Transport Infrastructure

Paragraph 5.22 states that 'Furthermore, the A27 and many local roads are often significantly over capacity.'

There is no evidence that the A27 as a road is over capacity. Within previous reviews by HE, Atkins and others no conclusion was ever drawn that the road was over capacity. The reports all concluded that the junctions were over capacity but the road itself has adequate capacity.

The recent Peter Brett report again makes reference to junction capacity but NOT to road capacity.

This is a clear difference and the wording of para 5.22 is misleading.

Your system for lodging detailed comments is just too complex. So in summary the plan talks about congested rural roads and such phrases as discouraging HGV's there but the plan to build hundreds and maybe thousands more houses on the Manhood Peninsula does not represent these points.
Highways West Sussex have no mechanism to look at the combined effect of multiple sites.
See uploaded document for more comprehensive argument.

With reference to park and ride sites for Chichester: would a more sustainable alternative be to enhance bus service frequencies, perhaps with new peak-time only routes?

The proposed changes to the A27 junction, in particular preventing right turns will essentially cut off the manhood peninsular and cause huge tailbacks at the other junctions as traffic is forced to double back on itself.

I am not supportive of the practicality of the proposed relief road. Aside from the environmental Impact, and destruction of iconic views of the cathedral I believe that the increased burden on the Fishbourne roundabout will make the scheme unviable.

The residents of Chichester opposed these changes (or at least very similar changes) last year, and I cannot believe that they are being proposed again.

5.24 At a meeting of the Council in June 2018, it was resolved that in the event of a future opportunity to apply for central government funding for new road schemes becoming available, support is given to a northern alignment for the A27 as a PREFERRED OPTION ..
It is stated that this decision was made after a LONG PROCESS OF LISTENING to the views of the community, attending the Build a Better A27 group meetings and considering the views of SYSTRA and select committee.

I am very concerned about the impact of these proposals on the transport infrastructure in Southbourne particularly. Currently the roads around the railway crossing in Southbourne are gridlocked on a daily basis (at the time of schools starting and finishing, much more so than at 'rush hour' when traffic is far lighter). With the degree of expansion of housing proposed in this area there is likely to be a significant impact around the railway crossing with likely increased pollution as a result of stationary cars in traffic. How much has the traffic been assessed at this site at around 9am and 3.15pm? Assessing the traffic at 5pm for instance would give an entirely false picture of how the road is used. The current infrastructure would not cope with a significant increase in traffic and I can't see evidence of this being addressed.

There is also likely to be a very significant knock-on effect in Westbourne village in terms of traffic as this is the quickest way to drive to Havant from Southbourne. The traffic situation through Westbourne is already really quite dangerous at key times and at two points traffic is unable to flow in both directions. Increasing the traffic that flows through Westbourne from Southbourne would be a real concern,

5.19. : Pollution from cars is much worse when the traffic is stationary. 12,390 additional houses will add to the already overloaded A27. Any roadworks designed to mitigate this will make the situation ten times worse during the construction phase. That is why the Northern route should be done first as it would alleviate a lot of the current pressure and provide a diversion for later improvements to the existing road.

This is a large document, so perhaps I have missed this part: What is the policy regarding asking Network Rail to invest in 21st Century signalling systems to improve delays at the Level Crossings in Chichester. These cause unacceptable delays to traffic, and works on the A27,and the resulting changes to some of the existing roundabouts will send more local traffic into the town, making these delays worse than they are now.

The emphasis on sustainable transport is not borne out in practice. 5.16 and 5.17 must specifically support cycle routes within the city and build more, they must protect national cycle route 2 and Centurion Way, and enhance these routes to make them safe for people to use.

It is very nice to include what should be done to A27 junctions but this cannot and should not be included in the plan as nothing has been decided. Infact it is all very much undecided.HE have not been consulted/or given an opinion in this plan, therefore there is no funding for any route . Unless this is adequately addressed in future iterations of the plan, i will raise this with the examiner at the appropriate time.

Para 5.19. Has the PBA Transport Assessment (App G) appropriately taken into account, in its Air Quality and Emissions assumptions, enhanced peak time and traffic light controlled junction congestion which will reduce LGV and HGV movement along the A27 and within the City (note App E references "average drive cycles" and at p54/55 ref to speeds of 50kph) as well as the rate at which emissions from LGVs (approx 15% and increasing proportion of total traffic), as opposed to Light Duty Vehicles, will improve given lack of substantive Government actions and limited grid capacity to support Goods and other commercial Vehicle recharging points within the Plan period? Note it is not clear that assumptions regarding non fuel particulate arisings from vehicle movement have taken into account overall increase in volume of traffic.

Para 5.30. Given estimated scale of cost of the proposed A27 by-pass works will be beyond that obtainable via S106/S278 Agreements and those works are viewed as a critical priority, does this mean that the new Local Plan could fail the viability tests in NPPF paras 34 and 57? It also appears that as the NPPF requires a five year Local Plan review cycle, the proposed mitigation scheme for this LPR will be superceded before it is built as will any subsequent iteration of on-line mitigation schemes. This is likely to result in either nothing being built, or anything that is being replaced in a short timescale which would represent very poor value for money.

Overall it appears that the most appropriate long term strategic solution to the inadequate performance of the strategic and local road networks at Chichester is for there to be a Northern by-pass. If the Council's preferred scheme to resolve the issues associated with the A27 at Chichester is for it to be re-aligned to the North of the City (with the necessary environmental mitigation), then the supporting text for Policy S23 and the Policy itself would need to make clear that that is its primary aim and that the proposed on-line mitigation scheme is only put forward as a backstop. Any subsequent works to the existing line of the A27 to mitigate the effects of further development in the longer term would then be viable and hence deliverable via S106/S278 Agreements. A Northern re-alignment of the A27 would also considerably ease the transport and related environmental issues and pressures within the City and support the aims of Policies S13 and S14 and those Polices supporting text.

