Policy S23: Transport and Accessibility

Showing comments and forms 121 to 150 of 194

This is an exceedingly long section to comment on and extremely important to the success, or otherwise, of the Plan. Additionally there has been insufficient community engagement on Primary Evidence Document 013 (Transport Study of Strategic Development Options and Sustainable Transport Measures) to make its contents and conclusions accessible to the communities CDC wishes to encourage to help shape the area in which they live!

The Peter Brett Associates report (Primary Evidence Document 013 - Transport Study of Strategic Development Options and Sustainable Transport Measures) is mis-named. It is primarily a traffic study with just four pages (130-133) dedicated to "Sustainable Transport Options". The version online is of poor resolution with Figures awkward to read. This is not a sound evidence base for a Plan which seeks to encourage the use of sustainable modes of travel as an alternative to the private car, with para. 5.27 of the Local Plan Review recording "A key objective is to achieve a significant shift in travel behaviour aimed particularly at reducing car use for short distance journeys.

With reference to PBA's report numbering/references:
7.3.4 AND 7.4.19 there is a key watercourse (likely chalk stream) which runs in a culvert underneath Parklands, including Bishop Luffa School fields, under the railway, past Tesco petrol filling station and under Cathedral Way/Terminus Road to the fields south of the A27 Fishbourne roundabout; if this watercourse is not treated with care, parts of Parklands can be expected to flood;
7.4.17/Figure 7.15, et seq "Jct 10 A259 Cathedral Way / Fishbourne Road / Terminus Road fails to identify and retain/enhance existing pedestrian crossing facilities - there is simply no mention made of non-vehicular transport at all! This highlights the failure of the study to engage with the realities of sustainable transport. (Since the construction of the Network Rail bridge to replace the Westgate/Fishbourne Road East level crossing, a number of cyclists also choose to use this route.)

The PBA report seems to make no mention of Phase 2 West of Chichester development either in Committed Developments (e.g. Table 5.1) or as a Strategic Site in Table 5.4. Has it been overlooked?

I am submitting this Objection on behalf both of myself and of Parklands Residents' Association. We are extremely concerned by the minimal attention given to effective walking and cycling infrastructure and understanding pedestrian/cycling flows and desire lines and that significant increases in traffic are predicted along Westgate, Parklands Road and Sherborne Road, with the potential to disrupt sustainable travel, increase noise and air pollution (particularly at peak times which coincide with sustainable travel peaks, and at the school runs). We aspire to Healthy Streets ( https://www.sustrans.org.uk/liveable-neighbourhoods?gclid=EAIaIQobChMI_ezGpsmq4AIV7rvtCh0MhQ7uEAAYASAAEgLU8fD_BwE ) as mentioned at 11.2.8 of PBA's report yet the report on which para.s 5.15 to 5.33 and Policy S23 are based appear to take us in the other direction.

We wish to work with CDC to better understand and improve this section of the Plan, and attach a list of comments and questions, but in the meantime OBJECT on the basis that the proposals as explained by the PBA report appear detrimental to Parklands and contradictory to the objectives of the Plan.

Attachments:

2019-02-07 V2 PBA TRANSPORT ASSESSMENT SUMMARY B BY PW.pdf (163.85 KB)

Full text:

Our concerns are mainly to do with the overburden of the A27, particularly at Stockbridge and Fishbourne where we are very concerned about the air quality and high levels of pollution. With the traffic often at a standstill this is not being given enough consideration in the plan. Building more houses, with more cars, in this area will only make the matter worse.

4.98 This high level extraction is a rerun of Option 3 of the failed Highways England (HE) consultation and none of it will resolve the issues during rush hour and adverse circumstances such as beach traffic. Nor for that matter does it offer a strategic alternative route in the event of road closure. The problems of the A27 and its proximity to the city are the issue that currently exist. Nothing is or will be done to mitigate these within the adopted plan or this proposed revised plan. This plan does not integrate with the mitigated Northern route that we have all campaigned for. We must (as described in planning legislation) plan for an integrated solution which addresses the immediate, and future transport requirements. This policy of tinkering with the junctions will not resolve the issues of the A27.

