clause; "conserves or enhances the significance, special interest, character and appearance of heritage assets".
Historic England welcomes and supports paragraph 5.12 as part of the positive strategy for the conservation and enjoyment of the historic environment required by paragraph 185 of the National Planning Policy Framework.
Historic England welcomes, in principle, paragraph 5.13 states that "Where development proposals might affect a heritage asset the Council will identify and assess the particular significance of the heritage asset and seek to avoid or minimise any conflict between the conservation of the heritage asset and any aspect of the proposal" as part of the positive strategy for the conservation and enjoyment of the historic environment required by paragraph 185 of the National Planning Policy Framework.
This very largely reflects paragraph 190 of the National Planning Policy Framework, but the Framework requires local planning authorities to take the particular significance of any heritage asset that might be affected by a proposal into account when considering the impact of a proposal on a heritage asset, "to avoid or minimise any conflict between the heritage asset's conservation and any aspect of the proposal". The requirement is clear - any conflict should be avoided or minimised; it is not sufficient to merely "seek to" avoid or minimise that conflict.

In addition, paragraph 189 of the Framework states;

"In determining applications, local planning authorities should require an applicant to describe the significance of any heritage assets affected, including any contribution made by their setting......Where a site on which development is proposed includes, or has the potential to include, heritage assets with archaeological interest, local planning authorities should require developers to submit an appropriate desk-based assessment and, where necessary, a field evaluation.

There is, therefore, a clear onus to be placed upon the applicant/developer to identify and describe the significance of any heritage assets affected.

Paragraphs 193, 194, 195 and 196 of the Framework set out how local planning authorities should consider the impact of a proposed development on the significance of a designated heritage asset. We believe that this could usefully be summarised in the Plan.

Reword paragraph 5.13;
"Where development proposals might affect a heritage asset the Council will identify and assess the particular significance of the heritage asset and take that significance into account when considering the impact of a proposal on a heritage asset, to avoid or minimise any conflict between the heritage asset's conservation and any aspect of the proposal".
Add new paragraphs;
"For applications which affect, or have the potential to affect, heritage assets the applicant will be expected to describe the significance of the asset and its setting, using appropriate expertise; at a level of detail proportionate to its significance and sufficient to understand the potential impact of the proposal; using appropriate references such as the Historic Environment Record and, if necessary, original survey (including, for assets of archaeological interest, an appropriate desk-based assessment and, where necessary, a field evaluation)";
"When considering the impact of a proposed development on the significance of a designated heritage asset, the Council will give great weight to the asset's conservation. Any harm to, or loss of, the significance of a designated heritage asset (from its alteration or destruction, or from development within its setting), will require clear and convincing justification"; and

"The Council will refuse proposals that would lead to substantial harm to (or total loss of significance of) a designated heritage asset unless it can be demonstrated that the substantial harm or total loss is necessary to achieve substantial public benefits that outweigh that harm or loss, or all of the circumstances in paragraph 195 of the National Planning Policy Framework apply. For proposals that would lead to less than substantial harm to the significance of a designated heritage asset, the Council will weigh this harm against the public benefits of the proposal".

Historic England welcomes and supports Policy S22, which we consider complies with the requirements of paragraphs 17 and 20 of the National Planning Policy Framework to contain strategic policies and for those strategic policies to make sufficient provision for the conservation and enhancement of the historic environment.

We also consider that the policy forms part of the positive strategy for the conservation and enjoyment of the historic environment required by paragraph 185 of the National Planning Policy Framework. We consider that the word "positive" is significant, and we believe that the Plan (and Council) should be proactive in the conservation and enhancement of the historic environment. National Planning Practice Guidance states "Such a [positive] strategy should recognise that conservation is not a passive exercise".
We therefore consider that the positive strategy for the conservation and enjoyment of the historic environment is not a passive exercise but requires a plan for the maintenance and use of heritage assets and for the delivery of development including within their setting that will afford appropriate protection for the asset(s) and make a positive contribution to local character and distinctiveness. We therefore look to local plans to contain commitments to positive measures for the historic environment. We therefore welcome the commitments within Policy S22 to positive actions, including heritage at risk, which paragraph 185 requires to be part of that positive strategy for the conservation and enjoyment of the historic environment. However, we do feel that the supporting text could helpfully explain a little more about the Council's approach to heritage at risk, perhaps borrowing some text from the Chichester Historic Environment Strategy and Action Plan.
We also consider that the positive strategy should comprise recognition throughout the Plan of the importance of the historic environment, of the historic environment's role in delivering the Plan's vision and the wider economic, social and environmental objectives for the Plan area, and of the potential impacts of the Plan's policies and proposals on the historic environment.
We are pleased to have identified a number of references throughout the Plan to the historic environment and we therefore consider that the Plan sets out an adequate positive strategy for the conservation and enjoyment of that historic environment as required by paragraph 185 of the National Planning Policy Framework and that the Plan is therefore compliant with that paragraph.

Add a new paragraph explaining what "heritage at risk" is and the Council's approach to assets at risk e.g.

"Unfortunately, heritage assets can be at risk from neglect, decay or other threats. Designated assets at risk, with the exception of Grade II secular buildings and Grade II places of worship used less than six times a year, are identified on the Historic England Heritage at Risk Register. Within the district outside the South Downs National Park, six assets are on the Register (February 2018): three scheduled monuments, two listed buildings and one conservation area. The Council will actively seek to address threats to heritage assets by recording and monitoring Heritage at Risk in Chichester District, publishing it on our website and working with the owners of heritage assets at risk to find solutions and secure repairs to bring them back into active use, including where appropriate viable new uses and/or proposals for enabling development so they are preserved for future generations."

Historic England suggests that paragraph 5.37 could also refer to the range of heritage assets to be found in the countryside of the Plan area.
Reword paragraph 5.37 as;

"It is valued for many reasons, including agriculture and community food production, its landscape qualities including the special characteristics of Chichester Harbour and Pagham Harbour, the setting it provides for Chichester City and other towns and villages, its range of heritage assets, including historic landscapes, and the opportunities it provides for recreation and biodiversity".
Historic England welcomes and supports clause d of Policy S32; "integrate with the surrounding built, historic and natural environments" as part of the positive strategy for the conservation and enjoyment of the historic environment required by paragraph 185 of the National Planning Policy Framework.
As noted in paragraph 6.12, the Chichester Entrenchments Scheduled Monument lies partly within and partly immediately to the north of the site. Paragraph 194 of the National Planning Policy Framework identifies Scheduled Monuments as being assets "of the highest significance", substantial harm to or loss of which should be wholly exceptional.

We have previously commented (as English Heritage) on the allocation of this site during the consultation on the Key Policies. We explained that development close to the earthworks might harm the historical value of the heritage asset by interrupting views between its parts and introducing incongruous land-use in its immediate surroundings. This in turn would make it difficult to appreciate the asset's open rural setting, its extensive linear nature and its purpose of enclosing large areas of open land.

Accordingly, we initially objected to the form of the allocation in the Key Policies, but subsequently withdrew that objection following amendments to the boundary of the Strategic Development Location on its northern side so that the boundary ran along the south edge of the belt of woodland in which the scheduled monument sits, thereby entirely excluding the monument from the SDL, and the allocation of the northern area of the amended site as open space.
We are therefore pleased to see that the Strategic Site Allocation still excludes the scheduled monument. We also welcome and support the following requirements of Policy AL1, which we consider provide, in principle, adequate protection for the Scheduled Monument in accordance with the National Planning Policy Framework:
6. Landscaped to protect priority views of Chichester Cathedral spire;
7. Keep land north of the B2178 in open use, free from built development, to protect the natural history interest of both Brandy Hole Copse, and the setting of the Chichester Entrenchments Scheduled Monument;
8. Conserve, enhance and better reveal the significance of the Chichester Entrenchments Scheduled Monument and other non-designated heritage assets and their settings and to record and advance understanding of the significance of any heritage assets to be harmed or lost;
However, this comment is without prejudice to any comments we may wish to make on any planning application that may be submitted for the development of this site.
Historic England makes no comment on the principle of the Shopwyke Strategic Site Allocation, which we note is an existing allocation.
However, the Grade II listed barn at Greenway Farm is located to the south-west of the site and the Grade II listed Shopwyke Grange and the Grade II* listed Shopwyke Hall are located to the south-east. Paragraph 194 of the National Planning Policy Framework states "Any harm to, or loss of, the significance of a designated heritage asset (from its alteration or destruction, or from development within its setting), should require clear and convincing justification". The paragraph identifies Grade II* buildings as assets of the "highest significance".

Historic England therefore welcomes and supports, in principle, the following requirement of Policy AL2, which we consider provide, in principle, adequate protection for the listed barn and Shopwyke Hall in accordance with the National Planning Policy Framework:
7. Protect existing views of Chichester Cathedral spire and conserve and enhance the historic significance of the listed barn at Greenway Farm and the cluster of buildings associated with the grade II* listed Shopwhyke Hall, which should be analysed at an early stage of the masterplan.
However, we consider that reference should also be made to the Grade II listed Shopwyke Grange. This comment is without prejudice to any comments we may wish to make on any planning application that may be submitted for the development of this site.
Reword criterion 7;"Protect existing views of Chichester Cathedral spire and conserve and enhance the historic significance of the listed barn at Greenway Farm, the listed Shopwyke Grange and the cluster of buildings associated with the grade II* listed Shopwhyke Hall which should be analysed at an early stage of the masterplan".
According to our records there are no designated heritage assets on this site, although the Grade II listed Shopwyke Grange and Grade II* listed Shopwyke Hall lie to the north-east of the allocated area, Paragraph 194 of the National Planning Policy Framework states "Any harm to, or loss of, the significance of a designated heritage asset (from its alteration or destruction, or from development within its setting), should require clear and convincing justification". The paragraph identifies Grade II* buildings as assets of the "highest significance".

We note that criterion 7 of Policy AL2 requires the development of the Shopwyke Strategic Site Allocation to ".......conserve and enhance the historic significance of the......cluster of buildings associated with the grade II* listed Shopwhyke Hall, which should be analysed at an early stage of the masterplan. We have suggested in our comments on this policy that it include reference to the listed Shopwyke Grange, and we consider that this requirement should also be included in Policy AL3 to provide, in principle, adequate protection for the listed barn and Shopwyke Hall in accordance with the National Planning Policy Framework.