Line 2 (in printed doc.) - delete second "be" and after "S278" insert "Agreements" for clarity.

5.31. What (Local Plan) status will envisaged (in previous LP) changes to Northgate gyratory and Westhampnett Road (St James Rd and Spitalfield lane junctions) now have?

Fishbourne roundabout should be grade separated before any new development which uses the A259 to reach Chichester is approved. This is because both Highways England and West Sussex County Council in their preferred options for A27 improvements have identified that grade separation at Fishbourne roundabout is required to meet future demands.

In the traffic study supporting the Local Plan Review there are no comparisons between the traffic and delays which are experienced now with what is forecast for 2035 which is the forecast year in the study to evaluate the impacts of the proposed developments and traffic mitigations.

The transport study improvements and mitigation are claimed to resolve capacity issues. It is not known if this is only achieved through increased rat running through the local area including Fishbourne residential streets (Salthill Road in particular) compared with the existing situation, i.e if it is assumed in the traffic model that there is rat running taking traffic away from the A27 junctions especially Fishbourne Roundabout which reduces the need for improvements at Fishbourne Roundabout.

The at grade improvements identified in the local plan review are clearly inadequate as evidenced by the detailed traffic assessments carried out by Highways England and their consultants and West Sussex County Council and their consultants.

5.16- The A27 is the only Strategic Route on the South Coast between Folkestone and Honiton. It is also Chichester residents' local distributor road. This means that the local traffic mixes with 48% through traffic of which a large proportion are HGV vehicles between the major ports of Southampton, Portsmouth and Dover. Chichester's section of the A27 is the only part of the Strategic Route without a diversionary route, so if there is an accident on it there is no alternative route for the through traffic, the local traffic and the visiting tourists, meaning Chichester City, the East West Corridor and the Manhood become gridlocked. According to West Sussex County Council's records of reported accidents on this stretch of the A27 between Portfield and Fishbourne Roundabouts during the 5 years period of 1/12/13- 20/11/18 there were 2 fatalities/26 serious accidents/170 slight accidents- that is on average 39.5 accidents annually on this stretch of the A27 alone.

5.18 Bearing the above point in mind how do CDC go about "discouraging HGVs from using unsuitable roads" considering the fact that the A27 at Chichester according to DFT is the third worst congested road after two stretches of the M25?

5.19 The Manhood Peninsula has major congestion issues when joining the 48% through traffic on the A27 but this has been brushed aside in the statement. A27 at Chichester is described as a bypass: this is no longer correct terminology, as all the development over the years around it has made it a local road in addition to a through road. The only access route by vehicle off/onto the Manhood Peninsula, 26,000 residents at last count, Selsey's population of 11,000 doubles in size during the high season which PBA have not modelled. Add to these numbers the 1,933 proposed developments on the Manhood Peninsula, and it follows that the road infrastructure will not cope and the transport mitigation plans will barely deal with the problem in the long term.

5.31 There are three access points onto the Manhood Peninsula from the A27 they are at 1. Bognor/Vinnetrow Road roundabout connecting onto the B2166, 2.Whyke roundabout connecting to the B2166 to Pagham or B2145 to Selsey and 3. Stockbridge roundabout connecting onto the (i)A286 to East Witterings or via the (ii) B2201 to connect with the B2145. In high season all these access points and roads are gridlocked and unable to cope with the sheer numbers of visitors to the beach areas in addition to residents. When there is an accident on any of these routes chaos ensues as diversionary routes are flooded with rat running all over the Manhood. Accidents on these roads are a regular occurrence, between 1/12/13-30/11/18:
1. B2166 from B215 to Pagham A259 (Via Mundham) 0 Fatal /18 Serious/ 71 Slight
2. B2145 from Whyke to Selsey via Hunston 1 Fatal/ 11 Serious/ 68 Slight
3. (i) A286 Stockbridge to East Witterings 3 Fatal/ 8 Serious /23 slight
(ii)B2201 from Stockbridge via Donnington Village to Selsey 4 Serious/ 12 Slight

CDC are correct in their 5.19 statement that accidents cause "knock on effects in terms of delays and diversion onto less suitable roads, and road safety issues." but these issues aren't just within Chichester City, they also affect the Manhood Peninsula and beyond.

Peter Bretts designs are not the answer as they do more to cause further congestion on the Manhood and increase Air pollution than solve it.

(1)Changes to the Bognor/Vinnetrow roundabout- closing the Vinnetrow junction and placing it on the A259 Bognor Road. The Bognor Road is always congested as it is the main road from Bognor to the A27. This will send the Pagham, Runcton and North Mundham west bound traffic to queue to join the Bognor traffic then queue to access the A27 at the Bognor roundabout giving way to the East bound A27 traffic and blocking the west bound A27 traffic (48,000 vehicle movements daily). Alternatively send the East and West B2166 traffic either to Whyke (with no right hand turns) via the congested Free School area to travel via the A27 to the heavily congested, accident prone Fishbourne roundabout.