We are also very worried about the proposed development at Apuldram. This is a flood plain and unsuitable for development. It would also destroy the iconic view of the Cathedral from the coastline.

The views of the cathedral and the South Downs from the sea and the Apuldram area (the only one where both are in one view). Views are a consideration for refusal of suitable land elsewhere within the plan yet this is not applied to this site. This affect on iconic views and habitats are further desecrated by an elevated road which is not affordable and was resoundly rejected by the public in 2016. There is no justification for the link road in the plan and the detailed impact is not available for us to comment on.
The proposed link road would remove the natural barrier between Chichester and the AONB and therefore needs to be removed as other areas have been removed for this same reason in this revised plan.
No consideration has been made for the Pollution impact including AQMA, Light into the dark skies of the AONB and noise.
17th 5.44 This statement is probably the most important statement in the plan so far "The landscape of the coastline is characterised by its relatively flat topography which, on occasion, serves to provide views from the water across to the South Downs National Park." The proposal to build SW of Chichester will not only spoil this view but will also spoil perhaps the only view framed by the South Downs of the cathedral in the whole area with employment sites and housing and with a proposed raised link relief road through countryside bordering the Chichester Harbour AONB. Unless this is adequately addressed in future iterations of the plan I will wish to raise this with the examiner at the appropriate juncture.

Waste - all of the development SW of Chichester the plan acknowledges the waste issue but does not propose a plan for a solution. As we know this will directly impact on our AONB and the harbour for water users and will impact the blue flag status of one of the areas greatest tourist attraction but is not considered in this local plan in any concrete detail. 3000 residential properties will have a massive effect on our status as a AONB.

AL 6 is wholly un appropriate for development as it:
a. Affects the AONB on its border:
i) Light pollution.
ii) Noise Pollution.
iii) Waste water issues. iv) Habitat risk.
v) Green buffer between Chichester and AONB vi) Only view of cathedral from the sea lost
vii) Unsuitable for residential property due to flood plain
viii) Green buffer between Chichester and Manhood
b. Proposed link road:
i) Ruined views of cathedral framed by South Downs
ii) Traffic congestion onto Fishbourne roundabout moves pollution
iii) Loss of Salterns way
c. Employment space in floodplain:
i) Noise pollution
ii) Light pollution into AONB Sustainability Statement
Air quality - PBA say that the development will not increase air quality issues but makes scant mention of the current AQMA and more importantly states "Outside of current air quality management areas (AQMAs)". There is no mention that the Stockbridge AQMA will improve with any of the proposed junction improvements and as such this should be rejected especially the proposed link road. No mention is made of the effect to the AONB of building the proposed link road. The reality is that what these proposals will do is move and extend the AQMA. Unless this is adequately addressed in future iterations of the plan I will wish to raise this with the examiner at the appropriate juncture.

Comment

Local Plan Review: Preferred Approach 2016-2035

Representation ID: 1937

Received: 07/02/2019

Respondent: Mrs Sally Mountstephen

Representation Summary:

The A27 in present form and proposed northern route (2016) no supported on following grounds:
- Present southern route unworkable
- Northern route unaffordable
- Proposed link road in AL6 would push traffic south, roads not capable of coping with increased traffic
- Cost of mitigation measures not enough

Full text:

I write to express my comments on The Local Plan - Preferred Approach

I have lived in West Wittering on the Manhood Peninsula for the last 19 years.
The Manhood Peninsula is a unique area which relies heavily on tourism, agriculture and horticulture; within its boundaries lie the Chichester Harbour Area of Outstanding Beauty (ANOB) and the Pagham Harbour Local Nature Reserve (LNR).
It has only 2 main access roads leading to the A.27.

