Policy S23: Transport and Accessibility

I have some comments on the Chichester Local Plan I wish to submit:

1) S28 and DM24 Pollution
This policy as it is not detailed enough. I would like to see more monitoring and more measures to be included in this policy to ensure actions are taken. These should include Clean Air Zones introduced, cleaner buses, car free day, workplace parking levy, anti-idling zones, increased pedestrianised areas in our villages and towns, better joined up cycle network

2) Policy AL6 - Land South-West of Chichester
I am opposed to the Stockbridge Relief Road and the allocation of houses to Apuldram and Donnington as it is too close to the AONB, on a floodplain and destroys prime agricultural land.

3) DM 16 Sustainable Design and Construction
The plan should acknowledge the need for the area to become carbon neutral in order to prevent climate change.
Manchester has committed that all new buildings will be net-zero carbon. This should be included in the Chichester Plan.

4) DM17 Stand-alone Renewable Energy
The plan should put aside space for renewable energy as a priority. We need space for wind turbines, battery storage and more solar panels on the roofs. Provision may be required on the coast for enabling the connection of an off-shore wind farm.

5) SA5 Southern Gateway
This policy needs to deliver better plans for people walking and cycling.
The green space should be preserved and an additional pocket park added to the area

The city needs a welcoming bus and train station, a proper public transport hub with toilets, tourist information, waiting area in the dry, warm and shade and proper information with RTPI screens (not just bus stops). The current bus and stations are hideous and unwelcoming and are not in keeping with the rest of the city.

6) S23 Transport and Accessibility
A coordinated package of improvements to junctions within the city is missing from this policy.

The roundabouts on Westhampnett Road near Sainsbury's, New Park Road near the new Coop, Eastgate, Northgate, Westgate and Southgate need redesigning to allocate more space to people on bikes and on foot.

More bus lanes and a linked up and continuous network of proper, protected cycle lanes need to be introduced.

St Paul's Road and Bognor Road need to have less private car parking to enable sustainable means to be prioritised - bus and bike lanes.

Transport measures need to ensure that we reduce our carbon footprint as emissions in this sector are still on the rise.

7) Policy S5 - Parish Housing Requirements
A Second home policy should be introduced to prevent an over dominance of new homes being sold to non-residents.

8) Policy S30
Wildlife Corridors need support but the wording needs to be made stronger so that development within this corridor is not permitted. The plan needs a stronger commitment to the preservation of wildlife within the area, in its current form it is lacking.

All proposals should demonstrate that they will have a net zero impact on climate change in line with the government's commitment in 2008 Climate Change Act as a signatory to COP21 Paris Agreement and the IPCC's report published in the autumn of 2018.

Resident of West Wittering
As mentioned previously even though the Peninsula has already met the supply commitment detailed in the adopted Local Plan nothing has been done to address the A27 issues.
Regarding the A286 Link Road this is ill conceived. No thought on the damage to the AONB, it will block the view across the fields as you approach Chichester along the A286. Cause even more congestion at the Fishbourne Roundabout and the potential increase in traffic could require a dual carriageway.

On a further point a statement was made by James Brokenshire Secretary of State for Housing, Communities and Local Government on 10 December 2018 in Parliament during the Housing, Communities and Local Government Question Time. The statement, I believe, was during a discussion on housing developments in Oxfordshire. The key point raised in the Secretary of States response was to a question on infrastructure delivery. In response he stated that prior to any significant development the supporting infrastructure must be already in place.

I have strong objections to your plans for the following reasons. Your proposals to the A27 contains already rejected suggestions of "no right turns" on the Whyke and Stockbridge roundabouts increasing the flow of traffic up and down the A27 as drivers are forced to drive to the already congested Bognor and Fishbourne roundabouts to get onto the opposite carriageway. The increased mileage and exhaust fumes will add to the pollution levels that are already very close to the government 's stated "safe" limit. We are already faced with the likely loss of the traffic lights on the Oving Road as more and more traffic is forced to find other ways in and out of Chichester and our city streets are turning into rat runs. Your policy needs to focus on the needs of your much-overlooked residents of the city.
You need to find another way without such negative impacts on us all.

Leave the Oving Crossing Alone.
Keep pushing for the Northern By Pass.

Donnington residents, of which I am one, will be hugely disadvantaged by these A27 changes including the ban on access to the East from the Stockbridge roundabout. We will face increased traffic disruption and idling queues adding environmental damage to our health on top of limits that are already being exceeded

There is little mention of provision for pedestrians and cyclists at major roundabouts. This would be an aopportunity to improve them.
Transport measures need to take emissions into account. CArbon emissions from transport are rising.

Air quality is already bad. More housing and more traffic will make it worse,

Please include specific protection for existing routes under

Integrated transport measures will be developed to mitigate the impact of planned
development on the highways network, improve highway safety and air quality, promote more sustainable travel patterns and encourage increased use of sustainable modes of travel, such as public transport, cycling and walking.

Real commitment to infrastructure must be made.

eg Centurion Way, Westgate, links to Manhood Peninsula.

"If the A27 is not improved within the next 5 years the area will be gridlocked. With the hundreds of new houses being built in the area and the ever growing number of cars it is folly to leave this vital work to the last minute. Councillors have a duty to the community to sort out the problem without delay. Why there was never the proposed flyover, over the Fishbourne roundabout is quite ridiculous and would have made the now vital improvements a much easier task."

I object to the proposed changes to the A27 namely not being able to turn right at the Stockbridge roundabout. This will unfairly impact on local residents and I don't think will improve the traffic situation. The proposed new road would create huge distribution. Again making the local traffic even worse. The area North of the city should be used for the additional housing as his would have much less impact on residents and the a27.

We recently received a circular from Donnington Parish Council highlighting what they consider are key issues within the 2035 plan that significantly affect us, as residents of Donnington / Stockbridge. Whilst I do agree with a number of points that they make, this is a very extensive and far reaching plan that, if implemented, will take many years to achieve (how long have we been talking about the A27 improvements with no actual action ever taken).