(2) Restricting access by no right hand turns at Whyke for traffic travelling west will send traffic bound for the B2145 and B2166 heading to Hunston and Selsey will go through the traffic light controlled Bognor roundabout then go back on itself to Whyke or when they get to Whyke they will turn left up the Whyke Road and execute a U-turn and go back to cross the A27. The intention To use the link road as means of approaching the Free School or Pagham or Hunston will be so cumbersome that few will use it. The other alternative will be for this traffic to turn left at Stockbridge and go through Kingsham and turn right onto the Whyke road and cross the A27. For traffic coming from the East will be obliged to leave the A27 at the Bognor roundabout to make their way across the city adding to the congestion rather than reducing it.

(3) Restricting access by no right hand turns at Stockbridge will cause traffic coming from the West will be obliged to leave the A27 at Fishbourne and cross most of the City to then cross south at Stockbridge and head for Selsey. Traffic from the East wanting to turn right will have either already done so at Bognor roundabout or will do so at Fishbourne: in both cases they will be adding to congestion in the City.

All these manoeuvres will be the chosen route for many when the A27 is blocked by traffic lights at four successive junctions.

Accidents on the Fishbourne roundabout over the past 5 years which have been reported are 7 Serious 41 Slight, the congestion on this roundabout is on daily traffic reports. The A259 East Corridor is having 3,050 new homes built with no new access point onto the A27 at Southbourne. The majority of this traffic will access the A27 at the Fishbourne Roundabout giving way to the City, A27 eastbound and westbound traffic and Stockbridge Link road traffic. Add to this city traffic the 1,600 extra homes and business park at AL1 this whole design is recipe for disaster. It will shift the current AQMA at Stockbridge right along to Fishbourne and the AONB.

Peter Bretts recycled designs have been publicly consulted on on several occasions over some years now and have been roundly rejected each time. As agreed by a clear majority consensus at the BABA27 workshops, what is needed is to separate 48% through traffic from local via a proper bypass to the North.

The two major issues of concern in the mitigation proposals are one the new traffic light controlled crossing of Via Ravenna and Terminus Road which will merely move the traffic jam from the Fishbourne Roundabout to the crossing. Two the A286 and Wophams Lane junction which is a narrow windy country lane presenting very dangerous junctions with the B2201 Selsey Road junction and at junction with the A286. This was sadly epitomised on Saturday 2/2/19 in a fatal accident which led to hours of chaos on roads as far south as Earnley and beyond.

The Peter Brett recycled concepts have been publicly consulted on on several occasions and have been roundly rejected each time. As agreed by a clear majority consensus at the BABA27 workshops, what is needed is to separate 48% through traffic from local via a proper bypass to the North. This will bring the current A27 back to 1990 levels and would mean its capacity will continue well after 2035 and the proposed housing in this plan. Wasting money on this short term fix which doesn't actually solve anything but makes congestion and air quality worse leading to a huge waste of money.

Please include names of some of the important cycle paths referred to at the end of section 5.16
In particular Centurion Way (National Cycle Route 88), Salterns Way, Chichester to Bognor Regis (National Cycle Route 2) and Chichester to Emsworth (National Cycle Route 2)

Given the projections for an increasingly ageing population is a strategy built around the promotion of increased cycling and walking viable in the long term? Similarly, integrated transport systems are to be applauded except that the provision of real-time travel information, upon which the efficiency of such integration depends, relies upon easy internet access through the use of smartphones, thus disadvantaging anyone who either does not have one or who does not feel confident in using same.

Any 'improvements' to the A27 must be done sympathetically with an overarching regard to the quality of life of those residents who live near to the road itself.

Access roads to the Manhood peninsula are already stretched to capacity at most times of the day. During the Summer the A286 to the Witterings is frequently completely blocked as far as the Stockbridge roundabout.

Until a serious plan has been implemented to cope with the existing traffic volumes it would be bordering on total incompetence by the planning authorities to allow construction of any further properties.

The A27 bypass issue should be resolved before any further development takes place.
Local residents funded the study for the seven options that were part of the exercise to address the bypass congestion. We have only seen details of five of these options, all of which have so far been rejected.

This is because local residents all know that by far the best, least cost, and fastest option would be a northern route road

5.16 .'..and the strategic road link between Havant and Eastbourne'
-it is the strategic road link connecting the south with the major south coast ports of Portsmouth and Southampton (major reasons for the HGV volume experienced).
- it is also a local road with long distance and local traffic competing for space.
5.18 ....'discouraging HGVs from using unsuitable roads': the Link Road combined with turning restrictions on the A27 will bring about the opposite.
5.27 behavioural change : Mott McDonald and SYSTRA consider effects on congestion, air quality, travel times, accident rates marginal
5.29 P&R benefits marginal (Mott McDonald and SYSTRA)

This rightfully acknowledges need for integrated transport and making smarter choices for new development. Use of initiatives such as the regular bus service to Graylingwell, paid for by the developer, will only work if car use is properly discouraged by providing the bare minimum of parking spaces and banning on-street parking thus making the bus the sensible option, there is no evidence of this in the policy.