While I have huge sympathy for the CDC being dictated to by the Government in relation to how many houses, retail units and commercial development they wish to see built, they do not take into consideration the countryside they want it built on.

Therefore I cannot support your view of the way forward (up to the year 2035) as being manageable or workable.

The one massive sticking point is the A.27 itself. I believe there is a considered view that the A.27 in its present form and the proposed northern route round Chichester (2016) is unworkable and unaffordable - the present southern route being unworkable and the northern route unaffordable.
The proposed spur road AL6 (which is Option 3 from the 2016 consultation which was dismissed as it was admitted the road would have to be upgraded to a dual carriage way within 12 years to cope with the increased traffic) from the Tesco's roundabout to link with the A.286 via a roundabout would merely push the traffic south and cause further havoc = eg: cars wanting to access the new Chichester Free School would have to then drive across Wophams Lane, through Hunston to the school, both roads are narrow and are not capable of coping with a huge flow of traffic. Those roads are already used by locals who wish to avoid the congestion on the A.27.

Once upon a time there were traffic lights on the A.27, these were removed and replaced with roundabouts, now you propose to put back traffic lights at the Stockbridge and Whyke roundabouts with no right turn if you are driving in a west - east direction. I have heard the cost to be in the region of £80 million pounds, money you do not have. Just leave the A.27 alone until someone with a vision of the future needs of Chichester has the guts to implement a northern route.

I quote 2 reasons why: An accident on the A.286 on 2nd February 2019 closed the road for 5 hours; a cyclist was killed on 10th May 2018 the A.27 was closed for approx 9 hours. The surrounding roads and Chichester were gridlocked.

The minimum number of houses the CDC proposes to build are: the Manhood 1,933, an east-west corridor of 10,056, with a token number of 489 for north of the area plan make no allowances for the inadequate number of police, doctors, schools and transport we already have in place. The East Wittering's Medical Centre had listed over 10,300 patients registered in 2018 - where is the provision for more medical centres?
All these extra houses will have at least one car per family, reality says two cars; how on earth is the A.27 going to cope with these larger numbers when it cannot cope with today's numbers?

The A.27 is the crux of the problem - get that sorted; then the CDC will have a mandate for the future.

Attachments:

Sally Mountstephen [7239].pdf (37.46 KB)

Object

Local Plan Review: Preferred Approach 2016-2035

Representation ID: 1958

Received: 05/02/2019

Respondent: Ms Ann Stewart

Representation Summary:

Object - LPR pays lip service to promoting transport alternatives such as walking, cycle routes, public transport and EV charging points.

Full text:

Policy S 6. Affordable Housing
Paragraph 5.comment
Where a proposal is unable to meet the1 requirements for the delivery of affordable housing due to it rendering the proposal financially unviable, developers will be expected to assess options in accordance with the following

Changes Insert
1 Where the authority has been satisfied that a proposal is genuinely unable to meet the requirements

Justification
The required numbers of affordable housing are simply not being delivered.
Reports by the charities Shelter and CPRE show that developers frequently break promises about the number of affordable housing they will deliver, using a the "viability" loophole. The loophole involves paying high prices for land in the knowledge that the overpayment can be recouped by reducing the obligation to deliver a specified number of affordable houses.
The authority needs to be able to challenge any claims of non-viability, and the onus of proof should be firmly on the developer. Where the developer claim an exemption this should be thoroughtly scrutinised
https://www.thetimes.co.uk/article/loophole-lets-developers-halve-number-of-affordable-homes-8nn3kmcj7
https://www.theguardian.com/politics/2018/mar/03/affordable-housing-rural-england-planning-laws-loophole-exploited-developers-report
https://www.s106affordablehousing.co.uk/

Policy S24 Countryside.  Section 5.36 comment
Paragraph
Areas outside settlement boundaries are defined as 'countryside' which includes villages, hamlets, farms and other buildings as well as undeveloped open land. In order to protect the landscape, character, quality and tranquillity of the countryside 1 it is essential to prevent inappropriate development. At the same time, it is necessary to provide for the social and economic needs of small rural communities, and enable those who manage, live and work in the countryside to continue to do so.