No town or city is ever going to stand still and, in order to ensure that Chichester remain a prosperous area (and to comply with ever increasing demands for new housing), both commercial and residential property WILL need to be built, but does virtually ALL of this need to be on or below the A27 corridor??

Continued development below or along the A27 corridor, without the inclusion of supporting infrastructure, especially adequate provision for the vast number of additional vehicle movements that will result, just does not make sense. In addition, our local education system and our health services are at breaking point, but there does not appear to be any provision within your plans to not only provide additional facilities, but also to provide reasonable and sensible access to them.

I know that for many years, the debate about whether to include a northern bypass route has raged on and it is interesting to see, within your plan, that this has NOT been completely ruled out. The inclusion, even of a simple route (similar even to that which has been put in at North Bersted), would SIGNIFICANTLY improve traffic flow around our City and allow easy access to the North of the City, Goodwood Motor Racing Circuit, Goodwood Horse Racing Circuit, the South Downs, Midhurst and all points North. Even if the consideration remains for further changes to the existing A27, this is still likely to take over 15 years to complete and will cause gridlock for the whole duration of that time. An alternative route must be put in place before consideration is given to further changes to the existing A27. Simple repairs / upgrades to a footbridge at Donnington recently caused chaos for much of the past year.....

One of the points of note from the Parish Council circular is that you are proposing that traffic will not be permitted to either cross the A27 (North or South) nor will right hand turns be permitted either onto, or off of, the A27 at three key junctions. Whilst, in theory, this might improve the general flow along the A27, this will also HUGELY increase the number and volume of traffic movements along the stretch from Portfield to Fishbourne as the thousands of vehicles based South of the A27 attempt access to our City and also East / West of it. Each vehicle will be forced to cover significantly more miles than currently required and all that will happen will be the gridlock points will refocus elsewhere along the A27.

I would add, that no thought has been given at all to the residents of Watery Lane, Queens Avenue and Queens Gardens, whose existing access to ANYWHERE is already directly onto the A27. To get into the City we already have to cross three lanes of busy traffic and to return to our homes means an additional two mile trip to the Selsey roundabout and back. During the bridge repairs, and at times when the Free School is finishing for the day, delays can add over 20 minutes to our return trip home. If there are accidents or other incidents on this stretch of road we are effectively blocked from access to our homes. The proposal to close access across the A27 would mean an additional TEN MILE round trip for the 30-40 residents vehicles that would be affected daily. This is an additional 100,000 miles of unnecessary road miles (based on only 30 vehicles, each day at 10 miles per day) just for those few vehicles. What does that equate to when multiplied by the 1000's of vehicles already on, or proposed to be added to, the Donnington area and Manhood peninsular? Just adding 5 miles to 1,000 vehicles each day adds an additional 1,825,000 unnecessary miles (and emissions) in the immediate area each year.

Much better public transport links, cycle paths and footpaths would greatly improve access to our City Centre and reduce vehicle movements. Whilst the footbridge was being repaired, a tarmac footpath was put in place between Queens Avenue and the canal (this is a route that, albeit a mud path, has been used for over 20 years by local residents) giving improved access to the canal, the High School, Kingsham Primary and the Free School. Perfect.. finally something of benefit to local residents.. but no.. it was dug up again this week because (according to The Highways Agency) no one would take responsibility for its future upkeep and repairs.... The cycle route from Donnington to the centre of town for example now runs along a pavement, get off at the bridge (no cycling!!), back onto pavement, cross the busy traffic, back onto the pavement, get off at the traffic lights at Terminus Road back on the busy pavement, onto the road at the railway crossing, before being squeezed off your bike up through South Gate and South Street by busy traffic (there is no clear, unambiguous return route)!! The cycle route to the High School, Kingsham and the Free School is now (again) restricted by no cycling on the bridge(??) before joining a narrow, busy, footpath past the petrol station. This does not encourage safe cycling so we use the car...

Between The Ministry for Transport, Highways England, The Highways Agency, WSCC, Chichester District Council and all of the parish councils and individuals involved in this process, is it any wonder that nothing actually ever gets done. There are simply too many factions involved.

Flyovers across the A27 from Donnington and the peninsular still remain a good idea, but only if they also permit easy access to / from the A27 by residents living south of the A27. I believe the process previously failed due to lack of proper consideration for the residents living south of the A27 and this will remain the case again unless further / better consideration is given as part of your '2035' proposals. Please, bite the bullet and do this properly, not piecemeal because of ineffectual politicians and bureaucrats arguing about which budget this might be funded from or other political considerations.

The proposals for the A27 are a cause for concern:
* This is because of the probable loss of the traffic light controlled crossing on the Oving road, and the alterations to the junctions at both Whyke and Stockbridge roundabouts which include 'no right turn' limitations from the A27.
* These junction changes at Whyke and Stockbridge will cause considerable inconvenience to westbound traffic from the A27 accessing the town and eastbound traffic wishing to access Donnington and The Witterings, also Hunston and Manhood.
* There will also be a serious risk that vehicles unable to make these manoeuvres will seek alternative 'rat runs' through our narrow and speed restricted streets.
* Alternatively, more mileage will be added to every journey as drivers will be required to drive to the next nearest roundabout, Bognor Road or Fishbourne, in order to return on the opposite carriageway in order to then turn left. The added exhaust emissions will have a negative impact on our air quality which is currently close to the Government's stated 'safe' limits.
The last comment is a particular concern to me as I am asthmatic and am aware of the poor air quality at present.

Dell Quay Sailing Club (DQSC), is a volunteer members club (700 plus members), situated at Dell Quay in the Area of Outstanding Natural Beauty (AONB) of Chichester Harbour providing organised competitive and recreational water borne activities for members aged 5 to 70 plus years, with other members taking to the water in their own vessels, some children younger than 5 years of age. This submission is made by the Directors of DQSC.