Highways England's rejection of the locally-proposed northern route for the A27 needs to be challenged. Rejection was undoubtedly owing to their 'not invented here syndrome', A northern route is the only one which will provide a long term solution beyond 2035. The proposed improvements to the existing A27 in the Local Plan are only sticking plaster solutions. The addition of signals to the Stockbridge Roundabout will improve the lot of those trying to cross it, but the abolition of right turns from the A286 will be a great inconvenience
Make bus use the sensible option by restricting car parking in new developments. Continue to press for a northern option for the A27

We wish to raise our OBJECTION to the Local Plan under consultation at this present time.
The Plan is fundamentally flawed. To be able to comment and analyse the plan correctly, there is one glaring fault which makes the plan invalidate. The transport model used for the plan is the Peter Brett Assoc report of 2010. This PBA consultation has been proved to be incorrect when issued and has not been changed so it is now incorrect and woefully outdated. You cannot produce a plan that has no up to date valid transport infrastructure/data included in it.
Furthermore, you have included a link road and development in AL6 Apuldram/Donnington which cannot be included as there is no funding for it or the upgrade of junctions that would be required at Fishbourne roundabout and there is no evidence that the correct and proper consultation with Highways England has taken place.
For a Local Plan to exclude all development however small in the North of the city is an unfair and makes the rest of the plan a nonsense and smacks of undue influence from certain quarters. To state that the SDNP means that no development can take place because of its special status is absurd. Chichester Harbour has the same protected status as an AONB, SSI, SAR etc and yet you are happy to include plans to concrete within 100mtrs of it. The SDNP is at least 1km from any area that was identified in previous drafts of this report and then mysteriously removed !!
This Local plan is full of inconsistencies and contradictions, with very little details on how mitigation would take place for these vast developments planned along with very vague lip service to how the infrastructure of Schools, doctors and other such services are going to be implemented or funded, or if in many cases like Graylingwell, who were promised a school, put in at planning and then ignored.
Therefore we wish to OBJECT to the plan and will seeking to raise our concerns with the examiner at the appropriate time if these failings are not addressed

The Council should not be proposing changes to the A27 until the outcome of discussions with the Highways Agency is known.
The changes proposed are similar to those in the Highways Agency consultation which were rejected by the residents. It is not appropriate for the Council to implement them.
Many of these changes are of limited benefit and will force traffic onto local streets if access to the A27 is restricted on the junctions at Stockbridge and Wyke.
The proposal to build a new link road across the floodplain through an AONB, ruining the views of the Cathedral is appalling.

I am writing to Object to CDC Local Plan. The Plan as it stands , is not a Local Plan. It is a plan to destroy large areas of Chichester's historic and environmentally sensitive areas in the South, east and west,whilst leaving the Northern part of the city completely untouched. Chichester Harbour has the same protection afforded to as the SDNP and yet there has been absolute no regard to its preservation. In fact that exact opposite. The plan aims to build on the flood plain and right up to the Chichester Harbour boundary with no viable detail or acknowledgement of just how destructive this would be. The inclusion of AL6 Apuldram/Donnington link road and proposed development is tanter mount to vandalism of the highest degree and I am appalled that it is even being considered. The fact that there is no detail or consultation within the document to show the required consultation with Highways England that should have taken place prior to it's inclusion just shows what an inaccurate and shoddy piece of work this plan is. AL6 is on a category 3 Flood Plain that according the Governments own recommendations should never be built on because of the environmental damage that can ensue, never mind the risk to flooding of any buildings on such a site. The suggested link road would have to be raised to at least 4 mtrs in order to alleviate the risk of flooding this would then lead to a complete eyesore and desecration of historic views of the Cathedral from the sea (the only one in England ) towards the Downs, something that the Local Plan states must be protected at all cost. There is no mention of the increased traffic, air pollution, noise and light pollution that such a development would cause. Councillor Dignum has lied, " NOT...embracing any 2016 options for the A27", but this plan clearly has. Where is his integrity and impartiality ? I allege that he has shown time and again that he has a much greater interest in preserving the North to the detriment of all other areas of Chichester !!! AL6 should be removed with immediate effect.Unless this is adequately addressed in future iterations of the plan, then I will raise it with the examiner at the appropriate time.
The plan also fails to address/acknowledge the huge increase in traffic volume now and in the future. There is no viable transport data/ study included within the Plan. The only reference is the Peter Brett Assoc report which was issued in 2010 and has been shown to be incorrect. It is also now completely useless as it is so outdated and claims there is no risk of air pollution from vehicles. We all know that Chichester has one of the worst hotspots for car pollutants/air quality on the South coast. Unless this is addressed in any future iterations of the plan then I will raise this with the examiner at the appropriate time.
I OBJECT to the CDC Local Plan in its present form and unless the Plan is rewritten to take into account the huge inaccuracies and biased, in future iterations then I will be raising it with the examiner at the appropriate time.

It is incomprehensible how anyone who lives in this area would contemplate permission for the number of homes that are being forced upon the local communities when this part of the country is so special. One would have to be blind not to look at a map of the South East of England and realise its slow death from concrete and congestion and here - especially west of Chichester is the last remaining foothold of sanity along the coast.
Chichester, a beautiful County Capital, is a Roman walled city with a Georgian centre - its roads reflect this wonderful heritage - THEY WERE NOT MADE FOR MODERN TRAFFIC LEVELS. This has a knock-on effect upon nearby villages including FISHBOURNE. The position of the Chichester Plains including FISHBOURNE is that it is caught between the SDNP and the sea. But that is no reason to concrete it over. All this is in YOUR CARE.Y

FISHBOURNE - The Present State
Fishbourne cannot be accused of Nimbyism - it has built more than the required number of houses requested on sensitive, sustainable sites and therefore there is no moral justification whatsoever to inflict the community with 250 more. There has been no explanation as to why this number and why Fishbourne from the CDC. Apparently the CDC has decided to classify Fishbourne as a 'service village'. Has anyone actually been to Fishbourne to verify this classification?
The truth is:
Fishbourne Parish Council has already submitted and enacted upon the Neighbourhood Plan with the full involvement and support from the local community.
Fishbourne has already reached its boundaries. It is crucial to the well being of communities and in the spirit of the Government's policies to prevent 'coalescence' of villages.
Fishbourne is a Conservation Area and the FISHBOURNE MEADOWS are a crucial part of it.
The Primary School is already filled with children from the catchment area. The Fishbourne Centre is so popular it is functioning at full capacity. The local church and its hall is likewise functioning at full capacity. The Fishbourne Playing Field facilities provide not only tennis courts, bowls, croquet, cricket, etc. and a fully equipped children's outdoor secure play area. All these are used on a regular basis. There is no doubt that Fishbourne is a thriving and active community and therefore there is NO CASE for further growth.