Changes Insert
1 tranquility, the natural environment and biodiversity of the countryside

Justification
The terms "landscape character, quality and tranquillity of the countryside" imply a limited valuation of the countryside- ie. as long as it looks nice and sounds nice....

This ignores the important issue of biodiversity loss and can make it easier to overlook biodiversity needs and allow developments that will increase the catastrophic losses of recent years.

The Living Planet report of 2018, published by the WWF reports that humanity has wiped out 60% of mammals, birds, fish and reptiles since 1970.

The 2016 State of Nature Report states that the UK is one of the most nature depleted countries in the world, and that in the UK one in ten species is threatened with extinction.

The loss of biodiversity leads to the loss of the many services that they provide, ie. flood control, water and air purification, nutrient recycling, carbon sequestration, pest control, pollination etc.

Section 5.38
Paragraph Object
The Council also wants to find ways of enhancing the character and appearance of the countryside, the amenities and opportunities that it offers, and its biodiversity1. However, there are dwellings and enterprises in these countryside areas, and particular needs arising from rural activities.2
To support a prosperous and diverse rural economy, some limited and carefully planned development may be acceptable to enable the countryside and local rural communities to evolve and thrive. 3

Changes Insert
1 while protecting its biodiversity

2 However, there are dwellings and enterprises in these countryside areas, and particular needs arising from rural activities, which can compete or conflict with these.

3 Where these conflict with the obligations towards character, tranquillity and biodiversity, mitigation measures will be required.

Justification
We are already suffering incremental loss of the countryside. The 2018 report by the CPRE. Government data shows that the loss of greenfield land to development has increased by 58% in the last four years. The present wording in the local plan still seems to give some preference to development in such a way that it will continue this incremental loss.

https://www.cpre.org.uk/media-centre/latest-news-releases/item/4867-countryside-being-lost-to-housing-at-an-alarming-rate-increase-brownfield-development

Section 5.40
Paragraph comment
Where development is proposed in the countryside, the Council will seek the beneficial management of the countryside. This will include encouragement of proposals that enhance the woodlands and recreational links1 to and within this area.

Changes Insert
1 and ecosystem links

Justification
See above 5.36

Policy S24: Countryside
Paragraph comment
Outside settlement boundaries as defined on the policies map, development will be permitted in the countryside provided that:
1. It conserves and, where possible, enhances the key features and qualities of the rural and landscape character1 of the countryside setting;  
2.It is of an appropriate scale, siting and design that is unlikely to cause unacceptable harm to the appearance of the countryside;2 and  
Changes Insert
1 rural, landscape and ecosystem character of the countryside setting

2 cause unacceptable harm to the appearance, ecosystems and biodiversity of the countryside

Justification
See above 5.36 5.38 5.40

Policy S26: Natural Environment
Section 5.50
Paragraph comment
The natural environment is under significant pressure to accommodate a range of demands1. This includes modern farming practices which have an influence on the evolving2 landscape and biodiversity of our countryside as well as development that more directly facilitates addressing housing needs and provides for economic growth.3

Changes Insert
1a range of demands that are often conflicting

2have often contributed significantly to the loss of many native species, biodiversity and local ecosystems

3developments that address housing needs and provide economic growth contribute significantly to this loss of the natural environment

Justification
The Living Planet report of 2018, published by the WWF reports that humanity has wiped out 60% of mammals, birds, fish and reptiles since 1970.

The 2016 State of Nature Report states that the UK is one of the most nature depleted countries in the world, and that in the UK one in ten species is threatened with extinction.

Both reports state that agricultural practices are one of the main drivers of this decline, but that road building and housing are causing ever increasing fragmentation of the countryside. This leads to the collapse of viable habitats and the loss of species and ecosystems at an unprecedented rate.