The proposed Adopted Plan areas all combine to further increase the infrastructure pressures in the area. The proposed development at AP/AL6 the fields between Apuldram Lane and the Stockbridge, are of particular concern to DQSC. However, when combined with existing planned expansion (Fishbourne, Southbourne and Chichester) the impact on the area as a whole will be enormous affecting the Sites of Special Scientific Interest (SSSI), AONB, wildlife habitats, road congestion, pollution (noise/light), and air quality.

The proposed adopted plan raises specific concerns with DQSC membership namely: infrastructure to support waste treatment/run off water, local flooding, traffic management on minor roads, the effects on the SSSI, the AONB and habitats will adversely affect the area. The greatest concerns are the quality of water within Chichester Harbour where members swim or race/sail in small boats that regularly capsize (potential Public Health Issues) and the effects of more vehicle traffic and limited facilities within the AONB to accommodate increased numbers of people and recreational (e.g. walkers/pedal bikers) users.

Sewage Treatment and Waste Water Disposal.
DQSC has particular concerns about the proposed development at AP6 the details of which are unclear as the impact on the sewage process works is described as "untested" in the report. Currently it is well known that the Apuldram waste water treatment cannot cope with the existing volume that is sent to it with lorries taking some effluent to other processing facilities and regular storm discharges into the SSIs 24, 27, 29. 30 and 31 (Ref https://magic.defra.gov.uk/magicMap.aspx) which are returned on the incoming tide and settle on the mud. The areas shown below are those affected and the state of those areas is shown in the table (copied from the defra.gov.uk website) below in which it states that the areas that are covered by the tide waters are "Unfavourable - Recovering" and to add further to any pollution from waste would be detrimental to the recovery of the eco systems affected.



027
27 MUD Unfavourable - Recovering Medium LITTORAL SEDIMENT 51.3959 SU 833 031 View map

028
28 Favourable No identified Condition Threat NEUTRAL GRASSLAND - Lowland 5.4059 SU 833 035 View map

029
FISHBOURNE SWAMP Unfavourable - Recovering Medium FEN, MARSH AND SWAMP - Lowland 6.4553 SU 836 044 View map

030
FISHBOURNE CHANNEL MUD Unfavourable - Recovering Medium LITTORAL SEDIMENT 33.1731 SU 837 036 View map

031
COPPERAS POINT Unfavourable - No change Medium LITTORAL SEDIMENT 49.3458 SU 830 020 View map

045
NON-SAC GRASSLAND SW OF FISHBOURNE Favourable No identified Condition Threat FEN, MARSH AND SWAMP - Lowland 3.5043 SU 832 038 View map


Any discharges from the Apuldram Treatment works directly affect Dell Quay Sailing Club as they flow past Dell Quay and affect the water quality in the area within which we organise on water activities and the general public visit. In the past 10 years DQSC has complained via the Chichester Harbour Conservancy to the Environment Agency who have attended and taken samples of the harbour water.

Recommendation
Further Sewage and Waste Water treatment plants need to be incorporated in the development plan.

Flooding. Nothing in the report assures DQSC that this has been considered and the effects that development will have on the increased likelihood of flooding affecting the site. The proposed development at AP/AL6 the fields between Apuldram Lane and the Stockbridge are on the FLOOD PLAIN for the river Lavant and any development their can only further increase the risk of flooding properties or if suitable drainage is installed only move the problem further down river or into Chichester Harbour either through the Waste Water Treatment plant at Apuldram (more storm water discharges) or by direct drainage which again will impact the SSSI (noted above) and the ensuing effect on water quality in the harbour.

The picture below shows the fields below the Water Treatment Plant at Apuldram and was taken from the Apuldram Lane looking towards Chichester Harbour however the fields the other side (the flood plain for the Lavant could not be seen due to the height of the hedge) this shows how great the problems could be now let alone what would happen if the flood Plain was built over.


Recommendation
There should be no development in the area designated AP/AL6.

Roads and Transport.

1. The proposed link road running from the Fishbourne roundabout to the Birdham road new roundabout. This is likely to have to be an elevated road to deal with the Lavant flood plain and so will increase light, noise and pollution near the AONB and interfere with natural habitat and wildlife movements interrupted. The proposed junctions for this link road will create more congestion on the A27 Fishbourne Roundabout and a choke point on the Birdham Road. This will further exacerbate the use of Apuldram road as a rat run - people will see congestion on the Fishborne Round about or at the roundabout on Birdham Road and then use Appuldram Road as a means of avoiding the congestion.

2. DQSC have concerns over the proposals for development west of Chichester including Apuldram, Fishbourne and Southbourne. All of these extra houses will have an impact on the A259 junction at Fishbourne and will further exacerbate the problems on the Apuldram road.

3. Lack of public transport to the areas surrounding the proposed developments.

Recommendation -

DQSC recommends that other alternative options are considered for access to developments in Southbourne and Fishbourne, possibly a suitable junction onto the A27 in both directions between Southbourne and Fishbourne.

Any correspondence or future questions should be sent to the Hon Secretary DQSC for representation to the membership of Dell Quay Sailing Club.

I am a resident of Donnington and am disappointed with the ridiculous scheme which you are proposing. In addition, I have not the slightest confidence that the scheme will be completed within budget and on time. The footbridge at the Stockbridge roundabout was a fiasco and if you cannot complete such a relatively small project, I am not convinced any of you are capable of taking on a much larger scheme.

I agree with all of our parish council recommendations and comments below.