Historic England welcomes and supports criterion 8 of Policy AL2; "Existing views of Chichester Cathedral spire are to be protected". However, this comment is without prejudice to any comments we may wish to make on any planning application that may be submitted for the development of this site.
Reword criterion 8 as;
"Protect existing views of Chichester Cathedral spire and conserve and enhance the historic significance of the listed Shopwyke Grange and the cluster of buildings associated with the grade II* listed Shopwhyke Hall which should be analysed at an early stage of the masterplan".
Historic England makes no comment on the principle of the two sites at Land at Westhampnett/North East Chichester Strategic Site Allocation, which we note were part of a broad strategic development location in the adopted Local Plan.
However, the site abuts the Graylingwell Hospital Conservation Area, the buildings of the former 'pauper lunatic asylum' (including the Grade II listed chapel), the Grade II listed Summersdale Farmhouse and a Grade II registered park and garden. Paragraph 194 of the National Planning Policy Framework states "Any harm to, or loss of, the significance of a designated heritage asset (from its alteration or destruction, or from development within its setting), should require clear and convincing justification".
Historic England therefore welcomes and supports, in principle, the following requirement of Policy AL4, which we consider provide, in principle, adequate protection for these designated assets in accordance with the National Planning Policy Framework:
9. Development should be designed with special regard to the Graylingwell Hospital
Conservation Area, the buildings of the former 'pauper lunatic asylum' and the Grade II registered park and garden in which they sit, and to other listed buildings in the vicinity of the site and their settings. Important views of Chichester Cathedral spire from the area should be protected;
This comment is without prejudice to any comments we may wish to make on any planning application that may be submitted for the development of this site.
Historic England makes no comment on the principle of the Southern Gateway Strategic Site Allocation.
However, the site includes a row of Grade II listed buildings on Southgate and a number of non-designated heritage assets (the southern gateway of the city had Roman roads converging upon it and this is likely to result in enhanced archaeological potential in this part of the city. The development of suburbs in the medieval and later periods is a further factor with both the canal and railway as examples of later uses of the area. There are a number of buildings of interest, including the former Law Courts and Bus Garage). Part of the site lies within the Chichester Conservation Area and there are listed buildings adjacent to the site.
Paragraph 184 of the National Planning Policy Framework states heritage assets "are an irreplaceable resource, and should be conserved in a manner appropriate to their significance, so that they can be enjoyed for their contribution to the quality of life of existing and future generations". Paragraph 194 of the Framework states "Any harm to, or loss of, the significance of a designated heritage asset (from its alteration or destruction, or from development within its setting), should require clear and convincing justification".

Historic England therefore welcomes and supports, in principle, the following requirements of Policy AL5;

3. Respect for the historic context and make a positive contribution towards protecting and enhancing the local character and special heritage of the area and important historic views, especially those from the Canal Basin towards Chichester Cathedral;
9. Include an archaeological assessment to define the extent and significance of any
archaeological remains and reflect these in the proposals, as appropriate;
However, we consider that these requirements should be strengthened to ensure that they provide adequate protection for these assets in accordance with the National Planning Policy Framework. In addition, we consider that Policy AL5 should promote more strongly the opportunity to use the heritage of the area to help define its character and the desirability of new development making a positive contribution to local character and distinctiveness as part of the positive strategy for the conservation and enjoyment of the historic environment required by paragraph 185 of the National Planning Policy Framework.
These comments are without prejudice to any comments we may wish to make on any planning application that may be submitted for the development of this site.
Reword clause 2 as follows;
Proposals should include a high quality distinctive design response appropriate to this gateway location and based on the character and heritage of the area, which establishes a clear hierarchy of streets and spaces, active frontages of buildings which front streets and spaces with clearly defined building lines;
Reword clause 3 as follows;
3. Respect for the historic context and make a positive contribution towards protecting and enhancing the local character and special heritage of the area, including the Conservation Area, listed buildings (both on and adjacent to the site), non-designated buildings of historic interest and important historic views, especially those from the Canal Basin towards Chichester Cathedral;
Reword clause 9 as follows;
9. Include an archaeological assessment to define the extent and significance of any
archaeological remains and reflect these in the proposals;
According to our records, the site Land South-West of Chichester (Apuldram and Donnington Parishes) contains no designated heritage assets. We therefore have no comment on the principle of the allocation, although we would expect its potential for non-designated archaeology to have been assessed, with reference to the Council's Historic Environment Record, in accordance with paragraph 187 of the National Planning Policy Framework which states;
Local planning authorities should maintain or have access to a historic environment record. This should contain up-to-date evidence about the historic environment in their area and be used to:
a) assess the significance of heritage assets and the contribution they make to their environment; and
b) predict the likelihood that currently unidentified heritage assets, particularly sites of historic and archaeological interest, will be discovered in the future.
Historic England welcomes and supports clause 3:
3. Protect existing views of Chichester Cathedral spire and the setting of the Chichester Harbour Area of Outstanding Natural Beauty which should be analysed at an early stage of the masterplan;
This comment is without prejudice to any comments we may wish to make on any planning application that may be submitted for the development of this site.
According to our records, the site at Highgrove Farm, Bosham, contains no designated heritage assets. We therefore have no comment on the principle of the allocation, although we would expect its potential for non-designated archaeology to have been assessed, with reference to the Council's Historic Environment Record, in accordance with paragraph 187 of the National Planning Policy Framework which states;
Local planning authorities should maintain or have access to a historic environment record. This should contain up-to-date evidence about the historic environment in their area and be used to:
a) assess the significance of heritage assets and the contribution they make to their environment; and
b) predict the likelihood that currently unidentified heritage assets, particularly sites of historic and archaeological interest, will be discovered in the future.
This comment is without prejudice to any comments we may wish to make on any planning application that may be submitted for the development of this site.

Historic England has no comments on the principle of land being allocated in the revised Fishbourne Neighbourhood Plan for a minimum of 250 dwellings.
However, we note that one of the specific issues that need to be taken into account in planning for development at Fishbourne identified in paragraph 6.65 of the Plan is "Protecting the heritage assets of Fishbourne and their setting".
We welcome the recognition and identification of this issue, but we consider that it should be included as a specific requirement in Policy AL9, to ensure that the allocation of the site or sites in the Neighbourhood Plan conforms with the National Planning Policy Framework, particularly paragraphs 184 and 194.
Add the following clause to Policy AL9;
"Demonstration that the development would not have an adverse impact on the significance of heritage assets, including listed buildings and the Fishbourne Roman site Scheduled Monument, or the character or appearance of the Fishbourne Conservation Area".
Historic England has no comments on the principle of land being allocated in the revised Chidham and Hambrook Neighbourhood Plan for a minimum of 500 dwellings.
However, we consider that Policy AL10 should include a specific requirement to ensure that the allocation of the site or sites in the Neighbourhood Plan conforms with the National Planning Policy Framework, particularly paragraphs 184 and 194.
Add the following clause to Policy AL10;
"Demonstration that the development would not have an adverse impact on the significance of heritage assets.
Historic England has no comments on the principle of land being allocated in the revised Hunston Neighbourhood Plan for a minimum of 250 dwellings.
However, we note that one of the specific issues that need to be taken into account in planning for development at Hunston identified in paragraph 6.77 of the Plan is "Respecting the setting of listed buildings and the Hunston conservation area".
We welcome the recognition and identification of this issue, but we consider that it should be included as a specific requirement in Policy AL11, to ensure that the allocation of the site or sites in the Neighbourhood Plan conforms with the National Planning Policy Framework, particularly paragraphs 184 and 194.
Add the following clause to Policy AL11;
"Demonstration that the development would not have an adverse impact on the significance of heritage assets, including listed buildings, or on the character or appearance of the Hunston Conservation Area."
According to our records, the site Land north of Park Farm, Selsey, contains no designated heritage assets. We therefore have no comment on the principle of the allocation, although we would expect its potential for non-designated archaeology to have been assessed, with reference to the Council's Historic Environment Record, in accordance with paragraph 187 of the National Planning Policy Framework which states;
Local planning authorities should maintain or have access to a historic environment record. This should contain up-to-date evidence about the historic environment in their area and be used to:
a) assess the significance of heritage assets and the contribution they make to their environment; and
b) predict the likelihood that currently unidentified heritage assets, particularly sites of historic and archaeological interest, will be discovered in the future.

This comment is without prejudice to any comments we may wish to make on any planning application that may be submitted for the development of this site.
Historic England has no comments on the principle of land being allocated in the revised Southbourne Neighbourhood Plan for a minimum of 1,250 dwellings.
However, we consider that a specific requirement should be included in Policy AL13 to ensure that the allocation of the site or sites in the Neighbourhood Plan conforms with the National Planning Policy Framework, particularly paragraphs 184 and 194.
Add the following clause to Policy AL13;
"Demonstration that the development would not have an adverse impact on the significance of heritage assets, including listed buildings, or on the character or appearance of the Prinsted Conservation Area."
Historic England has no comments on the principle of the allocation Land West of Tangmere.

However, the site is close to the Tangmere Conservation Area and a number of listed buildings, including the Grade I listed Church of St Andrew. Paragraph 194 of the National Planning Policy Framework states "Any harm to, or loss of, the significance of a designated heritage asset (from its alteration or destruction, or from development within its setting), should require clear and convincing justification". The paragraph identifies Grade I buildings as assets of the "highest significance".