The loss of biodiversity leads to the loss of the many services that they provide, ie. flood control, water and air purification, nutrient recycling, carbon sequestration, pest control, pollination etc.

Section 5.51
Paragraph comment/comment/object
In seeking to reconcile these1 demands on the natural environment, the Council will only support proposals that do not cause significant harm to the function2 of the natural environment. This includes ensuring the richness of the landscape and biodiversity of the area is not unduly compromised,3 with opportunities taken to enhance their value where appropriate.

Changes Insert
evaluate these conflicting1 demands

2 to the networks that are part of an integrated and functioning natural environment.

3The council will protect the richness of the landscape and biodiversity of the area.
Where developments are likely to compromise the natural environment, strategies that cause the least harm will be used, ie. using brown field sites wherever available as a matter of priority. The council will also prioritise development that have a smaller footprint and therefore require less land.

Justification
A report by the CPRE in 2016 states that there were enough brownfield sites in England to build 1.1 million new homes. There were almost enough brownfield sites for the councils participating in the report to meet their five-year housing targets without releasing any countryside for development.

https://www.cpre.org.uk/media-centre/latest-news-releases/item/4414-more-than-a-million-homes-possible-on-suitable-brownfield-land

Section 5.53
Paragraph object
Much of the undeveloped coastal plain of the plan area is high quality agricultural land which falls within Grades 1, 2 and 3a of the Agricultural Land Classification. In planning for the sustainable growth of the plan area, it is recognised that there may be occasions when the loss of such land is necessary. 1

Delete and replace

1 Where loss of such land may be thought necessary, this can only be granted when all other options have been fully explored and it has been comprehensively demonstrated that there is no alternative.

Justification
The loss of agricultural land has serious consequences for our food self-sufficiency. Defra states that we only produce 60% of our food and this is declining further. Moreover, this level of production relies on intensive farming methods that harms our natural environment and is contributes hugely to biodiversity loss. A recent CPRE reports shows that intensive farming methods are seriously degrading our soil and that future productivity will consequently be reduced. Measures needed to protect agricultural soils have to be less intensive, and consequently less productive. It is important that the loss of agricultural land is kept to an absolute minimum.

https://www.foodmanufacture.co.uk/Article/2018/08/07/Food-self-sufficiency-highlighted
https://www.cpre.org.uk/resources/farming-and-food/farming/item/5013-back-to-the-land-rethinking-our-approach-to-soil

S26
Paragraph object
Bullet point 4
Cons Considering the quality of the agricultural land, with the development of poorer quality agricultural land being preferred to the best and most versatile land.  
Delete and replace
Where loss of agricultural land may be thought necessary, this can only be granted when all other options have been fully explored and it has been comprehensively demonstrated that there is no alternative. The biodiversity value of all agricultural land must be considered.

Justification
Poorer quality agricultural land may have significant biodiversity value.

Policy S28 Pollution
Section 5.60
Paragraph Object
Some forms of development can result in pollutants, but are necessary to meet the economic and social needs of the plan area. These may include industrial and commercial land uses and new transport routes. Developers must submit robust and appropriate evidence to enable assessment whether there is a likely significant adverse effect on health and quality of life as a result of the development. Mitigation measures should be included in proposals where evidence suggests a likely significant adverse effect.

Changes Insert
This needs a whole extra paragraph on the problem of air pollution. It needs to acknowledge that traffic is a major cause of air pollution and that new transport routes are likely to add to the problem as new roads end up meaning more traffic. mitigation measures are unlikely to be a solution. Its needs to make a commitment to proactive measures to promote alternatives. The local plan seems to pay lip service to promoting alternatives such as walking, cycle routes, public transport and EV charging points, but delivery of these seems poor.