DONNINGTON PARISH COUNCIL OBJECTIONS
Donnington residents will be hugely disadvantaged by proposed changes to A27 access arrangements under Policy S23 and the Peter Brett Associates report - effectively no access to the East from Donnington (or the Manhood Peninsula) via A27 unless residents either head West first, encountering the amended Fishbourne Roundabout which will prioritise through traffic and will include an additional junction. Alternative routes to the East are either through the City or via unsuitable "back roads", increasing traffic levels through Hunston and North Mundham. Increased traffic from Whyke (facing the same issue) will cause even more congestion between Donnington and Fishbourne.
* Site AL6 Land South West of Chichester (Apuldram and Donnington parishes) includes a flood plain. Using data from CDC's flood plain assessment, the average height of flood water on the River Lavant is 2.05 metres (6.07 feet) above datum (sea level). This means that the road will have to be elevated by at least 2.5 metres and more with the supporting structures and road thickness itself. Therefore nearer 4 metres (13 feet). This would destroy the iconic views of the cathedral framed by the South Downs. The protection proposed by para 3 of Policy AL6 is unachievable. REMOVE POLICY AL6
* Each of the five junction modifications will require three years of work. This means 15 years of misery for Chichester residents whilst the junction works take place. We all remember the chaos caused by the replacement of one footbridge in Stockbridge, bringing gridlock to the area. (Policy S23 and Peter Brett Associates Transport Assessment)
* Overall, the plans for improvements to the junctions are to the advantage of through traffic not local residents. The proposals bear a marked similarity to Option 3a from the Highways England Improvements to the Chichester A27 Bypass consultation, which were emphatically rejected by the local community - in Donnington and across the whole of Chichester. (Policy SP23 and Peter Brett Transport Assessment)
* Air Quality will further deteriorate as a result of the proposed plans. Stockbridge already exceeds the recommended air quality levels and development on this scale will increase the problem. This has serious health implications for residents. (Policy DM24 & SP28)
* The South Downs National Park should take its allocation of 41 dwellings per annum - without some low level development in the Park, particularly social housing, communities there will not thrive. (Policy S3, Policy S5 & Policy S19 )
* There are no proposals for any new primary schools in the Manhood Peninsula. This will only increase pressure on current schools to provide more places, and lead to increased traffic on the roads as parents are forced to commute to schools outside their local area where spaces may be available.
* Impact on ecology - the Chichester Harbour and surrounding area are designated as an Area of Outstanding Natural Beauty and have the status of being a Special Protection Area, Special Area of Conservation, Site of Special Scientific Interest and is a Ramsar site. It is wholly inappropriate to consider development on this scale in such close proximity to an area with this status. There will be a significantly adverse impact on the ecology of the area and mitigation is not sufficient. (Policy S18 Integrated Coastal Management Zone Manhood)
* Green tourism is a very important part of the Manhood Peninsula economy and to overdevelop and spoil the natural environment which attracts this trade would be inappropriate and hugely detrimental (Policy S18 Integrated Coastal Management Zone Manhood)
* A viable alternative site is available for industrial development within the buffer zone at Goodwood and the employment land should be allocated there. (Policy AL6, S15, S16)

Fishbourne has an over-subscribed primary school, a well-supported community centre and playing fields but no convenience store or doctors' surgery. What it also has is the most beautiful open view to the west to the horizon where you can see wonderful sunsets which everyone can enjoy. It is imperative that this landscape be preserved.

For most everyday living, the use of a car is a necessity.

As Fishbourne is squeezed between the harbour and the A27, the only land available for potential development is Clay Lane towards Chichester or Bethwines Farm.

When a planning application for 200 dwellings was submitted for Bethwines Farm in 2008, this generated over 330 letters of objection including those from Chichester Harbour Conservancy, Fishbourne Parish Council, Bosham Association, Chichester Society, Environment Agency, Natural England. This application was withdrawn before it could be refused. Today would be no different.

Any development here would only harm the environment and would certainly not enhance the landscape and rural character of the area. Once this countryside is gone, Fishbourne would not be the attractive village it currently is and one could well be living in surburbia.

Bethwines Farm is good quality farm land and domestic food production is of strategic national importance. By building on part of it, it could seriously prejudice the viable agricultural operations of the farm and would do nothing to enhance the area's biodiversity and wildlife habitats.

Access via Blackboy Lane would be problematic due to its narrow width and, due to existing development and ditches, there is no opportunity to provide a pavement all the way down to the A259.

There would undoubtedly be a huge increase of traffic travelling down Blackboy Lane trying to join the A259, which is already very busy, with the subsequent increase of traffic through the conservation area of Fishbourne to the Tesco roundabout.

There will be increased recreational pressure on Chichester Harbour and its wildlife.

There is potential for flooding below the site and the run-off being discharged into the harbour.

Clay Lane, in comparison, is very scrubby, unattractive land with no notable outlook. It is preferable to develop poorer quality agricultural land rather than the best. To my knowledge, this land has never been used to grow crops. By developing here, most traffic will travel along Clay Lane towards Chichester, thus avoiding the Tesco roundabout and the A27.

Hopefully, this site would encourage developers to build smaller properties that are needed for first-time buyers rather than large detached homes for in-comers.

A development site is currently underway in Clay Lane nearer to Chichester and one has also been completed in Clay Lane along from its junction with Salthill Road.

I understand that a 'wildlife corridor' is proposed to the west of Chichester. Due to the current building work in Clay Lane and the Whitehouse Farm development, it would be eminently more sensible to provide this wildlife corridor to the west of Fishbourne. The link could easily be made from the top of Chichester Harbour to the South Downs National Park.

The area round Bethwines Farm has enormous diversity. Buzzards, starlings, sparrows, owls, bats, woodpeckers, deer, hedgehogs, harvest mice, slow worms, partridges are regularly seen. In contrast, I don't recall seeing any wildlife along Clay Lane.

In addition, if another road is to come into Tesco roundabout from the south west Apuldram/Donnington, I hate to think of the chaos this will cause with even more traffic travelling along the A259.