Historic England therefore welcomes, in principle, clauses 5 and 8 of Policy AL14

5. Protect existing views of Chichester Cathedral spire and reduce any impact on views from within the National Park;
8. Conserve and enhance the heritage and potential archaeological interest of the village, surrounding areas and World War II airfield, including the expansion or relocation of the Tangmere Military Aviation Museum.
However, we consider that clause 8 should be strengthened to ensure that it provides adequate protection for these assets in accordance with the National Planning Policy Framework. In addition, we note that paragraph 6.95 of the Plan identifies, as one of the specific issues need to be taken into account in planning the development and site layout at Tangmere, "Conserving and enhancing the setting of the historic village (particularly the Conservation Area"). We consider that this should be included within Policy AL14.
This comment is without prejudice to any comments we may wish to make on any planning application that may be submitted for the development of this site.
Reword criterion 8 as follows:

8. Conserve and enhance the heritage and potential archaeological interest of the village, surrounding areas and World War II airfield, particularly the Conservation Area and the Grade I listed Church of St Andrew and including the expansion or relocation of the Tangmere Military Aviation Museum.
Add a new criterion as follows:
""Conserve and enhancie the setting of the historic village, particularly of the Conservation Area".
Historic England welcomes and supports clause b of Policy DM3 as part of the positive strategy for the conservation and enjoyment of the historic environment required by paragraph 185 of the National Planning Policy Framework.
Historic England welcomes and supports clauses 1 c and 2 e of Policy DM5 as part of the positive strategy for the conservation and enjoyment of the historic environment required by paragraph 185 of the National Planning Policy Framework.
Historic England welcomes, in principle, clause 2 of Policy DM13 but considers that the policy should be, in the first instance, to avoid adverse impact on the historic environment as part of the positive strategy for the conservation and enjoyment of the historic environment required by paragraph 185 of the National Planning Policy Framework. We consider that the wording used in Policies DM3 and DM5 would be appropriate.
Reword clause 2 of Policy DM13 as:
"Is located so as not compromise the essential features of nationally designated areas of landscape, historic environment or nature conservation protection".
Historic England welcomes and supports clause 1 of Policy DM17 as part of the positive strategy for the conservation and enjoyment of the historic environment required by paragraph 185 of the National Planning Policy Framework.
Historic England welcomes and supports clause b of Policy DM20 as part of the positive strategy for the conservation and enjoyment of the historic environment required by paragraph 185 of the National Planning Policy Framework.
Historic England welcomes and supports paragraph 7.129 as part of the positive strategy for the conservation and enjoyment of the historic environment required by paragraph 185 of the National Planning Policy Framework.
Many farm buildings that are now redundant for modern farming needs are likely to be of historic interest - it is acknowledged that farm buildings are generally under-represented on the National Heritage List for England. Historic England considers that Policy DM21 should include stronger protection for such buildings as part of the positive strategy for the conservation and enjoyment of the historic environment required by paragraph 185 of the National Planning Policy Framework.
Add a new criterion to Policy DM21 as follows:

"Features of architectural or historic significance are retained and, where the building forms part of a historically significant complex of buildings, consideration is given to the future use(s) of those buildings and the impact of the proposal on the integrity and character of the complex".
Historic England welcomes and supports, in principle, paragraphs 7.154 - 7.161.
However, we consider that paragraph 7.154 should be reworded to clarify the distinction between designated and non-designated heritage assets (the latter including buildings on the Local Buildings List for Chichester).
Reword paragraph 7.154 as follows:
"There are a large number of "Heritage Assets" (as defined in the National Planning Policy Framework), both designated and non-designated, in the plan area. Designated assets are Listed Buildings, Scheduled Monuments, Conservation Areas and Registered Historic Parks and Gardens. Non-designated assets include archaeological sites (although the remains may be of national significance equivalent to scheduled monuments, and which should be considered subject to the policies for scheduled monuments) and non-listed buildings which have been identified as locally important, such as those on the Local Buildings List for Chichester City and 'positive' buildings within Conservation Areas."
Historic England welcomes and supports in principle, Policy DM27 both as part of the positive strategy for the conservation and enjoyment of the historic environment as required by paragraph 185 of the National Planning Policy Framework and also as a non-strategic policy for the conservation and enhancement of the historic environment as suggested by paragraph 28 of the Framework.
However, we consider that clause e. should specify the (wholly) exceptional circumstances in which permission for a proposed development that would lead to substantial harm to (or total loss of significance of) a designated heritage asset would be granted i.e. where it can be demonstrated that the substantial harm or total loss is necessary to achieve substantial public benefits that outweigh that harm or loss, or all of the circumstances in paragraph 195 of the National Planning Policy Framework apply.

We would also welcome the policy being more detailed in terms of the considerations to be taken into account when assessing development proposals affecting the different types of heritage asset, as do, for example, Policies EH10, EH11, EH14 and EH15 of the West Oxfordshire Local Plan 2031. These policies were developed with Historic England and the Inspector that examined the Local Plan 2031 shared our concern that the historic environment policy in the Local Plan 2031 provided inadequate locally specific detailed policy guidance and considered the more detailed policies necessary for the Plan to be sound.

(However, we do acknowledge that the Inspector that examined the Key Policies development plan document considered the modified historic environment policy (Policy 47) put forward by the Council with our support was sufficient for the Plan to be sound, and that Policy DM27 in the Local Plan Review very largely repeats Policy 47).

Reword clause e. of Policy DM27 as follows;
"Development involving substantial harm to or loss of designated heritage assets will
only be granted in exceptional circumstances (wholly exceptional circumstances for
designated assets of the highest significance) i.e. where it can be demonstrated that the substantial harm or total loss is necessary to achieve substantial public benefits that outweigh that harm or loss, or all of the circumstances in paragraph 195 of the National Planning Policy Framework apply.

More details of the considerations to be taken into account when assessing development proposals affecting the different types of heritage asset. We would be pleased to work with the Council on a revised policy or policies.

Paragraph 7.195 of the Plan notes that the remnants of canals "are important early 19th Century historic features in the landscape of the coastal plain and warrant protection".
Historic England agrees with this statement, but Policy DM33 makes no mention of protecting the historic significance of the remaining canal sections.
Reword the first paragraph of Policy DM33 as follows;
"Development that makes provision of through navigation or enhancement of the Chichester Ship Canal and the Wey and Arun Canal will be supported where it meets environmental, ecological, historical and transport considerations."
Historic England welcomes and supports clause 3 of Policy DM34 as part of the positive strategy for the conservation and enjoyment of the historic environment required by paragraph 185 of the National Planning Policy Framework.

Paragraph 1.5 of the Local Plan Review states "This Plan seeks to balance the economic, social and environmental dimensions of sustainable development". "Balance" implies some gains and some losses. However, this does not reflect the four bullet points that follow this sentence.
In addition, Paragraph 8 of the National Planning Policy Framework explains that;
"Achieving sustainable development means that the planning system has three overarching objectives, which are interdependent and need to be pursued in mutually supportive ways (so that opportunities can be taken to secure net gains across each of the different objectives)".

We therefore suggest that "balance" is not the most appropriate word.

The three overarching objectives include; "c) an environmental objective - to contribute to protecting and enhancing our natural, built and historic environment......". We therefore welcome the fourth bullet point of paragraph 1.5; "Protecting and enhancing the unique and special qualities of our environment".

Reword the first sentence of paragraph 1.5 as; "This Plan seeks to deliver the economic, social and environmental dimensions of sustainable development in mutually supportive ways".

Paragraph 1.16 explains that the National Planning Policy Framework reiterates the importance of significantly boosting the supply of new dwellings, whilst ensuring provision for other development needs including economic growth.
Whilst not untrue, we consider that this does not fully represent the Government's objectives and policies as set out in the Framework and therefore gives the misleading impression that the Framework is only about housing supply and economic development.
In fact, the protection and enhancement of the natural, built and historic environment is also identified as important in the Framework e.g. in the environmental overarching objective for the planning system as set out in paragraphs 8, 11b)i and 20 d).
Reword the final sentence of paragraph 1.16 as:
"The importance of significantly boosting the supply of new dwellings is reiterated, whilst ensuring provision for other development needs including economic growth and protecting and enhancing the natural, built and historic environment".
Paragraph 31 of the National Planning Policy Framework requires "The preparation and review of all policies should be underpinned by relevant and up-to-date evidence". We previously expressed our concerns about the historic evidence base for the policy framework for the district when commenting on the Issues and Options stage of the Local Plan Review;
"We are aware of the Council's series of Conservation Area Character Appraisals, The Future Growth of Chichester Study and the Landscape Capacity Studies. However, the Council's "Supporting documents" webpage has no historic environment documents and we are not clear if the Council has other historic environment evidence e.g. is there an extensive urban survey of Chichester or other townscape or characterisation study ? Is there an urban archaeological database ? Is there a list of locally important heritage assets ? Has the Council undertaken a survey of grade II buildings at risk ?".
However, looking at the Council's Local Plan Review Preferred Approach Plan - Evidence Base - December 2018 webpage, the only specific historic environment evidence base document identified is the Chichester Historic Environment Strategy and Action Plan. Whilst we welcome the Strategy, we have previously expressed the view that we do not consider that it forms, by itself, an adequate historic environment evidence base for the Local Plan Review.
We are aware that the Council has a list of locally important buildings, but that Chichester was not covered by the West Sussex Extensive Historic Town Surveys - perhaps as it was thought a candidate for the more intensive approach of an Urban Archaeological Database (UAD). However, we are not aware that such a UAD exists, and whilst we are aware of the Council's Historic Environment Record (the availability of which accords with paragraph 187 of the National Planning Policy Framework), we do wonder if the archaeological evidence and significance of the city is fully understood and readily available. We suggested that the Historic Environment Strategy could set out actions to enhance understanding and management of the archaeological resource of the historic city and we would be pleased to discuss how we might be able to assist with this.
We will expect the Council to have an adequate, up-to-date and relevant historic environment evidence base and to demonstrate in the Pre-Submission Local Plan how that historic evidence base has informed and influenced the Plan's policies and site allocations.
The historic environment evidence base for the Local Plan Review should be set out on the Council's Evidence Base webpage. If there are indeed gaps in that evidence base, then these should be filled and that evidence taken on board in preparing the Pre-Submission Local Plan Review document.
Historic England welcomes and supports the reference to the historic environment of Chichester district, and the heritage assets therein, in paragraphs 2.27 and 2.28 as part of the positive strategy for the conservation and enjoyment of the historic environment required by paragraph 185 of the National Planning Policy Framework.