The Disastrous Consequences of Mass Unnecessary and Unwanted Development
If this is 'forced' upon the community it will break every democratically arrived at Policy of the Parish Council and anger the vast majority of residents for, by permitting a few houses on Bethwines Farm will open up the floodgates to 1000. This will destroy valuable green field agricultural land. It will exacerbate flooding. Will cause untold traffic congestion for with every household there will be two cars as a minimum creating gridlock on local roads. Will heighten the already dangerous levels of air pollution. The local sewerage plant in Apuldram is already at breaking point. All this on top of the already permitted 1600 homes at Whitehouse Farm north of Fishbourne. The chaos and damage to the roads, the noise, the mud, the dust, potential danger to locals due to confined sites etc during construction which could take years not months. The agricultural land in this area is of special importance to the national production of horticulture. It provides employment to 9,000 and creates £1 billion in sales - substantial statistics.
CHICHESTER HARBOUR
Is an AONB, an SSSI, a Ramsar, an SAC, an SPA, an SINC/SNCI, a Conservation Area, a Local Wildlife Site, and a Local Nature Reserve. This is the JEWEL IN THE CROWN. It is the duty of every citizen, especially those in Authority, to safeguard this valuable, irreplaceable asset, unharmed for the nation and future generations. NOTHING should be permitted that would endanger it in any way. So why is the Chichester District Council not fighting the Government to protect it? To protect it from:
Mass Developments that are not NEEDED that will damage the waters through flooding - including Apuldram sewerage outflow, will create pollution from additional traffic, will disturb the wildlife and tranquillity from growing disturbances, will create light pollution, and with the growth in population create damaging levels of litter, and many more.
A259 -Main Road
This is the only access for all the developments being planned and being built in Bosham, Chidham, Nutbourne and Southbourne (hundreds and in some instances thousands) that will accumulate at Fishbourne roundabout in order to access the A27 and the City. This route is the only one that all delivery trucks and all agricultural machinery can use. The traffic will continue to grow along this road as the bus schedules are being cut and the SW train service seems to be in permanent decline. This road is also the boundary to the Chichester Harbour Trust. How then will the CDC enforce the protections of the Trust? AIR POLLUTION
AIR POLLUTION
The UN in June 2017 is quoted as saying: 'Air pollution is Europe's leading environment killer'.
NAEI have a map of the Chichester Plains where the average levels are 0.1 - 0.3 but Fishbourne and Donnington roundabouts already reach 25!
Friends of the Earth are quoted as saying 'Costs to the UK of air pollution runs to £20 billion.
Living Streets say '80% of toxic nitrogen oxide concentrations are found at roadsides from motor traffic'.
'40,000 deaths annually are attributed to air pollution'
'38 out of 43 UK zones exceeded legal levels of nitrogen oxide emission in 2013.'
The UK is breaking the law with its current air pollution levels.
We now have children dying with 'air pollution' on their death certificates.
THE LEVELS AT FISHBOURNE ROUNDABOUT ARE ALREADY BREAKING LEGAL LIMITS
So what will these levels reach :
When all these 2250 scheduled developments with two cars per unit take place using the only road available - A259.
When the TRAFFIC DOUBLES OVER THE THREE SUMMER MONTHS creating gridlock down to the Manhood Peninsular
When your proposed Stockbridge link road - whose construction will break all the criteria laid down in the CDC policies by building across major flood plains, by restricting the protected views of the Cathedral, by building on the protected Fishbourne Meadows and into the AONB of Chichester Harbour, and end up TAKING ALL THE TRAFFIC ON TO THE FISHBOURNE ROUNDABOUT.
WILDLIFE CORRIDOR
The last minute offer of a Wildlife Corridor in an attempt to mitigate the horrors being inflicted upon this community you have placed in a narrow strip to the east of the village. This will immediately be irrelevant for it is too narrow, will pass through a built up environment which will lead to disturbances throughout the day, will lead to noise pollution, will lead to light pollution and will therefore NOT PROVIDE a safe haven for any wildlife. The obvious position for such a corridor would be to the WEST of FISHBOURNE where the open agricultural green field sites will enable all forms of wildlife to access both the Harbour Conservancy and the National Park safely.
THE A27
What is the point of this whole exercise when there has been no decision on the route of the A27. Until the CDC issues correct data on present traffic flows, until the CDC issues correct data on 'projected' traffic flows, until the CDC recognises that this is a NATIONAL STRATEGIC road and NOT A LOCAL road, until the CDC re presents the NORTHERN option, then no permissions for further developments should take place.
The Secretary of State for Housing is quoted as saying: 'The message it (NPPF) sends is clear and direct; we want the right number of homes in the right places. CENTRAL TO THIS IS THE VOICE OF THE COMMUNITIES.'
As the community's elected representatives it is your duty to protect the National Assets in this area. It is your duty to provide 'sustainable' developments that do not create or add to the highway safety, air pollution or any other damage to your communities. This area does not NEED new three/four bedroom houses. What it does need is AFFORDABLE housing. Part of the relief could come from allowing Affordable housing in the SDNP which would halt the decline of the communities, fill the empty schools, and provide continuing regeneration. Jake Berry MP in the Ministry of Housing has said that WHERE HOUSING IS NEEDED IS IN THE NORTH where the region is undergoing regeneration and businesses are relocating.
THE FISHBOURNE COMMUNITY
The Fishburne community has acted in good faith throughout this whole exercise. It is now up to the CDC to support it.