PBA's report Table 7.1 states no right turns from A27. The directional arrows NSN on the A286 in Fig 7.3.5 are so indistinct they do not appear to agree with the Table statement. I corresponded with PBA's Paul Gebbett who wrote 'Agreed, this is not clear on the figure, the nearside lane on the A286 in both directions is for straight ahead and right turn and offside lane for right turn only'. In response to my query 'The words at the RHS of the drawing are incomplete, but look as though they say the footbridge should be pulled down and replaced with a signal controlled at-grade pedestrian crossing. Is this correct?' he wrote 'The text referred to in the figure, should have been removed as it refers to the previous 2029 mitigation on which this mitigation was based. Our mitigation does not propose to remove the footbridge'.
Thus, PBA are acknowledging significant and misleading errors in their report and I think that CDC would not have to expect a local person to have to contact PBA direct to get clarification.
PBA are also acknowledging their reliance on and 'cut and paste' of previously produced A27 reports, which raises doubt about how much original, newly informed and up-to-date data has been used, which has been properly tested against current conditions for its relevance.

Consultation documents should be accurate and easy to read/understand. An Executive Summary which easily and clearly identifies the differences of the report from reports produced over the recent years is needed. This would have revealed exactly how much or how little account was taken of all the work that went into the BABA27/Systra exercise. That this is lacking raises the question of how 'desk top' PBA's study is and how much liaison and consultation with WSCC concerning Systra actually took place. PBA are also acknowledging their reliance on and 'cut and paste' of previously produced A27 reports, which raises doubt about how much original, newly informed and up-to-date data has been used, which has been properly tested against current conditions for its relevance.
PBA's proof reading of their report is woeful. The lack of clarity with Fig 7.3.5 is repeated elsewhere in the report. Improvements = CDC insist that consultants produce accurate reports. How else can a properly informed consultation take place?

The PBA report states 'At this time, the study (Systra) is desk top only and no formal modelling or design has been progressed.' PBA thus appear to dismiss the Systra and BABA27 work in its entirety.

PBA have taken no account of all the background work leading to the 2 concepts of the Systra consultation, which identified key issues needing resolution eg separating through and local traffic. If these had been taken account of, the proposed unworkability of roundabout (rbt) mitigations would have become clear as traffic would have to use local narrow, residential roads within the City, with speed bumps, schools, residents' parking to compensate for inaccessible roundabouts.
For example, no right turns for westbound traffic from the A27 onto the A286 at the Stockbridge and Whyke rbts - traffic for the Southern Gateway and Whyke would have to leave the A27 at the Bognor rbt and use Quarry Lane and Kingsham Ave and Kingsham Road, both narrow residential roads. Or, would have to continue west on the A27 to the Fishbourne rbt into Ave de Chartres and then onto Terminus Road. But no right turn into Stockbridge road don't allow access to John Rennie Road, South Bank and Kings Ave, Lacy House and Byron Court.

Allow right turns from A27 to north/south A286 and B2145. Redo analysis of traffic flows taking account of local traffic needs and analyse more accurately the conflict arising from PBA's non-separation of through and local traffic and whether their proposals will accommodate the additional traffic. Any further work by PBA or any other consultant must take account of the Systra consultation.

Air quality at the A27/Stockbridge junction deteriorates year on year. Although monitoring of NO2 at the junction shows levels generally below the prescribed upper limit, adequate monitoring of particulates and NO2 for 200m from the junction on the A286 north and south is not done. Several blocks of student accommodation, apartments for retirement and health impaired people, most of whom are elderly, are located on these stretches of road. Residential dwellings line both sides of these stretches of road and form effective traps for vehicle emissions. It is difficult to conceive that bunching of idling vehicles at the A286 north/south traffic signals will not add to further deterioration in air quality and residents' health.
No account is taken of the damaging effect recurring/constant air pollutants cause to people with already-compromised respiratory health, resulting in unnecessary health and well-being deterioration, reduced mobility, increased medication and reduced enjoyment of life.

The impact of air polluants is not a 'one size fits all'. The demographic of the population must be recognised. In addition to the elderly population on the Stockbridge Road from the railway lines to the junction, there are large schools with their playing fields immediately adjacent to the A27 between the Stockbridge and Whyke junctions. The foot/cyclepath alongside the A27 is used by schoolchildren and others to access the school. The Free School just south of the Whyke rbt will be affected by vehicle emissions from idling traffic queuing at the S-N lights on the Whyke B2145 junction.
Signalising the Stockbridge and Whyke junctions for the benefit of through traffic does not benefit people. Air quality impacts argue for separation of through and local traffic.

Traffic noise on the A27 increases year on year as its volume increases. The further predicted increases will maintain this trend. Signalising the Stockbridge junction will result in bunched traffic accelerating away from the lights, with high-powered motorbikes particularly accelerating hard to get past traffic. This already is very noisy, especially in the evenings and at weekends (when motorbike convoys use the A27), and will get even more so. Even good quality double glazing does not exclude the noise and leaving south-facing windows open in good weather is impossible.
Despite PBA's conclusion that noise will not be a problem, they acknowledge some roads merit further study. Since Appendix H 'Noise assessments' does not open on my computer, it is not possible to examine how noise was measured, what time of day etc.

Signalising the Stockbridge junction for the benefit of through traffic does not benefit residents. Separating through and local traffic would reduce traffic volume and reduce the stop/hard acceleration noise. Even though this noise is not continuous, its occurrence is sufficiently frequent and loud to ruin outdoor enjoyment.

Page 92, 6.5 states 'The strategic development locations will be planned and designed to be of a high standard as sustainable development, well integrated with existing settlements and neighbourhoods.'
Compare this with the Chichester Gate Design Concept...'the proposed design will provide a high quality development that formalises a historic gateway into and out of Chichester. Located along the city's principle southern approach.....the development creates a strong and lasting impression as visitors travel along Stockbridge Road.'
And look at what we got. Chichester Gate with its unused piazza and tawdry, empty premises is the template of how not to do it. The planned Southern Gateway development will be very visible to all, residents and visitors. Chichester Gate is a reminder of CDC's failure to deliver its aspirations.
The Southern Gateway development may follow a similar trajectory, not meeting CDC's flagship project aspirations as developers/builders sacrifice quality to higher/denser buildings, poor and low cost design and build. Good design and use of good materials doesn't have to imply high cost. It implies imagination and flair.
Across the Stockbridge Road is the John Rennie Road development whose design brief was 2 storeys with the occasional 3rd, but resulted in 3 storeys with the occasional 4th. Is this now the CDC ruling for building height and bulk?