Historic England welcomes and supports, in principle, the identification of "Protect the area's valuable heritage and historic assets" as one of the challenges faced by the Plan.
However, the National Planning Policy Framework requires local plans to deliver an environmental overarching objective which includes "to contribute to conserving and enhancing our natural, built and historic environment" (paragraph 8 c)) and to include strategic policies to make sufficient provision for "conservation and enhancement of the natural, built and historic environment" (our underlining).
The Framework therefore requires local planning authorities, through their local plans, to do more than just conserve the historic environment i.e. to enhance it as well. This should be identified as a challenge (although it is also an opportunity).
Reword the last bullet point of paragraph 2.28 as; "Protect and enhance the area's valuable heritage and historic assets".
Historic England welcomes, in principle, as part of the positive strategy for the conservation and enjoyment of the historic environment required by paragraph 185 of the National Planning Policy Framework, the reference to the historic environment in paragraph 3.1;

"It is the intention of the Council to enable the delivery of infrastructure, jobs, accessible local services and housing for future generations while supporting the historic and natural environment".

However, the National Planning Policy Framework refers to "conserving and enhancing our natural, built and historic environment" (paragraph 8 c)) and the "conservation and enhancement of the natural, built and historic environment". We therefore suggest that "supporting" should be "conserving and enhancing" as terminology more consistent with the Framework and possibly ambiguous than "supporting".

Reword the first sentence of paragraph 3.1 as;
"It is the intention of the Council to enable the delivery of infrastructure, jobs, accessible local services and housing for future generations while conserving and enhancing the historic, built and natural environment".
Historic England welcomes the inclusion of "Have a quality of life that is enriched through opportunities to enjoy our local culture, arts and a conserved and enhanced heritage;" in the Vision as part of the positive strategy for the conservation and enjoyment of the historic environment required by paragraph 185 of the National Planning Policy Framework.
Historic England welcomes "As an historic walled cathedral city, its rich cultural and architectural heritage will be conserved, enhanced and promoted together with the views and landscape value afforded by its setting" in paragraph 3.4 as part of the positive strategy for the conservation and enjoyment of the historic environment required by paragraph 185 of the National Planning Policy Framework.
Historic England welcomes and supports "The conservation and enhancement of the historic environment, the high quality landscapes and the agricultural and other rural activities that support it will remain paramount" in paragraph 3.14 as part of the positive strategy for the conservation and enjoyment of the historic environment required by paragraph 185 of the National Planning Policy Framework.
Historic England welcomes and supports, in principle, the Strategic Objective "Conserve and enhance landscape and heritage" as part of the positive strategy for the conservation and enjoyment of the historic environment required by paragraph 185 of the National Planning Policy Framework. However, we suggest that it could be rather more ambitious e.g. "Conserve, enhance, increase appreciation and enjoyment of and access to heritage"
Paragraph 4.2 states that; "New development must achieve sustainable development principles and must not adversely affect the character, quality, amenity or safety of the built environment, wherever it occurs". The implication is that this is a requirement of the National Planning Policy Framework, but we cannot find this exact wording in the Framework.

However, paragraph 127 of the Framework does set out what planning policies and decisions should ensure of developments, including "are sympathetic to local character and history" and "establish or maintain a strong sense of place". In addition, paragraph 185 of the Framework requires plans to set out a positive strategy for the conservation and enjoyment of the historic environment, which should take into account "the desirability of new development making a positive contribution to local character and distinctiveness".

We therefore consider that the final sentence of paragraph 4.2 should be revised to more closely reflect the requirements of the National Planning Policy Framework.

Reword the final sentence of paragraph 4.2 as ""New development must achieve sustainable development principles, must not adversely affect the history, quality, amenity or safety of the natural, built and historic environment and should make a positive contribution to local character and distinctiveness and establish or maintain a sense of place". (Alternatively, these could be set out as bullet points for clarity).
Historic England welcomes and supports "enhance the quality of the built, natural, historic, social and cultural environments" in Policy S2 as part of the positive strategy for the conservation and enjoyment of the historic environment required by paragraph 185 of the National Planning Policy Framework.
Although the historic environment is not identified as a constraint or as an opportunity for enhancement in paragraph 4.12 as a factor in the definition of the Settlement Hierarchy, we note that paragraph 4.14 does explain that consideration has been given to other factors in determining whether a settlement is a suitable location for additional housing growth. We would like to think that these other factors include the potential effects on the historic environment.
Historic England welcomes and supports "where possible enhances the character, significance and setting of heritage assets" as one of the considerations to guide potential discussions on a possible site for a new settlement in paragraph 4.33 as part of the positive strategy for the conservation and enjoyment of the historic environment required by paragraph 185 of the National Planning Policy Framework.
Historic England welcomes and supports "it is acknowledged that new development needs to be planned sensitively with special regard to the unique character of the city's historic environment and setting, and should be underpinned by historic characterisation assessments" in paragraph 4.90 as part of the positive strategy for the conservation and enjoyment of the historic environment required by paragraph 185 of the National Planning Policy Framework.
Nevertheless, we suggest that reference should also be made to heritage impact assessments to underpin the planning of new development.
Reword paragraph 4.90 to read;
"it is acknowledged that new development needs to be planned sensitively with special regard to the unique character of the city's historic environment and setting, and should be underpinned by historic characterisation assessment and heritage impact assessments".
Historic England welcomes and supports "such development will need to be sensitive to the
historic character of the city" in paragraph 4.91 as part of the positive strategy for the conservation and enjoyment of the historic environment required by paragraph 185 of the National Planning Policy Framework.
Historic England welcomes and supports "conserve and enhance the city's historic character and heritage", "Enhance the city's existing heritage, arts and cultural facilities", "Protect views of the cathedral" and "All development will be required to have special regard to the city's historic character and heritage. Development proposals should be underpinned by historic characterisation assessments and make a positive contribution to the city's unique character and distinctiveness" in Policy S13 as part of the positive strategy for the conservation and enjoyment of the historic environment required by paragraph 185 of the National Planning Policy Framework.
Nevertheless, we would like to see a reference to heritage impact assessments to underpin development proposals.
We also wonder if it would be helpful to have a specific policy to protect important views, allied to or combined with a policy for tall buildings in the historic city ?
Reword Policy SP13 to read "Development proposals should be underpinned by historic characterisation assessment and a heritage impact assessment......".
Historic England welcomes and supports "Any development proposals within the vicinity of the site must clearly demonstrate how the development would protect, and where possible enhance, the operation and heritage of the site as a motor-circuit and airfield" in Policy S15 as part of the positive strategy for the conservation and enjoyment of the historic environment required by paragraph 185 of the National Planning Policy Framework.
Historic England welcomes and supports "All proposals must ensure that the cultural and historical significance of the military facilities (and any other significant archaeological assets) located on the site, are understood and inform the scope of future development of that site" in Policy S17 as part of the positive strategy for the conservation and enjoyment of the historic environment required by paragraph 185 of the National Planning Policy Framework.
However, we would prefer "significant archaeological assets" to be retained in situ.
Reword Policy S17 as;
"All proposals must ensure that the cultural and historical significance of the military facilities (and any other significant archaeological assets) located on the site, are understood and inform the scope of future development of that site, with any significant archaeological assets retained in situ".
Paragraph 2.2 of the Plan notes that the North of the Plan Area has "rich cultural and heritage assets". We are surprised, therefore, that paragraph 4.128 has no mention of these assets.
Reword paragraph 4.128 "This part of the plan area is predominantly rural with few sizeable settlements, characterised by undulating countryside with a high proportion of woodland, typical of the Low Weald landscape. Conserving the rural character of the area, with its high quality landscape and natural and historic environment, is a key objective".
Historic England welcomes and supports "Conserve and enhance the rural character of the area, the quality of its landscape and the natural and historic environment;" in Policy S19 as part of the positive strategy for the conservation and enjoyment of the historic environment required by paragraph 185 of the National Planning Policy Framework.
Historic England welcomes paragraph 5.1 as part of the positive strategy for the conservation and enjoyment of the historic environment required by paragraph 185 of the National Planning Policy Framework.
Strictly-speaking, historic parks and gardens are registered for their special historic interest rather than their protection per se, but one of the purposes of Registration is to encourage appropriate protection and inclusion on the Register is a material consideration in the determination of planning applications.
Historic England welcomes paragraph 5.5 as part of the positive strategy for the conservation and enjoyment of the historic environment required by paragraph 185 of the National Planning Policy Framework.
Historic England welcomes and supports Policy S20, particularly the references to history, historic character and local identity in clause 1, sense of place in clause 2, character in clause 8 and high quality public realm in clause 11 as part of the positive strategy for the conservation and enjoyment of the historic environment required by paragraph 185 of the National Planning Policy Framework.
However, we would also like to see a specific clause relating to heritage assets.
Add a new clause; "conserves or enhances the significance, special interest, character and appearance of heritage assets".
Historic England welcomes and supports paragraph 5.12 as part of the positive strategy for the conservation and enjoyment of the historic environment required by paragraph 185 of the National Planning Policy Framework.
Historic England welcomes, in principle, paragraph 5.13 states that "Where development proposals might affect a heritage asset the Council will identify and assess the particular significance of the heritage asset and seek to avoid or minimise any conflict between the conservation of the heritage asset and any aspect of the proposal" as part of the positive strategy for the conservation and enjoyment of the historic environment required by paragraph 185 of the National Planning Policy Framework.
This very largely reflects paragraph 190 of the National Planning Policy Framework, but the Framework requires local planning authorities to take the particular significance of any heritage asset that might be affected by a proposal into account when considering the impact of a proposal on a heritage asset, "to avoid or minimise any conflict between the heritage asset's conservation and any aspect of the proposal". The requirement is clear - any conflict should be avoided or minimised; it is not sufficient to merely "seek to" avoid or minimise that conflict.

In addition, paragraph 189 of the Framework states;

"In determining applications, local planning authorities should require an applicant to describe the significance of any heritage assets affected, including any contribution made by their setting......Where a site on which development is proposed includes, or has the potential to include, heritage assets with archaeological interest, local planning authorities should require developers to submit an appropriate desk-based assessment and, where necessary, a field evaluation.