I represent West Stoke and East Ashling Residents A 27 action group.

WSCC and CDC were wrong to ignore the results of all consultations and recommend a Northern By Pass that if built would never solve the problems of dangerous junctions with A27 and ignores national policy of National Parks.
In the LPR Plan there is a clear statement that the A 27 junctions need to be improved to allow for additional traffic new proposed housing will create.
Surely it makes sense then to do the job properly and once only by seeking a smaller amount of RIS2 funding to make the changes to CDC's own plan more effective.
Do not delay further to improve the junctions please.

CDCF should like to respectfully comment and respond to the current Local Plan Consultation being held by Chichester District Council.
For a start, the consultation papers and documents provided for consideration are without doubt, a 'massive' piece of work. The Chapters and text form a highly technical and complex piece of work covering the whole of the Chichester District. It is as if the district has been 'rolled out' flat or to put it another way, 'no stone has been left unturned'. The Planning Policy Team at CDC must be congratulated for their thoroughness and attention to detail.
With this in mind, it would be presumptuous of CDCF to 'drill down' into the document and request small changes here and there. CDCF have the interests of cyclists and cycling at heart and this response wishes to adopt a more 'broad brush' approach.
Without wishing to state the obvious, different cyclists have different needs and preferences. For some people, cycling is a way to travel from home to work whereas for others, it is a whole family leisure activity. Some cyclists travelling to work require a flat surface and a direct route (on or off road) to achieve a good speed and comfortable cadence. A cyclist on an off road leisure route, wishes to enjoy the safety, peace and fresh air away from vehicular traffic.
One size does not fit all and the Local Plan must reflect these differences. CDCF note that the Local Plan Vision for 2035 includes a reference to residents 'pursuing a healthy lifestyle with good access to leisure facilities and open spaces' and to 'move around safely and conveniently with opportunities to choose alternatives to car travel'. Under the heading of Objectives for the Local Plan (3.19) the document lists the need to 'achieve a sustainable and integrated transport system through improved cycle ways and links to public transport'. CDCF would endorse these statements.
CDCF note that the Local Plan sets out those areas within the Chichester District where new housing would be most suitable and appropriate. According to the Local Plan, the East/West corridor from Tangmere to Southbourne is the most favoured location for the majority of these new dwellings, circa 10,056 with a further 1933 new dwellings being built on the Manhood Peninsular.
CDCF have very recently been working on a cycle project known as CHEMROUTE. This is an abbreviation that describes our aspirations for a decent and useable cycle route between Chichester and Emsworth. In addition to following the A259 corridor, this vital section of cycle route forms part of the National Cycle Network Route 2 ie Dover to St Austell. NCN2 passes through West Sussex and into Hampshire and we
2.
have a duty and responsibility to ensure that our section is clearly marked, engineered and designed to national standards. Our work on this project has taken us to meet with representatives of the Parish Councils along the route and it has been encouraging to see the unanimous support for NCN2. The Parish Councils are writing this support into their own Local Plans and the hope is that, when certain sites become the subject of a planning application for new housing, contributions will be sought through the Community Infrastructure Levy process to require developers to finance this important cycle route. CDCF are pleased to see that CDC's Local Plan sets out a commitment to improve the highway infrastructure for cyclists and pedestrians. In simple terms, if the residents of each new household along the A259 corridor ran two cars, this would result in an additional 20,000 cars using the A27 and A259. The traffic jam would be spectacular! Sustainable transport, such as cycling, buses and trains are the only solution and for the former, a decent cycle route must be put in place to encourage the population to leave their cars at home.
One of the frustrations of our current planning process is that planning officers can only make a determination on the development site. In other words, the area of land inside the red boundary line that extends around the whole site. Many developers put in place cycle paths within a new housing area but very often, these paths reach the 'red line' and stop. In other words, these paths do not link in with existing cycle paths or long term plans for a cycle route. The A259 corridor is already seeing and will see in the future, new development sites being identified and it makes sense to require developers to finance cycle infrastructure improvements to encourage their 'new residents' to cycle or walk.
The same argument may be applied to the Manhood Peninsular only here; the current road networks are even more difficult. It is encouraging to see that Policy 18 acknowledges that there is a need to 'improve the infrastructure to support sustainable modes of transport, especially cycle ways, bridleways and footpaths'. In recent months, the Selsey Community Forum has been planning for a Selsey Greenway path to link Selsey with Chichester. It is well known that the B2145 is not a good place to be on a pedal cycle and at the time of writing this response, the first stage of the Greenway ie Selsey to Pagham Nature Reserve is nearing completion. There are advanced plans to progress the pathway further north towards Hunston and Chichester. Further west, the Salterns Way is a considerable community asset and is well used by walkers and cyclists alike.
It is worth noting that the Local Plan points out that CDC are updating their Cycling, Walking and Infrastructure Plan and under Green Infrastructure (DM32) the text reads, 'planning permission will be granted where it can be demonstrated that the following criteria have been addressed: the proposals do not lead to the dissection of the linear network of cycle ways, PROW, bridleways and ecological corridors'.
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Therefore, developers will have to incorporate measures to avoid harm and mitigate effects.
It must also be pointed out that the National Planning Policy Framework that came into force in July 2018 (para 98) directs that, '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'.
CDCF note that the Chichester District forming part of the South Downs National Park will not become the focus for any major new housing developments. The Centurion Way follows the old railway line that was once operated by the London and South Coast Railway Company. To date the Centurion Way extends from Chichester to West Dean and a planning application is currently under consideration to extend the path to the top of Cocking Hill where the South Downs Way crosses over the A286. The ultimate aim is to extend the Centurion Way to Midhurst. CDCF have recently established a Centurion Way User Group to protect the route from unreasonable changes and to offer light maintenance along the route.
In summary, Highways England have a published a Cycling Strategy, West Sussex County Council have a Walking and Cycling Strategy, Chichester District Council have a Cycling, Walking and Infrastructure Planning Policy. For any of these 'policies' and in particular, this Local Plan, to make any sense whatsoever, CDCF must urge the relevant authorities to put their words into actions. When our communities can actually see real change happening, then and only then, shall we feel satisfied and confident in the knowledge that our thoughts and comments have been applied to everyday, real life situations. CDCF should like to wish the CDC Planning Policy Team well with this project and the eventual publication of the final Local Plan.