Strengthen the quality and rigour of CDC's planning scrutiny and enforcement processes at all stages.
Disallow piecemeal development of different standards occurring as a result of the main developer selling parcels of land to 'sub-developers'. Appoint/co-opt a Design Champion - perhaps an architect who represents good practice, design etc, to work with and advise CDC and developers. Use the Design Codes system to define more accurately design requirements.

PBA's report Table 7.1 states no right turns from A27. The directional arrows NSN on the A286 in Fig 7.3.5 are so indistinct they do not appear to agree with the Table statement. I corresponded with PBA's Paul Gebbett who wrote 'Agreed, this is not clear on the figure, the nearside lane on the A286 in both directions is for straight ahead and right turn and offside lane for right turn only'. In response to my query 'The words at the RHS of the drawing are incomplete, but look as though they say the footbridge should be pulled down and replaced with a signal controlled at-grade pedestrian crossing. Is this correct?' he wrote 'The text referred to in the figure, should have been removed as it refers to the previous 2029 mitigation on which this mitigation was based. Our mitigation does not propose to remove the footbridge'.
Thus, PBA are acknowledging significant and misleading errors in their report and I think that CDC would not have to expect a local person to have to contact PBA direct to get clarification.
PBA are also acknowledging their reliance on and 'cut and paste' of previously produced A27 reports, which raises doubt about how much original, newly informed and up-to-date data has been used, which has been properly tested against current conditions for its relevance.

Consultation documents should be accurate and easy to read/understand. An Executive Summary which easily and clearly identifies the differences of the report from reports produced over the recent years is needed. This would have revealed exactly how much or how little account was taken of all the work that went into the BABA27/Systra exercise. That this is lacking raises the question of how 'desk top' PBA's study is and how much liaison and consultation with WSCC concerning Systra actually took place. PBA are also acknowledging their reliance on and 'cut and paste' of previously produced A27 reports, which raises doubt about how much original, newly informed and up-to-date data has been used, which has been properly tested against current conditions for its relevance.
PBA's proof reading of their report is woeful. The lack of clarity with Fig 7.3.5 is repeated elsewhere in the report. Improvements = CDC insist that consultants produce accurate reports. How else can a properly informed consultation take place?

The PBA report states 'At this time, the study (Systra) is desk top only and no formal modelling or design has been progressed.' PBA thus appear to dismiss the Systra and BABA27 work in its entirety.

PBA have taken no account of all the background work leading to the 2 concepts of the Systra consultation, which identified key issues needing resolution eg separating through and local traffic. If these had been taken account of, the proposed unworkability of roundabout (rbt) mitigations would have become clear as traffic would have to use local narrow, residential roads within the City, with speed bumps, schools, residents' parking to compensate for inaccessible roundabouts.
For example, no right turns for westbound traffic from the A27 onto the A286 at the Stockbridge and Whyke rbts - traffic for the Southern Gateway and Whyke would have to leave the A27 at the Bognor rbt and use Quarry Lane and Kingsham Ave and Kingsham Road, both narrow residential roads. Or, would have to continue west on the A27 to the Fishbourne rbt into Ave de Chartres and then onto Terminus Road. But no right turn into Stockbridge road don't allow access to John Rennie Road, South Bank and Kings Ave, Lacy House and Byron Court.

Allow right turns from A27 to north/south A286 and B2145. Redo analysis of traffic flows taking account of local traffic needs and analyse more accurately the conflict arising from PBA's non-separation of through and local traffic and whether their proposals will accommodate the additional traffic. Any further work by PBA or any other consultant must take account of the Systra consultation.

Air quality at the A27/Stockbridge junction deteriorates year on year. Although monitoring of NO2 at the junction shows levels generally below the prescribed upper limit, adequate monitoring of particulates and NO2 for 200m from the junction on the A286 north and south is not done. Several blocks of student accommodation, apartments for retirement and health impaired people, most of whom are elderly, are located on these stretches of road. Residential dwellings line both sides of these stretches of road and form effective traps for vehicle emissions. It is difficult to conceive that bunching of idling vehicles at the A286 north/south traffic signals will not add to further deterioration in air quality and residents' health.
No account is taken of the damaging effect recurring/constant air pollutants cause to people with already-compromised respiratory health, resulting in unnecessary health and well-being deterioration, reduced mobility, increased medication and reduced enjoyment of life.

The impact of air polluants is not a 'one size fits all'. The demographic of the population must be recognised. In addition to the elderly population on the Stockbridge Road from the railway lines to the junction, there are large schools with their playing fields immediately adjacent to the A27 between the Stockbridge and Whyke junctions. The foot/cyclepath alongside the A27 is used by schoolchildren and others to access the school. The Free School just south of the Whyke rbt will be affected by vehicle emissions from idling traffic queuing at the S-N lights on the Whyke B2145 junction.
Signalising the Stockbridge and Whyke junctions for the benefit of through traffic does not benefit people. Air quality impacts argue for separation of through and local traffic.

Traffic noise on the A27 increases year on year as its volume increases. The further predicted increases will maintain this trend. Signalising the Stockbridge junction will result in bunched traffic accelerating away from the lights, with high-powered motorbikes particularly accelerating hard to get past traffic. This already is very noisy, especially in the evenings and at weekends (when motorbike convoys use the A27), and will get even more so. Even good quality double glazing does not exclude the noise and leaving south-facing windows open in good weather is impossible.
Despite PBA's conclusion that noise will not be a problem, they acknowledge some roads merit further study. Since Appendix H 'Noise assessments' does not open on my computer, it is not possible to examine how noise was measured, what time of day etc.