There is, therefore, a clear onus to be placed upon the applicant/developer to identify and describe the significance of any heritage assets affected.

Paragraphs 193, 194, 195 and 196 of the Framework set out how local planning authorities should consider the impact of a proposed development on the significance of a designated heritage asset. We believe that this could usefully be summarised in the Plan.

Reword paragraph 5.13;
"Where development proposals might affect a heritage asset the Council will identify and assess the particular significance of the heritage asset and take that significance into account when considering the impact of a proposal on a heritage asset, to avoid or minimise any conflict between the heritage asset's conservation and any aspect of the proposal".
Add new paragraphs;
"For applications which affect, or have the potential to affect, heritage assets the applicant will be expected to describe the significance of the asset and its setting, using appropriate expertise; at a level of detail proportionate to its significance and sufficient to understand the potential impact of the proposal; using appropriate references such as the Historic Environment Record and, if necessary, original survey (including, for assets of archaeological interest, an appropriate desk-based assessment and, where necessary, a field evaluation)";
"When considering the impact of a proposed development on the significance of a designated heritage asset, the Council will give great weight to the asset's conservation. Any harm to, or loss of, the significance of a designated heritage asset (from its alteration or destruction, or from development within its setting), will require clear and convincing justification"; and

"The Council will refuse proposals that would lead to substantial harm to (or total loss of significance of) a designated heritage asset unless it can be demonstrated that the substantial harm or total loss is necessary to achieve substantial public benefits that outweigh that harm or loss, or all of the circumstances in paragraph 195 of the National Planning Policy Framework apply. For proposals that would lead to less than substantial harm to the significance of a designated heritage asset, the Council will weigh this harm against the public benefits of the proposal".

Historic England welcomes and supports Policy S22, which we consider complies with the requirements of paragraphs 17 and 20 of the National Planning Policy Framework to contain strategic policies and for those strategic policies to make sufficient provision for the conservation and enhancement of the historic environment.

We also consider that the policy forms part of the positive strategy for the conservation and enjoyment of the historic environment required by paragraph 185 of the National Planning Policy Framework. We consider that the word "positive" is significant, and we believe that the Plan (and Council) should be proactive in the conservation and enhancement of the historic environment. National Planning Practice Guidance states "Such a [positive] strategy should recognise that conservation is not a passive exercise".
We therefore consider that the positive strategy for the conservation and enjoyment of the historic environment is not a passive exercise but requires a plan for the maintenance and use of heritage assets and for the delivery of development including within their setting that will afford appropriate protection for the asset(s) and make a positive contribution to local character and distinctiveness. We therefore look to local plans to contain commitments to positive measures for the historic environment. We therefore welcome the commitments within Policy S22 to positive actions, including heritage at risk, which paragraph 185 requires to be part of that positive strategy for the conservation and enjoyment of the historic environment. However, we do feel that the supporting text could helpfully explain a little more about the Council's approach to heritage at risk, perhaps borrowing some text from the Chichester Historic Environment Strategy and Action Plan.
We also consider that the positive strategy should comprise recognition throughout the Plan of the importance of the historic environment, of the historic environment's role in delivering the Plan's vision and the wider economic, social and environmental objectives for the Plan area, and of the potential impacts of the Plan's policies and proposals on the historic environment.
We are pleased to have identified a number of references throughout the Plan to the historic environment and we therefore consider that the Plan sets out an adequate positive strategy for the conservation and enjoyment of that historic environment as required by paragraph 185 of the National Planning Policy Framework and that the Plan is therefore compliant with that paragraph.

Add a new paragraph explaining what "heritage at risk" is and the Council's approach to assets at risk e.g.

"Unfortunately, heritage assets can be at risk from neglect, decay or other threats. Designated assets at risk, with the exception of Grade II secular buildings and Grade II places of worship used less than six times a year, are identified on the Historic England Heritage at Risk Register. Within the district outside the South Downs National Park, six assets are on the Register (February 2018): three scheduled monuments, two listed buildings and one conservation area. The Council will actively seek to address threats to heritage assets by recording and monitoring Heritage at Risk in Chichester District, publishing it on our website and working with the owners of heritage assets at risk to find solutions and secure repairs to bring them back into active use, including where appropriate viable new uses and/or proposals for enabling development so they are preserved for future generations."

Historic England suggests that paragraph 5.37 could also refer to the range of heritage assets to be found in the countryside of the Plan area.
Reword paragraph 5.37 as;

"It is valued for many reasons, including agriculture and community food production, its landscape qualities including the special characteristics of Chichester Harbour and Pagham Harbour, the setting it provides for Chichester City and other towns and villages, its range of heritage assets, including historic landscapes, and the opportunities it provides for recreation and biodiversity".
Historic England welcomes and supports clause d of Policy S32; "integrate with the surrounding built, historic and natural environments" as part of the positive strategy for the conservation and enjoyment of the historic environment required by paragraph 185 of the National Planning Policy Framework.
As noted in paragraph 6.12, the Chichester Entrenchments Scheduled Monument lies partly within and partly immediately to the north of the site. Paragraph 194 of the National Planning Policy Framework identifies Scheduled Monuments as being assets "of the highest significance", substantial harm to or loss of which should be wholly exceptional.

We have previously commented (as English Heritage) on the allocation of this site during the consultation on the Key Policies. We explained that development close to the earthworks might harm the historical value of the heritage asset by interrupting views between its parts and introducing incongruous land-use in its immediate surroundings. This in turn would make it difficult to appreciate the asset's open rural setting, its extensive linear nature and its purpose of enclosing large areas of open land.

Accordingly, we initially objected to the form of the allocation in the Key Policies, but subsequently withdrew that objection following amendments to the boundary of the Strategic Development Location on its northern side so that the boundary ran along the south edge of the belt of woodland in which the scheduled monument sits, thereby entirely excluding the monument from the SDL, and the allocation of the northern area of the amended site as open space.
We are therefore pleased to see that the Strategic Site Allocation still excludes the scheduled monument. We also welcome and support the following requirements of Policy AL1, which we consider provide, in principle, adequate protection for the Scheduled Monument in accordance with the National Planning Policy Framework:
6. Landscaped to protect priority views of Chichester Cathedral spire;
7. Keep land north of the B2178 in open use, free from built development, to protect the natural history interest of both Brandy Hole Copse, and the setting of the Chichester Entrenchments Scheduled Monument;
8. Conserve, enhance and better reveal the significance of the Chichester Entrenchments Scheduled Monument and other non-designated heritage assets and their settings and to record and advance understanding of the significance of any heritage assets to be harmed or lost;
However, this comment is without prejudice to any comments we may wish to make on any planning application that may be submitted for the development of this site.
Historic England makes no comment on the principle of the Shopwyke Strategic Site Allocation, which we note is an existing allocation.
However, the Grade II listed barn at Greenway Farm is located to the south-west of the site and the Grade II listed Shopwyke Grange and the Grade II* listed Shopwyke Hall are located to the south-east. Paragraph 194 of the National Planning Policy Framework states "Any harm to, or loss of, the significance of a designated heritage asset (from its alteration or destruction, or from development within its setting), should require clear and convincing justification". The paragraph identifies Grade II* buildings as assets of the "highest significance".

Historic England therefore welcomes and supports, in principle, the following requirement of Policy AL2, which we consider provide, in principle, adequate protection for the listed barn and Shopwyke Hall in accordance with the National Planning Policy Framework:
7. Protect existing views of Chichester Cathedral spire and conserve and enhance the historic significance of the listed barn at Greenway Farm and the cluster of buildings associated with the grade II* listed Shopwhyke Hall, which should be analysed at an early stage of the masterplan.
However, we consider that reference should also be made to the Grade II listed Shopwyke Grange. This comment is without prejudice to any comments we may wish to make on any planning application that may be submitted for the development of this site.
Reword criterion 7;"Protect existing views of Chichester Cathedral spire and conserve and enhance the historic significance of the listed barn at Greenway Farm, the listed Shopwyke Grange and the cluster of buildings associated with the grade II* listed Shopwhyke Hall which should be analysed at an early stage of the masterplan".
According to our records there are no designated heritage assets on this site, although the Grade II listed Shopwyke Grange and Grade II* listed Shopwyke Hall lie to the north-east of the allocated area, Paragraph 194 of the National Planning Policy Framework states "Any harm to, or loss of, the significance of a designated heritage asset (from its alteration or destruction, or from development within its setting), should require clear and convincing justification". The paragraph identifies Grade II* buildings as assets of the "highest significance".

We note that criterion 7 of Policy AL2 requires the development of the Shopwyke Strategic Site Allocation to ".......conserve and enhance the historic significance of the......cluster of buildings associated with the grade II* listed Shopwhyke Hall, which should be analysed at an early stage of the masterplan. We have suggested in our comments on this policy that it include reference to the listed Shopwyke Grange, and we consider that this requirement should also be included in Policy AL3 to provide, in principle, adequate protection for the listed barn and Shopwyke Hall in accordance with the National Planning Policy Framework.