Justification
Air pollution, largely due to traffic emissions, is a major health hazard. (On a personal note, a member of my family died a day before his 22nd birthday, last March, from an asthma attack. His asthma was considered under medical control. He was in Bournemouth city centre at the time, so air quality is likely to have been a contributing factor to his death)
https://uk-air.defra.gov.uk/air-pollution/causes

Last year the UK were referred to Europe's highest court for failing to tackle illegal levels of air pollution.
https://www.theguardian.com/environment/2018/may/17/uk-taken-to-europes-highest-court-over-air-pollution

A recent report by the Welsh government demonstrates the cost effectiveness of investing in alternatives to road traffic.
http://www.wales.nhs.uk/sitesplus/888/news/48759

Policy DM28: Natural Environment
Section 7.169
Paragraph Comment
Development proposals must take account of international, national and local designations as part of their application. Exceptions will only be made where no reasonable alternatives are available and the benefits of development clearly outweigh the negative impacts. Where a development proposal would result in any significant harm that cannot be prevented or mitigated, appropriate compensation will be sought. 1

Changes Insert
1 However, the council also recognizes that some developments will cause irreparable harm to local biodiversity, ie ancient woodlands, and that no mitigation or compensation measures will be adequate to make up for this loss.
Where this is the case the council undertakes to
* scrutinise Environmental Impact assessments for their thoroughness and veracity.
* Consider the development along with others in the vicinity, in order to also evaluate cumulative impacts

Policy DM28

Paragraph comment
The impact of proposals will be carefully assessed to ensure the protection, conservation and enhancement of the landscape of1 the Plan area. Planning permission will be granted2 where it can be demonstrated that all the following criteria have been addressed:

Changes Replace
1 and biodiversity
2 only be considered

Paragraph Comment
1.There is no adverse impact on:
* The openness of the views in and around the coast, designated environmental areas and the setting of the South Downs National Park; and  
* The tranquil and rural character of the area.1

Changes Insert
* 1 The biodiversity of the area

Paragraph Comment
3. Development of poorer quality agricultural land has been fully considered in preference to best and most versatile land; 1  
Changes Insert
Poorer quality land will also be assessed for its biodiversity potential, and where this proves to be significant the land should be subject to the biodiversity protection measures.

Justification
Biodiversity is an essential feature of the natural environment. Treating it separately in the local plan risks a conflict between what is permitted under one heading, but not permitted under the other.

The Living Planet report of 2018, published by the WWF reports that humanity has wiped out 60% of mammals, birds, fish and reptiles since 1970.

The 2016 State of Nature Report states that the UK is one of the most nature depleted countries in the world, and that in the UK one in ten species is threatened with extinction.

This is despite considerable legislation to protect our ecosystems and biodiversity, much of it reflected in the good intention that make up part of the existing Local Plan.

The Chichester area has significant populations of threatened coastal, woodland and farmland species. Some of these populations are rapidly disappearing because of the cumulative impacts of farming practices, loss of habitat, disturbance from new developments and climate change. Populations that are barely surviving under these circumstances are likely to collapse completely if one more stress to their survival is added. Any decision to allow a development that will cause such a final collapse should not be taken lightly.

Continued below in D 29

Policy DM 29: Biodiversity
Section 7.172
Paragraph Comment
All new developments are encouraged1 to take account of and incorporate biodiversity

Exceptions will only be made where no reasonable alternatives are available and the benefits of development clearly outweigh the negative impacts. Where a development proposal would result in any significant harm to biodiversity and geological interests that cannot be prevented or mitigated, appropriate compensation will be sought. 2

Changes Insert/Replace
1 required

2 However, this in the recognition that some developments will cause irreparable harm to local biodiversity, ie ancient woodlands, and that no mitigation or compensation measures will be adequate to make up for this loss.