Signalising the Stockbridge junction for the benefit of through traffic does not benefit residents. Separating through and local traffic would reduce traffic volume and reduce the stop/hard acceleration noise. Even though this noise is not continuous, its occurrence is sufficiently frequent and loud to ruin outdoor enjoyment.

Page 92, 6.5 states 'The strategic development locations will be planned and designed to be of a high standard as sustainable development, well integrated with existing settlements and neighbourhoods.'
Compare this with the Chichester Gate Design Concept...'the proposed design will provide a high quality development that formalises a historic gateway into and out of Chichester. Located along the city's principle southern approach.....the development creates a strong and lasting impression as visitors travel along Stockbridge Road.'
And look at what we got. Chichester Gate with its unused piazza and tawdry, empty premises is the template of how not to do it. The planned Southern Gateway development will be very visible to all, residents and visitors. Chichester Gate is a reminder of CDC's failure to deliver its aspirations.
The Southern Gateway development may follow a similar trajectory, not meeting CDC's flagship project aspirations as developers/builders sacrifice quality to higher/denser buildings, poor and low cost design and build. Good design and use of good materials doesn't have to imply high cost. It implies imagination and flair.
Across the Stockbridge Road is the John Rennie Road development whose design brief was 2 storeys with the occasional 3rd, but resulted in 3 storeys with the occasional 4th. Is this now the CDC ruling for building height and bulk?

Strengthen the quality and rigour of CDC's planning scrutiny and enforcement processes at all stages.
Disallow piecemeal development of different standards occurring as a result of the main developer selling parcels of land to 'sub-developers'. Appoint/co-opt a Design Champion - perhaps an architect who represents good practice, design etc, to work with and advise CDC and developers. Use the Design Codes system to define more accurately design requirements.

The link road between the Birdham Road and the Fishbourne roundabout has long been a favourite of the planners. It would reduce congestion at the Witterings roundabout on the A27 Chichester by-pass, but only by further overloading of the Fishbourne roundabout. Extra traffic would be generated to the right of the Fishbourne Road entrance/exit, further lengthening queues through Fishbourne; already lengthy throughout the day (not just at rush hours). A solution for the whole of the by-pass is needed, and I support the scheme proposed by the joint group of local councils to the Highways Authority - it is unacceptable that the Highways Authority has turned this down without giving good reasons, and used this as an excuse to withdraw funding. In the meantime, I am opposed to "tinkering" with the by-pass, which will not resolve anything, but will only move problems from one location to another.

This additional policy is welcomed and its purpose in the Plan is supported including the proposed new road connecting Birdham Road to A27 Fishbourne roundabout (see Policy AL6), known as the Stockbridge Link Road when first proposed by Highways England as part of Option 2b in the 2016 Consultation.

I appreciate that the housing numbers proposed in the LPR have been imposed by central government, but for CDC to refer to the housing target numbers as minimums appears seriously flawed. This will surely encourage developers to submit plans for greater numbers than might otherwise be the case. It also makes it very difficult for local communities to resist further development when the "minimum" figure has been reached. The housing numbers imposed are already greater than the district can reasonably bear, so for CDC to set minimum targets is doing a great disservice on all counts, and particularly on environmental grounds.

Chichester district already suffers from insufficient road capacity and the plans for the A27 junctions and link road will not solve the problem. The junction changes will not solve the lack of road capacity for through and local traffic, and restricting right-hand turning at junctions will make local journeys more difficult. The proposed AL6 link road would direct more traffic off the A27 on to the A286, one of the most congested roads in the district, providing access to some of the most popular tourism destinations on the Manhood Peninsula. For this reason alone it should be resisted.

I am concerned that East Wittering/Bracklesham have been classed as a "settlement hub". The definition of a settlement hub should include good access to the main road network, the rail network, employment and secondary and higher education facilities. These villages do not have easy access to these services, being situated in a "cul-de-sac", on the congested A286. They are essentially rural, seaside communities which rely heavily on tourism for their economy and it is their rural nature which attracts so many visitors. The 350 minimum homes proposed for these two villages would have severe implications on all aspects of the local infrastructure, particularly the roads.

Living off Bell Lane in Somerley, I would like to draw your attention to the findings of the Peter Brett Transport Study for the LPR. It states that the forecast for the increase in road noise arising from a further 350 homes in East Wittering/Bracklesham along the length of Bracklesham Lane, the B2198, is "major". Bracklesham Lane leads into Bell Lane as it passes through the Somerley Conservation Area and it is vital that mitigation measures should be taken to reduce the effects of the additional traffic noise, preferably in the form of a speed limit reduction to 30mph. The accident rate on this road is already higher than average, including fatalities.

Selsey, another "settlement hub", has been badly affected by excessive suburban development in recent years with no improvement to its local infrastructure. The further extensive housing numbers proposed for this fishing and seaside village risk undermining its attraction to tourists. It is important that development of these seaside communities is carefully designed and limited in numbers to prevent over-suburbanisation. It should also be recognised that the geography of the peninsula means that access to and from the coast will always be restricted and subject to severe congestion. Additional housing on the Manhood Peninsula will only worsen this unresolvable situation and must be considered with caution to maintain its attractiveness to tourists who contribute so greatly to the economy of the Chichester district.

The Manhood Peninsula is also one of the last remaining rural hinterlands on the south coast plain. It contains several internationally designated habitat sites which are among the most important wildlife areas in the Chichester district. CDC should consider strengthening the ICZM to recognise the international importance of the peninsula, further safeguarding its environment and associated green tourism. The provision of wildlife corridors are probably more important here than anywhere else in the district. In addition, the AL6 proposed link road and commercial development would be adjacent to internationally designated habitat sites, cross two flood zones, and impair significant views of the cathedral and the Downs, contrary to CDC's ICZM policy. This proposed road appears to fail on all counts.