Historic England welcomes and supports criterion 8 of Policy AL2; "Existing views of Chichester Cathedral spire are to be protected". However, this comment is without prejudice to any comments we may wish to make on any planning application that may be submitted for the development of this site.
Reword criterion 8 as;
"Protect existing views of Chichester Cathedral spire and conserve and enhance the historic significance of the listed Shopwyke Grange and the cluster of buildings associated with the grade II* listed Shopwhyke Hall which should be analysed at an early stage of the masterplan".
Historic England makes no comment on the principle of the two sites at Land at Westhampnett/North East Chichester Strategic Site Allocation, which we note were part of a broad strategic development location in the adopted Local Plan.
However, the site abuts the Graylingwell Hospital Conservation Area, the buildings of the former 'pauper lunatic asylum' (including the Grade II listed chapel), the Grade II listed Summersdale Farmhouse and a Grade II registered park and garden. Paragraph 194 of the National Planning Policy Framework states "Any harm to, or loss of, the significance of a designated heritage asset (from its alteration or destruction, or from development within its setting), should require clear and convincing justification".
Historic England therefore welcomes and supports, in principle, the following requirement of Policy AL4, which we consider provide, in principle, adequate protection for these designated assets in accordance with the National Planning Policy Framework:
9. Development should be designed with special regard to the Graylingwell Hospital
Conservation Area, the buildings of the former 'pauper lunatic asylum' and the Grade II registered park and garden in which they sit, and to other listed buildings in the vicinity of the site and their settings. Important views of Chichester Cathedral spire from the area should be protected;
This comment is without prejudice to any comments we may wish to make on any planning application that may be submitted for the development of this site.
Historic England makes no comment on the principle of the Southern Gateway Strategic Site Allocation.
However, the site includes a row of Grade II listed buildings on Southgate and a number of non-designated heritage assets (the southern gateway of the city had Roman roads converging upon it and this is likely to result in enhanced archaeological potential in this part of the city. The development of suburbs in the medieval and later periods is a further factor with both the canal and railway as examples of later uses of the area. There are a number of buildings of interest, including the former Law Courts and Bus Garage). Part of the site lies within the Chichester Conservation Area and there are listed buildings adjacent to the site.
Paragraph 184 of the National Planning Policy Framework states heritage assets "are an irreplaceable resource, and should be conserved in a manner appropriate to their significance, so that they can be enjoyed for their contribution to the quality of life of existing and future generations". Paragraph 194 of the Framework states "Any harm to, or loss of, the significance of a designated heritage asset (from its alteration or destruction, or from development within its setting), should require clear and convincing justification".

Historic England therefore welcomes and supports, in principle, the following requirements of Policy AL5;

3. Respect for the historic context and make a positive contribution towards protecting and enhancing the local character and special heritage of the area and important historic views, especially those from the Canal Basin towards Chichester Cathedral;
9. Include an archaeological assessment to define the extent and significance of any
archaeological remains and reflect these in the proposals, as appropriate;
However, we consider that these requirements should be strengthened to ensure that they provide adequate protection for these assets in accordance with the National Planning Policy Framework. In addition, we consider that Policy AL5 should promote more strongly the opportunity to use the heritage of the area to help define its character and the desirability of new development making a positive contribution to local character and distinctiveness as part of the positive strategy for the conservation and enjoyment of the historic environment required by paragraph 185 of the National Planning Policy Framework.
These comments are without prejudice to any comments we may wish to make on any planning application that may be submitted for the development of this site.
Reword clause 2 as follows;
Proposals should include a high quality distinctive design response appropriate to this gateway location and based on the character and heritage of the area, which establishes a clear hierarchy of streets and spaces, active frontages of buildings which front streets and spaces with clearly defined building lines;
Reword clause 3 as follows;
3. Respect for the historic context and make a positive contribution towards protecting and enhancing the local character and special heritage of the area, including the Conservation Area, listed buildings (both on and adjacent to the site), non-designated buildings of historic interest and important historic views, especially those from the Canal Basin towards Chichester Cathedral;
Reword clause 9 as follows;
9. Include an archaeological assessment to define the extent and significance of any
archaeological remains and reflect these in the proposals;
According to our records, the site Land South-West of Chichester (Apuldram and Donnington Parishes) contains no designated heritage assets. We therefore have no comment on the principle of the allocation, although we would expect its potential for non-designated archaeology to have been assessed, with reference to the Council's Historic Environment Record, in accordance with paragraph 187 of the National Planning Policy Framework which states;
Local planning authorities should maintain or have access to a historic environment record. This should contain up-to-date evidence about the historic environment in their area and be used to:
a) assess the significance of heritage assets and the contribution they make to their environment; and
b) predict the likelihood that currently unidentified heritage assets, particularly sites of historic and archaeological interest, will be discovered in the future.
Historic England welcomes and supports clause 3:
3. Protect existing views of Chichester Cathedral spire and the setting of the Chichester Harbour Area of Outstanding Natural Beauty which should be analysed at an early stage of the masterplan;
This comment is without prejudice to any comments we may wish to make on any planning application that may be submitted for the development of this site.
According to our records, the site at Highgrove Farm, Bosham, contains no designated heritage assets. We therefore have no comment on the principle of the allocation, although we would expect its potential for non-designated archaeology to have been assessed, with reference to the Council's Historic Environment Record, in accordance with paragraph 187 of the National Planning Policy Framework which states;
Local planning authorities should maintain or have access to a historic environment record. This should contain up-to-date evidence about the historic environment in their area and be used to:
a) assess the significance of heritage assets and the contribution they make to their environment; and
b) predict the likelihood that currently unidentified heritage assets, particularly sites of historic and archaeological interest, will be discovered in the future.
This comment is without prejudice to any comments we may wish to make on any planning application that may be submitted for the development of this site.

Historic England has no comments on the principle of land being allocated in the revised Fishbourne Neighbourhood Plan for a minimum of 250 dwellings.
However, we note that one of the specific issues that need to be taken into account in planning for development at Fishbourne identified in paragraph 6.65 of the Plan is "Protecting the heritage assets of Fishbourne and their setting".
We welcome the recognition and identification of this issue, but we consider that it should be included as a specific requirement in Policy AL9, to ensure that the allocation of the site or sites in the Neighbourhood Plan conforms with the National Planning Policy Framework, particularly paragraphs 184 and 194.
Add the following clause to Policy AL9;
"Demonstration that the development would not have an adverse impact on the significance of heritage assets, including listed buildings and the Fishbourne Roman site Scheduled Monument, or the character or appearance of the Fishbourne Conservation Area".
Historic England has no comments on the principle of land being allocated in the revised Chidham and Hambrook Neighbourhood Plan for a minimum of 500 dwellings.
However, we consider that Policy AL10 should include a specific requirement to ensure that the allocation of the site or sites in the Neighbourhood Plan conforms with the National Planning Policy Framework, particularly paragraphs 184 and 194.
Add the following clause to Policy AL10;
"Demonstration that the development would not have an adverse impact on the significance of heritage assets.
Historic England has no comments on the principle of land being allocated in the revised Hunston Neighbourhood Plan for a minimum of 250 dwellings.
However, we note that one of the specific issues that need to be taken into account in planning for development at Hunston identified in paragraph 6.77 of the Plan is "Respecting the setting of listed buildings and the Hunston conservation area".
We welcome the recognition and identification of this issue, but we consider that it should be included as a specific requirement in Policy AL11, to ensure that the allocation of the site or sites in the Neighbourhood Plan conforms with the National Planning Policy Framework, particularly paragraphs 184 and 194.
Add the following clause to Policy AL11;
"Demonstration that the development would not have an adverse impact on the significance of heritage assets, including listed buildings, or on the character or appearance of the Hunston Conservation Area."
According to our records, the site Land north of Park Farm, Selsey, contains no designated heritage assets. We therefore have no comment on the principle of the allocation, although we would expect its potential for non-designated archaeology to have been assessed, with reference to the Council's Historic Environment Record, in accordance with paragraph 187 of the National Planning Policy Framework which states;
Local planning authorities should maintain or have access to a historic environment record. This should contain up-to-date evidence about the historic environment in their area and be used to:
a) assess the significance of heritage assets and the contribution they make to their environment; and
b) predict the likelihood that currently unidentified heritage assets, particularly sites of historic and archaeological interest, will be discovered in the future.

This comment is without prejudice to any comments we may wish to make on any planning application that may be submitted for the development of this site.
Historic England has no comments on the principle of land being allocated in the revised Southbourne Neighbourhood Plan for a minimum of 1,250 dwellings.
However, we consider that a specific requirement should be included in Policy AL13 to ensure that the allocation of the site or sites in the Neighbourhood Plan conforms with the National Planning Policy Framework, particularly paragraphs 184 and 194.
Add the following clause to Policy AL13;
"Demonstration that the development would not have an adverse impact on the significance of heritage assets, including listed buildings, or on the character or appearance of the Prinsted Conservation Area."
Historic England has no comments on the principle of the allocation Land West of Tangmere.

However, the site is close to the Tangmere Conservation Area and a number of listed buildings, including the Grade I listed Church of St Andrew. Paragraph 194 of the National Planning Policy Framework states "Any harm to, or loss of, the significance of a designated heritage asset (from its alteration or destruction, or from development within its setting), should require clear and convincing justification". The paragraph identifies Grade I buildings as assets of the "highest significance".

Historic England therefore welcomes, in principle, clauses 5 and 8 of Policy AL14

5. Protect existing views of Chichester Cathedral spire and reduce any impact on views from within the National Park;
8. Conserve and enhance the heritage and potential archaeological interest of the village, surrounding areas and World War II airfield, including the expansion or relocation of the Tangmere Military Aviation Museum.
However, we consider that clause 8 should be strengthened to ensure that it provides adequate protection for these assets in accordance with the National Planning Policy Framework. In addition, we note that paragraph 6.95 of the Plan identifies, as one of the specific issues need to be taken into account in planning the development and site layout at Tangmere, "Conserving and enhancing the setting of the historic village (particularly the Conservation Area"). We consider that this should be included within Policy AL14.
This comment is without prejudice to any comments we may wish to make on any planning application that may be submitted for the development of this site.
Reword criterion 8 as follows:

8. Conserve and enhance the heritage and potential archaeological interest of the village, surrounding areas and World War II airfield, particularly the Conservation Area and the Grade I listed Church of St Andrew and including the expansion or relocation of the Tangmere Military Aviation Museum.
Add a new criterion as follows:
""Conserve and enhancie the setting of the historic village, particularly of the Conservation Area".
Historic England welcomes and supports clause b of Policy DM3 as part of the positive strategy for the conservation and enjoyment of the historic environment required by paragraph 185 of the National Planning Policy Framework.
Historic England welcomes and supports clauses 1 c and 2 e of Policy DM5 as part of the positive strategy for the conservation and enjoyment of the historic environment required by paragraph 185 of the National Planning Policy Framework.
Historic England welcomes, in principle, clause 2 of Policy DM13 but considers that the policy should be, in the first instance, to avoid adverse impact on the historic environment as part of the positive strategy for the conservation and enjoyment of the historic environment required by paragraph 185 of the National Planning Policy Framework. We consider that the wording used in Policies DM3 and DM5 would be appropriate.
Reword clause 2 of Policy DM13 as:
"Is located so as not compromise the essential features of nationally designated areas of landscape, historic environment or nature conservation protection".
Historic England welcomes and supports clause 1 of Policy DM17 as part of the positive strategy for the conservation and enjoyment of the historic environment required by paragraph 185 of the National Planning Policy Framework.
Historic England welcomes and supports clause b of Policy DM20 as part of the positive strategy for the conservation and enjoyment of the historic environment required by paragraph 185 of the National Planning Policy Framework.
Historic England welcomes and supports paragraph 7.129 as part of the positive strategy for the conservation and enjoyment of the historic environment required by paragraph 185 of the National Planning Policy Framework.
Many farm buildings that are now redundant for modern farming needs are likely to be of historic interest - it is acknowledged that farm buildings are generally under-represented on the National Heritage List for England. Historic England considers that Policy DM21 should include stronger protection for such buildings as part of the positive strategy for the conservation and enjoyment of the historic environment required by paragraph 185 of the National Planning Policy Framework.
Add a new criterion to Policy DM21 as follows:

"Features of architectural or historic significance are retained and, where the building forms part of a historically significant complex of buildings, consideration is given to the future use(s) of those buildings and the impact of the proposal on the integrity and character of the complex".
Historic England welcomes and supports, in principle, paragraphs 7.154 - 7.161.
However, we consider that paragraph 7.154 should be reworded to clarify the distinction between designated and non-designated heritage assets (the latter including buildings on the Local Buildings List for Chichester).
Reword paragraph 7.154 as follows:
"There are a large number of "Heritage Assets" (as defined in the National Planning Policy Framework), both designated and non-designated, in the plan area. Designated assets are Listed Buildings, Scheduled Monuments, Conservation Areas and Registered Historic Parks and Gardens. Non-designated assets include archaeological sites (although the remains may be of national significance equivalent to scheduled monuments, and which should be considered subject to the policies for scheduled monuments) and non-listed buildings which have been identified as locally important, such as those on the Local Buildings List for Chichester City and 'positive' buildings within Conservation Areas."
Historic England welcomes and supports in principle, Policy DM27 both as part of the positive strategy for the conservation and enjoyment of the historic environment as required by paragraph 185 of the National Planning Policy Framework and also as a non-strategic policy for the conservation and enhancement of the historic environment as suggested by paragraph 28 of the Framework.
However, we consider that clause e. should specify the (wholly) exceptional circumstances in which permission for a proposed development that would lead to substantial harm to (or total loss of significance of) a designated heritage asset would be granted i.e. where it can be demonstrated that the substantial harm or total loss is necessary to achieve substantial public benefits that outweigh that harm or loss, or all of the circumstances in paragraph 195 of the National Planning Policy Framework apply.

We would also welcome the policy being more detailed in terms of the considerations to be taken into account when assessing development proposals affecting the different types of heritage asset, as do, for example, Policies EH10, EH11, EH14 and EH15 of the West Oxfordshire Local Plan 2031. These policies were developed with Historic England and the Inspector that examined the Local Plan 2031 shared our concern that the historic environment policy in the Local Plan 2031 provided inadequate locally specific detailed policy guidance and considered the more detailed policies necessary for the Plan to be sound.

(However, we do acknowledge that the Inspector that examined the Key Policies development plan document considered the modified historic environment policy (Policy 47) put forward by the Council with our support was sufficient for the Plan to be sound, and that Policy DM27 in the Local Plan Review very largely repeats Policy 47).

Reword clause e. of Policy DM27 as follows;
"Development involving substantial harm to or loss of designated heritage assets will
only be granted in exceptional circumstances (wholly exceptional circumstances for
designated assets of the highest significance) i.e. where it can be demonstrated that the substantial harm or total loss is necessary to achieve substantial public benefits that outweigh that harm or loss, or all of the circumstances in paragraph 195 of the National Planning Policy Framework apply.

More details of the considerations to be taken into account when assessing development proposals affecting the different types of heritage asset. We would be pleased to work with the Council on a revised policy or policies.

Paragraph 7.195 of the Plan notes that the remnants of canals "are important early 19th Century historic features in the landscape of the coastal plain and warrant protection".
Historic England agrees with this statement, but Policy DM33 makes no mention of protecting the historic significance of the remaining canal sections.
Reword the first paragraph of Policy DM33 as follows;
"Development that makes provision of through navigation or enhancement of the Chichester Ship Canal and the Wey and Arun Canal will be supported where it meets environmental, ecological, historical and transport considerations."
Historic England welcomes and supports clause 3 of Policy DM34 as part of the positive strategy for the conservation and enjoyment of the historic environment required by paragraph 185 of the National Planning Policy Framework.