Policy DM29:
Paragraph Comment
Planning permission will be granted 1 for development where it can be demonstrated that all the following criteria have been addressed:

Changes Insert/Replace
1 Only be considered

Section 6
Paragraph Comment
The benefits of development outweigh any adverse impact on the biodiversity on the site. Exceptions will only be made where no reasonable alternatives are available; and planning conditions and/or planning obligations may1 be imposed to mitigate or compensate for the harmful effects of the development.  
Changes Insert/Replace
1 will

Justification
Planners must not lose sight of the fact that biodiversity requires a genuine range of habitats. For instance, while the emphasis on ecological networks and wildlife corridors is important for many species, but this is not enough.

Other species need dense woodland. with a well-developed canopy and understory, that provide a range of shelter and feeding opportunities. Developments on the edge of woodland alter habitats, and incrementally we are losing our dense woodland. Old trees are an essential feature of such woodland, providing holes and crevices for shelter and a myriad of feeding opportunities. Replanting young trees is not an adequate compensation.

Environmental Impact Assessments must be scrutinised carefully. The methods used in such assessments can, at times, be superficial and some conclusions can be misleading i.e. the presence of Bechstein bats, the rarest of UK mammals, was dismissed as "only of local value" in a planning application for oil exploration at Markwells Wood.

The loss of biodiversity leads to the loss of the many services that they provide, ie. flood control, water and air purification, nutrient recycling, carbon sequestration, pest control, pollination etc.

Our biodiversity is a precious feature of the Chichester area. While protecting this biodiversity will cause conflict with genuine housing and economic development, we have to guard against more spurious justifications. To put it bluntly, should we really lose our biodiversity for the sake of massive suburban sprawl of expensive executive homes?

Comment

Local Plan Review: Preferred Approach 2016-2035

Representation ID: 1963

Received: 05/02/2019

Respondent: Mr David Myers

Representation Summary:

Roads - increasing traffic, but crumbling roads, no A27 bypass solution.

Full text:

The following are my general comments on what I consider to be serious problems that are likely to be encountered with these latest proposals.

Based on past experience I think it fair to say that will be big problems with the lack of sufficient infrastructure (money).

Look at where we are with the current Local Plan:-

Roads - increasing traffic, but crumbling roads, no A27 bypass solution.

Foul Drainage - denials by Southern Water that there are problems. Proposal to run a sewer from Whitehouse Farm around north of Chichester to Tangmere instead of upgrading Apuldram WW treatment works. Sewer pipe problems at Bosham and elsewhere. Untreated sewage discharged into the harbour. Increasing danger to public health.

Education - existing schools short of funding Police - also short of funding
Hospitals - under pressure

The latest Plan will substantially increase the amount of development in the East - West corridor along the A259. This is likely to have an adverse impact on the wild life in the Chichester Harbour AONB, with increased public use of the shoreline footpaths.

I thought the AONB had the same status as a National Park. Surely any ideas for development likely to affect it should be treated in the same way as the NP?

The actual control of when building takes place once permissions are granted seems to rest entirely with developers?

Attachments:

David Myers [4894].pdf (31.00 KB)

Comment

Local Plan Review: Preferred Approach 2016-2035

Representation ID: 1981

Received: 07/02/2019

Respondent: Mr Anthony Tuffin

Representation Summary:

As prevailing wind is from south-west, best long-term solution would be to site A27 north of city.

Full text:

Chichester District Council
Local Plan consultation 2018/19

Comments by
Anthony Tuffin

1. There is no simple and intuitive way to comment online. A cynic could be forgiven for suspecting that the web designer had been instructed to make it difficult for the public to comment. So, I am commenting by e-mail.

2. Summary:
2.1 Selsey is not a hub.
2.2 Opportunities have been missed for development north of Chichester.
2.3 Manhood cannot cope with more development until a new A27 has been built north of Chichester.

3. 6.79 describes Selsey as 'settlement hub', but goes on to state that "it is located at the southern end of the Manhood Peninsula (Selsey Bill)" and 6.81 states, "The B2145 is the only road connecting the town to the north" As there is sea to the east, south and west of Selsey and only one road to the north in and out of the town, it is not a hub. Indeed, it is at the circumference end of just one spoke.