The British Horse Society (BHS) is the UK's largest equine charity and equestrian membership organisation and the governing body for recreational riding. Its charitable objects include the promotion of equestrian safety, particularly on roads, and equestrian access to bridleways and other off-road multi-use routes for the public benefit. On behalf of The Society I would like to make the following comments:

Chichester Local Plan Review 2016-2035 Preferred Approach

The Society's priority when commenting on this document is to try and ensure that the policies and wording in the text include commitments to support and protect vulnerable road user groups, including equestrians (West Sussex Transport Plan, page 32, para 1.4.5), from the dangers they face on local roads due to the inevitable increase in traffic on these roads brought about by planned housing development.

The Plan area covered is home to a large number of equestrians, who bring significant economic benefits, especially to rural communities, but unless they have access to a safe network of bridleways, byways, and other off-road informal recreational routes which they can use daily, the dangers to horse riders will increase, and the industry will struggle to survive.

Policy S18: Integrated Coastal Zone Management for the Manhood Peninsula (page 68)
Equestrians on the Manhood Peninsula feel increasingly unsafe on the local roads they have always used, where the speed and volume of vehicles has grown considerably, and will do so even more as a result of the proposed housing development. There are now more than 500 horses kept in the area (Manhood Riding Club count) in private stables, livery yards, and the local Riding School (at which the Chichester Group of Riding for the Disabled is based).

We would, therefore, absolutely support objective 5 of this Policy "Improve infrastructure to support sustainable modes of transport, especially cycle ways, bridleways and footpaths, including the National Coastal Footpath ".

We would suggest the best way to do this is to ensure that at least one multi-use route (bridleway) is provided through, or around the fringe of developments, which can also serve as a green corridor for leisure and recreation and, and benefit health and well-being, wildlife and biodiversity. These routes can form the basis of a safe non-motorised user (NMU) network and link with existing public rights of way (prow) where possible.

Policy S20: Design (page 74)
Bullet point 5 - wording is supported "incorporates and/or links to high quality Green Infrastructure and landscaping to enhance biodiversity and meet recreational needs, including public rights of way."
However, it is important as mentioned above that this incudes 'multi-use' public rights of way for the benefit of all.

Transport Infrastructure
Para 5.15 - very good to see "bridleways" included in this para.
Para 5.16 - The wording "There is an extensive public rights of way network across the plan area... is misleading. The wording implies that this prow network is available to all users, whereas on the Coastal Plain the prow network consists almost entirely of footpaths, which are not available for use by cyclists and equestrians. Upgrading appropriate/suitable prow to bridleways would contribute to the West Sussex Transport Plan (2011-2026) aim of "improving safety for all road users", mentioned in para 5.18.

Policy S23: Transport and Accessibility
Bullet point 8 - Our view is that the objective "improving safety for all road users", should be included in the actual Policy wording, not just in the accompanying text. However, it is good to see 'public rights of way' included, which need to be multi-use bringing safety benefits for all vulnerable road users.

Countryside and Countryside Gaps (page 82)
Para 5.37 - Absolutely agree the plan area's countryside is an important and diminishing resource, and the Council's aim to protect the countryside from the urbanising impacts of development is welcomed. For existing and future residents, the opportunity to enjoy 'informal recreation' (walking, cycling, horse riding) in the countryside is important for leisure, health, and well-being. The Council needs to take a very active role in ensuring that any development provides benefits, most likely in the way of safe, off-road multi-use routes(green links), and the mention of this in para 5.40 is welcomed.

Policy S32: Design Strategies for Strategic and Major Development Sites (page 92/93)
The references in Point b, "movement and access arrangements and Green Infrastructure provision", in Point e, "community leisure and recreation facilities as appropriate", and Point g, "contain a Green Infrastructure framework to ensure that public and private open space standards are met, relate well to each other and to existing areas and that the new spaces are safe, convenient, accessible and functional" are welcomed.
However, it is important that leisure and recreational routes, and new prow connect to the wider countryside for public benefit, and are not just contained within a development. There are many examples in the county where new routes have been created across or on the fringe of a development, which link to a wider network of recreational routes. The National Planning Policy Framework (NPPF), para 98, 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"

Policy AL1: Land West of Chichester (page 96)
Point 4 - whilst welcoming the provision of "open space and green infrastructure", this development provides an excellent opportunity to improve links to the wider countryside, in particular to BW 270 and Park Lane (which should be formally dedicated as a prow).
Point 10 - An "appropriate landscaping buffer", is also an excellent opportunity to provide a multi-use prow (bridleway), for the safety and enjoyment of all vulnerable road users, which as a 'green corridor, would also contribute to green infrastructure.
We would also request that when looking at 'key landscaping' of the Centurian Way (CW), the issue of upgrading this to a multi-user path where possible, to include equestrians is considered, so that they can also benefit from a safe and secure off-road environment. The CW is the only disused railway line in the county that is not available for use by all NMUs. The Worth Way and Downs Link are fully multi-use, and are highly valued and well used.