In conclusion, therefore, I would ask CDC to abandon proposals for the AL6 link road and junction changes on the A27, which are a waste of money, and instead urge the government to invest in a long-term, sustainable solution for the A27 so that the district is more able to accommodate the increased housing numbers being imposed on it. I would also like to see the minimum housing target numbers changed to maximum and remove East Wittering/Bracklesham as a settlement hub for the reasons set out above.

As a Grosvenor Road resident I strongly support the proposal for a new road connecting Birdham Road to A27 Fishbourne roundabout. This will significantly reduce the traffic flow along Stockbridge Road south of the Stockbridge roundabout which will have three benefits. 1: It will make it easier for traffic to join Stockbridge Road from side roads. 2: It will make Stockbridge Road safer for pedestrians. 3: Reducing the number of northbound vehicles queuing for the Stockbridge Roundabout will reduce pollution from exhausts.

Chichester has failed to make any meaningful improvements to the cycle network in the past 20 years which I have enjoyed living here.

Centurion Way is an excellent backbone of our town cycle network yet it has barely been touched since Sustrans passed it on. The Network Rail Cycle / Footbridge is rushed and way below optimal.

Please reinforce your plans for dedicated cycle / walking paths to connect all 4 quadrants of the City outskirts to the centre.

A car free City Centre has been discussed and apparently rejected. Cycle access has been further restricted without any evidence that allowing cycling on North and East Street is a problem. Stop cars not bicycles!

We must act to reduce our blind dependence upon cars and fossil fuels.

A27: I reject the Northern bypass option. Invest in rail infrastructure, clean and cheap local buses and train links.

Congestion will be increased along the A27 between Whyke and Fishbourne, pedestrians and cyclists accessing the city will be subjected to increased pollution. The canal path will not be a pleasant place if it is to be a highway to the town, it can only take so much traffic (cyclists/pedestrians).

Considering the amount of disruption the partial replacement of one bridge caused these A27 changes would be make Chichester an unpleasant place to live or visit (a place to be avoided) for several years.

Policy S21Planning For Health and Wellbeing + Section 5.19 Transport Infrastructure + Para 1.2.2 are not synchronised in their documented statement to the public . Can the public be enlightened as to why , that given the extent of the tourist season for weekend traffic, holiday population increase in the summer, the Goodwood Events that bring both the A27 and the inner city rat runs to a halt . must have been discussed by Officers/CDC Exec/CDC Cabinet before the Scope of the Transport Study was concluded. Para 3.4.2 in the Transport study references para1.2.3 which clearly has been removed and not included the Consultant Scope Study. Why ?

Stockbridge Link Road: PBA Report pp80-82

The new Stockbridge Link Road (PBA report pp80-82) is stated in Policy S23 to "promote sustainable modes of travel". There is no provision whatsoever in the PBA document (see maps on pp66-68) for walking/cycling from Chichester centre (e.g.bus/railway) across the A27 to the proposed development of area AL6. The road itself is therefore largely proposed to support that development.

There will be traffic flow change through to the Witterings from the A27, however, the policy clearly states that the development of the link road is contingent upon funding from the development of site AL6. This area was previously excluded from development plans (December 2016 Report: Site Allocation: Proposed Submission Development Plan Document 2014-2029 Methodology and Assessment - Table 9.1 P 40). The Sustainability Appraisal in November 2016 states: "Overall this site has the most negative impacts and the fewest positive of all the Chichester options."

The Peter Brett Transport Study estimates that the cost of mitigation measures at £68m, this level is clearly way beyond the level at which it could be funded by developer contributions. Without defined future funding plans, housing development should be phased in line with actual funding.

In the Brett Transport Study in the Appendix dealing with Air Pollution, given what they say in 3.2.22 and particularly in 3.2.23, it is staggering that in 3.2.24 they make their glib 'standard' statement when we know already that 4.1% of deaths in Chichester are due to PM2.5 pollutants from vehicle emissions.
How can 3.2.24 consider future vehicle uncertainties ref 3.2.22, if they are uncertain? There is no risk analysis in the Brett report to support the assertion that: the report is 'an appropriately conservative assessment.' The real risk to lives in this area is too significant to be dealt with in this superficial way.

The details in paras 5.21 to 5.24 have not been addressed in Policy S23.

Para 5.26 should refer to both County and District Councils preference to a Northern By-pass.

The proposals for mitigation at the A27 roundabouts and the new road from Stockbridge to Fisbourne roundabout are in effect the same as the option offered by HE in their most recent consultation, and also previously in a consultation on the A27 in 2004. They have been roundly rejected by the people who live on the Manhood and to the South East of Chichester on the grounds of producing more chaos than currently exists. The proposals attached to the plan make no prediction of the effects on air quality, particularly the reduction of particulates which should be the first priority for any changes to the roads given the proximity of the City's schools to the road and the rising evedence for long term health damage by particulate air pollution

Resident of West Wittering
People travelling across the Stockbridge Roundabout are faced with ever increasing levels of pollution. This will only deteriorate further if further housing is built on the Manhood Peninsula. Only a Northern A27 bypass will reduce the level.

POLICY S23 promises a travel plan to "achieve timely delivery of transport infrastructure to support new housing". A comprehensive travel plan would be welcomed but "timely delivery" would require the provision of the infrastructure before the building was completed.

Paragraphs 5.23 - 5.25 reference the support given to a northern bypass and a reasonable alternative of a full southern upgrade by CDC and uncertainty over funding. This position and uncertainty is now out of date following statements by HE that neither scheme is feasible or affordable. These paragraphs should be updated to reflect the current situation which is that no viable scheme capable of central government funding is available

I object to the insertion of the Stockbridge Relief Road. Any road building will only attract more traffic, congestion and pollution in future,which given climate change we cannot afford. We need to limit travel in individual cars and encourage instead public transport use.

This strategy should include a package of measures to improve inner city junctions to allocate more space for people on foot or on bikes eg New Park Road junction near the University, Eastgate and the roundabout near Sainsbury's.