Introduction
I agree with most of the points made in the Introduction, not least the points about affordable housing, (para 2.9) for which there is a clear demand and inherent because of the 0.75%pa rise in population and the yawning gap between incomes and house prices.
I will acknowledge that I am writing as a baby boomer, but I note the above average presence of senior citizens in the CDC area and your anticipation that it will rise to 35% by 2015 (para 2.8). This surely has implications for the facilities that CDC, and probably more so WSCC because of its responsibilities for social care, will need to provide, and I do not notice any focus on this in your introductory section. In fairness I am slightly more encouraged when I read paragraph 3.19
I would also ask how many of the young people educated in the area return here to live and work after qualifying. And if the number is low, why, and what do you propose to do to ameliorate the haemorrhage?
Spatial Vision and Strategic Objectives
I agree with your list of items in paragraph 3.2. That said, I note that you state that people should be able to "move around safely and conveniently with opportunities to choose alternatives to car travel (my emphasis). This surely has major implications for public transport, for walking, and for cycling, and surely these should be highlighted in this introductory summary. I shall look forward to seeing what you have to say about these later in the document.
I agree with paragraph 3.3 - but what do you mean by your hope to "balance the ageing population"? That could sound horribly ominous!
In para 3.4 I understand the wish to diversify the local economy - but where are these new organisations to go? You talk about "new sustainable neighbourhoods on the eastern, western and southern sides of Chichester, which could, especially when one thinks of Whitehouse Farm, appear to presage a level of growth which will frighten many. I think that the example of Summersdale, where I live, does not bode entirely well, for it is largely devoid of any community centres and has no public transport in the evenings.
In para 3.6 you speak of a "highly accessible transit corridor" Do you really mean this, says he thinking of the state of Chichester by-pass, the queues that I see coming east on to the Fishbourne roundabout in the morning, and the rush-hour queues from Bognor? Perhaps I could add what the all too predictable impact of Whitehouse Farm will be on both the Fishbourne roundabout and the Northgate gyratory.
Re para 3.10, my understanding is that rather more than "moderate levels of growth" are proposed between Fishbourne and Southbourne, and I shudder at the impact on the A259, all the more so when I think of all that traffic passing through the narrow main road at Fishbourne and also coming out on to what is already a very dangerous Fishbourne roundabout, which I do my best to avoid now!
Turning to paragraph 3.19 I welcome, amongst the other points you make there, the references to affordable housing, to air quality, to the section on health and well-being, and (at a time of fears about global warming) to the reference to flood risk.
Spatial Strategy
I welcome the list of services and facilities mentioned in paragraph 4.12, as that most certainly is not the case in present-day Summersdale.
In fairness I recognise the increased demand for housing as mentioned in para 4.22, as this is inherent in an area of rising population and probably more single-person households (which I have not seen mentioned). I suspect, for instance, that I am far from alone in living singly since bereavement in the family house where I have lived for forty years and from which I have no plans to move. That said, enormous care will be needed in selecting the areas for expansion and the implications for infrastructure and community buildings. Moreover you are clearly right in para 4.30 to refer to longer term growth.
You are clearly right to talking of "meeting the housing needs of the plan area and tackling homelessness" in para 4.34. In all honesty I was appalled when I saw the numbers of people sleeping out late a night when I happened to walk home at a late hour last March. I did not think that such an inhuman state of affairs obtained in Chichester, and am horrified that it still apparently does. I strongly agree with paragraphs 4.43 and 4.44. I welcome the policy statement S6, even if I think that we really need is a return to council house building, as was used to solve even worse problems in the decades after 1945.
Re para 4.66 I have very mixed feelings. It has pleased me not to see the extent of boarded up properties that one sees elsewhere. That said:-
* I write as one who detests shopping and does very little within Chichester city centre; I probably use only about half a dozen shops and those only occasionally.
* I know that my wife always preferred to go to Worthing and can think of a friend who prefers Southampton.
* I think that you have to recognise as a fact of life that more people are going to shop on-line, not least for reasons of price, and that that inherently impacts on traditional retail shopping.
* I tend to do my shopping on the edge of town as that is where the big supermarkets are and parking is easy. I would take some persuasion to change that.
* Looking at policy S9, do you really need more shipping in the Southern Gateway at a time of decline of town centre retail shopping?
Providing Supporting Infrastructure and Services
Paragraph 4.80 should also include cycle tracks and bus routes if you really want to move away from the use of private cars.
I note that paragraph 4.81 includes a reference to "appropriate revenue support". I fully agree and wish that I could believe that this present austerity-obsessed government would actually provide it.
Your policy S12 seems right to me.
East-West Corridor
I think that you are somewhat optimistic in paragraph 4.88. The 700 bus service is very good, but what about other routes, especially in the evening? The present state of the Chichester by-pass is dreadful, and the Fishbourne roundabout is a particular source of danger, moreover one likely to be made worse by more traffic coming from Whitehouse Farm and from further development along the A259.
Policy S13 seems fine to me.
Paragraphs 4.95-98 describe a situation that I know only too well. I would add that as a cyclist I find the western end of The Hornet and St Pancras to be by far the most dangerous pieces of road in Chichester, and I write as one who usually does not mind where he cycles.
I do not agree with paragraph 4.101 - I think that a park and ride is badly needed, arguably from both the west and the south.
Re policy S.14:-
* Re peripheral car parks, if you want to revive the city centre, is that really the answer? What about those who find walking difficult or who do not want to carry heavy shopping half a mile to their car?
* I shudder what the queues will be like with a bus lane up to the Bognor roundabout.
* I think that the present bus/rail interchange is quite good, though I think that you need safer crossing of the road and seats in the bus station
* I do not notice any statement about solving the problems caused by the level crossings by Chichester Station. Having had to wait there for over five minutes yesterday while a train was sitting in Chichester Station I feel bound to ask whether there cannot be some mechanism to bring the gates down just before a train is due to leave, and when you are going to have either a bridge or an underpass there.
Re paragraphs 4.103-105, wshat consideration has been given to the transport consequences of such development, especially given the absurd decision to remove the Oving lights?
Given that I live in Maplehurst road, you will not be surprised that I have noted policy S15. Essentially I welcome this policy, not least, as having some pretentions to being a musician, I am very aware of noise, and the weekends where un-silenced racing is allowed are truly a misery, which ideally would be stopped as unbelievably selfish and insensitive and at very least should not be allowed to expand beyond the one such meeting per year. In fairness the banks erected some years ago have made a difference, and for the most part aircraft do behave themselves. I also think that any housing development closer to Goodwood Airfield should be out of the question, as the noise would be intolerable to anyone with normal hearing. In policy S16, point 2 I think that un-silenced racing should not be allowed despite their loss of amenity, as the consequent noise is not reasonable.
Re paragraphs 4.111-115, what do you think is going to be the impact of 1600 new houses in that area - to amenity and the rural aspect; to the A259; to traffic through Fishbourne; and the already dangerous Fishbourne roundabout? I think that the scale of this development is highly questionable for these reasons.
Strategic Policies
Looking at policy S20, I agree with all the points that you make. I would add:-
* The need for a public transport system that does not stop in the evening, and
* The need for good bicycle access. When I think that at least twice a promised access to Centurion Way has not been delivered, I think it fair to make that point, especially if you really do want to get people out of their cars.
Re paragraph 5.16 I find it sad that you do not mention in your strategic corridors that the cycle track adjacent to the A259 going west from Chichester is part of cycle route NCN2.
Re paragraph 5.22 our roads are going to be even more over capacity with significantly more housing development. I have already referred several times to my concerns over the dangerous Fishbourne roundabout.
Re paragraph 5.27 I welcome the interest in cycling provision. Living in Summersdale it takes me less than ten minutes to cycle into the city centre - in fact by far the quickest way I can get there. For the most part it is safe, I think, but with the glaring exception of the Northgate gyratory. Whoever designed that clearly forgot that a cyclist is at his/her most risk when pulling away, so to expect cyclists to stop at each exit is a massive deterrent. This cyclist prefers not to use the cycle lane in order to have safer crossing at each exit. I find the St Pauls Road exist especially dangerous. I would also like to have paint markings on the raised kerbs at each exit for safety in the dark.
More generally, if you are in the Low Countries, it is exceptional for cyclists can have two way traffic in what it is a one-way street for motorists - I have seen so many no-entry signs there with "uitgezonderd fietser" below. In fairness there is some of this in Chichester, but I think that there is scope for more.
I also think that Chichester centre needs increased provision for cycle parking, for instance adjacent to the Little London car park, where there is plenty of potential space, and at the eastern end of East Street, where I find the present racks often to be full.
I would also like you to think how cyclists can be safer at the western ends of The Hornet and St Pancras, which are the two roads in Chichester which make me feel very chary.
With the additions of the points made in the previous paragraphs and also restating a need for evening bus services, I generally support the points made in policy S23, though I would repeat what I have already said about expecting people to park too far away from the city centre if you really want people to come there, and I would extend this point by saying that if you are going for distant parking, a park and ride becomes essential. I am agnostic about the Birdham Road to Fisbourne proposal, as I do not know enough about it to comment.
Re policy S24 I would make a particular plea for the Lavant Gap, which is important both to Lavant and Summersdale especially as an important part of our amenity. And we did not fight to save it to have a northern by-pass trundling through there!
I agree with policy S27 and would add that I can remember the floods some fifteen years ago and looking out at the River Lavant east of Maplehurst Road to see how far the waters were going to spread. That too me (besides proximity to Goodwood) would be a major factor in my opposing any development there. I am aware that the Pagham Rife project subsequently ameliorated the risk, but I still think that it needs to be borne in mind, especially given the impact of global warming.
I agree with policies S28 29, 30, and 31. I would make a particular point of air and noise pollution.
Strategic Site Allocations
I agree with policy S32,
How can you write paragraph 6.8? You will know as well as I do that cycling links are not good, and will be worse if Centurion Way is to be diverted. Also how are cyclists supposed to get into the city from the northern end of Whitehouse Farm - down St Paul's Road and coming on to the Northgate Gyratory (which will also be receiving significantly more motor traffic? Please!! I hope that you also know that the plans could well include a really dangerous junction on Centurion Way that is the entrance from Bishop Luffa Close.
As for motor traffic, the same point about St Paul's Road applies. And as for the southern end, surely you know what that is going to do to local roundabouts, not least the dreadful Fishbourne roundabout?
In terms of recreational disturbance, (para 6.12) why is there no reference to Centurion Way?
The points above all are relevant to policy AL1.
Re policy AL2 I do not know enough to comment in much detail. That said, I am concerned about transport access. I know that I am not alone in detesting coming up to the Bognor roundabout from Bognor and often prefer the safer route via the Oving traffic lights. Has any account been made of how such traffic, which is not inconsiderable will be affected, and how this will make the journey from Bognor to Chichester significantly worse than it presently is?
Re policy AL5 I accept the case for redevelopment, though was far from impressed with the last proposal I saw and commented on at the time; I thought, and still think, that the road alternations then proposed were insane and asking for more rather than less jams. I welcome the references to access for cyclists and pedestrian. I am not clear when there are references to the bus depot as to whether that includes the bus station. If you want people to come to Chichester centre, bus access needs to be close; moreover the present bus station is properly close to the railway station, which is important for integrated travel. I do not see any reference to taking away the present crossing gates, which are a serious impediment to traffic at the moment, both on Stockbridge and Basin Road; I think that that is a bad omission.
Re policy AL9 I lack the detailed knowledge usefully to comment, but would ask how far the present state of the A259 has been borne in mind in planning both in Fishbourne and further west from Chichester. It is narrow and at times congested now - major development can only exacerbate such problems.
Re policy AL10 I can comment only as one who fairly often cycles east-west along the A259. The exit from the cycle track on the southern side of the A259 to the east side of Chidham is presently dangerous because of the road layout and the warning sign about cyclists being several; yards too late and often obscured by foliage. Where there is a cycle track in Chidham, parking on that track is not uncommon. There is also a significant gap in the cycle track through much of Chidham. Moreover this is part of a national cycling route, and will become even more significant with more development in Chidham and points west.
Re policies AL11 and AL12 please bear in mind the need for cycle access and for the proposed cycle track between Chichester and Selsey (via Hunston) to develop, especially if you really mean to develop non-motor transport (and also as a valuable and healthy amenity) and bearing in mind how dangerous the B2145 is.
Re policy AL13 cycling provision to the west of the roundabout presently is reasonable; it is not good west of the roundabout. My comments about NCN2 refer here too.
Development Management
I am especially pleased to see paragraphs 7.2, 7.4, 7.6, and 7.8, as with an ageing population and baby bookers such as me passing 80 within ten years or so, increased specialist provision is inevitably going to be necessary. This is not to downplay other specific groups, eg students - I simply write from an area of specific knowledge. I agree with policy DM1.
The principles behind policy DM2 seem right to me and I am pleased to see recognition of the need for affordable housing. I would make specific reference to resolving homelessness, young families with not much money, and people in the twenties moving to a new area to start work.
I agree with what you are saying in policy DM8. I have raised my concerns about such issues as cycling routes, bus services, parking and the impact on existing crowded and/ or dangerous routes earlier in this response.
I can see why you are seeking to protect the city centre and prevent an excessive dominance of out of town areas, all the more so as I have seen this in the USA. That said, I find shopping on the edge of town a lot easier -things are in the same place; parking is easier; prices tend to be better. And how far are you crying for the moon as on-line shopping takes off? I for one would take a lot of persuasion to do much shopping in a city centre especially with poor parking. So, while I accept most of what you say in policy DM12, it is with this big proviso.
I agree with policies DM13 and DM14.
I think that any new building should have to incorporate solar panels (re policy DM16). I know how much electricity my solar panels have saved me, and, were I younger and further solar installation not so expensive (it would take me more than a decade to get my money back) I would seriously consider more to provide solar energy for heating and electricity storage.
We are now so aware of air quality issues that I am very pleased to see policy DM24. I also agree with policy DM25 and would add that this should be a significant issue (because of the noise pollution emanating from Goodwood) for any development east of Maplehurst Road.
Re policy DM33, last time I was there I thought that the canal towpath was very dangerous at the western end, particularly for anyone trying to ride a bicycle there.
My apologies but I do not know enough about the later policies usefully to comment.

Summary
In case it helps for me to summarise what I have been seeking to say:-
* As a cyclist I have inevitably had a lot to say about present inadequacies in the network. These need remedy if you really want people to get their bikes out in a city that is made for cycling and feel safe in so doing. Moreover there are the clear health and pollution gains from more cycling, and it is actually often the quickest way from a resident anywhere in the city to get into the centre.
* Housing is important - to resolve homelessness; to provide affordable housing; to meet the needs of young families with not much money or young singles moving here to begin a job/ career.
* There are particular issues re an ageing population and the increased needs are so predictable now even if perhaps not immediate.
* If you really want people on buses, fares have to be lower so that they are competitive with the marginal cost of a car journey for a family, which they are not at present. Services need to be good and to include the evenings.
* I think that there is a danger of Canute tendencies re retail when I think of the attractions of edge of city shopping let alone on-line trading.
* This is linked with car parking - reasonably central car parking and/or a park and ride are crucial if you really want to maintain/expand the city centre.
* The present situation over the level crossing is unacceptable.
* The Fishbourne roundabout is unacceptably dangerous, and the present "by-pass" is a denial of your hopes of an easy east-west transit.
* I am pleased to see the sections on air and noise pollution, and also the encouragement of solar electricity, and I hope that these will really mean something

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