Policy AL2: Land at Shopwyke (Oving Parish) (page 99/100)
Point 9 - Despite repeated requests for the proposed bridge connection across the A27 at Coach Road (a route used by all NMUs until it was severed when the A27 was realigned) to also be made available for equestrian use, it would appear from the Policy wording that horse riders continue to be excluded, despite the large numbers of horses kept in the Oving area.

At present, riders have to box their horses over the A27 to access the safe network of bridleways and riding routes in the National Park, which is a situation contrary to the aims and objectives set out in this Plan. In order to gain maximum benefit from bridge infrastructure, it should be made available for as many users as possible.

Policies AL3 to AL14
All of these Policies require opportunities for the provision of green infrastructure with links to the wider countryside to be explored, and these are welcomed and supported. Creating new routes and links is especially important on the Coastal Plain, where an off-road multi-use path network would be of great benefit to all NMUs.

The West Sussex Rights of Way Management Plan 2018-2028 has Objectives (page 3) which include:
2. Improve path links to provide circular routes and links between communities.
3. Improve the PRoW network to create safe routes for both leisure and utility journeys, by minimising the need to use and cross busy roads.
4. Provide a PRoW network that enables appropriate access with minimal barriers for as many people as possible.
5. Promote countryside access to all sections of the community enabling people to confidently and responsibly use and enjoy the countryside.

The Plan also states in Improvement schemes (page 13), that "A starting point for new schemes will be to consider who could benefit from a new route, such as walkers, cyclists, horse riders and the disabled, and be as inclusive as possible, often the aim will be to achieve at least bridleway status.

Policy DM32 Green Infrastructure (page 199)
It is disappointing that the wording (on page 197/198) omits to mention that prow (footpaths, bridleways, byways), are defined by Natural England, and also recognised nationally, as multifunctional 'green corridors', and are therefore part of GI. Providing a multi-use (walker, cyclist, equestrian) prow or recreational route around the periphery would comply with NPPF, para 98, as mentioned above.
It is good to see public rights of way, and bridleways mentioned in Point 4 of the Policy, although the wording "do not lead to the dissection of the linear network" appears to be rather negative, much better to tell someone what they should do "The proposals protect, and contribute to the improvement of ........"

Policy DM34: Open Space, Sport and Recreation .... (page 204)
We support the aim to "seek to retain, enhance, improve access and increase the quantity and quality of....rights of way including improvement of links to them." This will be of great benefit to all NMUs.

Point 1 - Excellent to see requirement for development to contribute to new links to the existing rights of way network, which should be multi-use wherever possible.
Also support the aim to secure on-site provision secured via S106 agreements to provide (amongst other things) links to the existing rights of way network to meet any identified shortfalls in the local area, and would request in line with the WS RoW Management Plan that these links will be "as inclusive as possible, often the aim will be to achieve at least bridleway status."

I support the Chichester District Council's support (along with West Sussex County Council) for a northern by-pass alignment as a preferred option (see section 5.24, p78) but I feel that a little clarification is needed where this section of the Plan refers to a southern route as a reasonable alternative to confirm that this is an 'on-line' option on the route of the existing southern by-pass rather than a separate alignment further south still. I would also add that Chichester residents should be fully engaged in future consultation with Highways England (and in turn with Chichester DC and WSCC on their behalf) in the design issues and environmental impacts concerning junction improvements at the key roundabouts on the southern bypass. I feel that any left exit only options at current roundabouts would be detrimental to local residents by encouraging rat running along Kingsham Road, Kingsham Ave,Terminus Rd and Quarry Lane and result in 'traffic churn' and potentially worsen congestion on the southern by-pass where west heading traffic is compelled to head to the next roundabout to the east before coming all the way back to their 'starting point' before continuing an onward westwards journey. I felt that the Highways England consultation with local residents did not provide a fair cost comparison of a northern route with a fully engineered 'on-line' grade separated/ 'hamburger' style roundabout option and I would like to see consideration of a single carriageway, through traffic only, option for a northern route; perhaps a solution along the lines of the Bognor Regis Relief Road. After all, the HE traffic user analysis told us that the majority of A27 bypass users represented local traffic as opposed to through traffic. If this analysis is flawed and the majority is through traffic then a dual carriageway northern option should be considered.

There is limited emphasis on an integrated public transport system which is essential to avoid congestion and pollution. Promises to 'work with' bus and rail providers does not constitute a policy. The upgrades to the Fishbourne roundabout will not rectify the congestion currently. In fact it will be made worse by the planned link Road to Birdham. The traffic from an additional 2250 homes travelling east will severely impact the traffic flow from commuters and beach traffic. The Impact on the A259 will be further worsened by the lack of planned slip roads between Emsworth and Fishbourne .deterioration in air quality.

Para. 5.26. This should not be considered as part of this plan. WSCC/CDC prefer a new bypass to the north of the city and this should be pursued vigorously with the Department for Transport and Highways England.