According to the Oxford English Dictionary, "hub" means;
* The central part of a wheel, rotating on or with the axle, and from which the spokes radiate.
* The effective centre of an activity, region, or network.
* A central airport or other transport facility from which many services operate.

I.e., "centre" or "central" is the key part of the meaning, but Selsey is neither a centre nor central.

4. The Council should not import housing need that the South Downs National Park (SDNP) refuses.

5. The Chichester District cannot accommodate future housing or employment space until the A27 uncertainty is ended. The local population rejected Highways England's last proposal.

6. Para 3.4 omits development opportunities north of the city. Including these would help us reduce the pressure to the south where there is a lack of appropriate space because of the flood plain.

7. Para 3.7 states, "The relationship between the National Park and significant natural areas to the south, especially Chichester Harbour Area of Outstanding Natural Beauty, will be carefully managed by maintaining and enhancing the countryside between settlements." How, then, can you justify the proposal at Apuldram, which would remove the only view of a cathedral from the sea in the country and long-distance views of the downs?

8. Para 3.19 Strategic infrastructure excludes the Mitigated Northern Route. Tweaking the existing A27 lacks local community consensus and would prevent us from getting a long-term solution; i.e., a strategic northern route.

9. Policy S4 Why is there no housing planned for the area between the city and the SDNP to relieve the pressure south of the city?

10. Para 4.84 "Some funding for the A27 junctions package of improvements has already been secured from planning permissions granted to date." The population of Chichester have asked for a new strategic route for the A27 endorsed by both CDC and West Sussex County Council (WSCC) in a democratic process.
We should not spend money to improve a road that is Highways England's responsibility.
It is Highways England's responsibility to provide a suitable trunk road for the south coast and it is the Government's responsibility to fund it.
CDC cannot accept housing allocation for the Manhood Peninsula surrounded by the sea and the congested A27 until the congestion is relieved.
11. DM24 air pollution. There seem no recommendations for the reduction in air pollution. As the prevailing wind is from the south-west, the best long-term solution would be to site the A27 north of the city.

End.

Comment

Local Plan Review: Preferred Approach 2016-2035

Representation ID: 2000

Received: 07/02/2019

Respondent: Mr Martin Tomlinson MBE

Representation Summary:

Attachment contends that proposed alterations/mitigations to the A27 focus on the E-W-E through flow of traffic and will make local traffic journeys longer/use unsuitable narrow residential City centre roads.

Full text:

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. Linda Boize 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 her 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.

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 alreadycompromised 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.

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?

Attachments:

Martin Tomlinson [6586].pdf (56.10 KB)

Attachments:

Summersdale Residents Association [5435].pdf (55.10 KB)

Object

Local Plan Review: Preferred Approach 2016-2035

Representation ID: 2046

Received: 07/02/2019

Respondent: Ms Sarah Lambert

Representation Summary:

The plan has no recent transport data and isn't robust enough to cope with current or future traffic.

Full text:

I am writing to Object to CDC Local Plan as I believe in its current form it will destroy large areas of Chichester's historic and environmentally sensitive areas in all but the Northern part of the city. It doesn't protect Chichester Harbour, aiming to build on the flood plain and right up to Harbour boundary. The proposed AL6 link road is on a category 3 Flood Plain that according the Governments recommendations should not be built on due to environmental damage and the risk of flooding. The plan has no recent transport data and isn't robust enough to cope with current or future traffic.

Comment

Local Plan Review: Preferred Approach 2016-2035

Representation ID: 2108

Received: 15/02/2019

Respondent: West Sussex County Council

Representation Summary:

Understandably much consideration is given to the A27 around Chichester; however, in addition to seeking new infrastructure from new development, it is recommended support in principle is given to maximising the value of existing infrastructure so as to facilitate off-road user modes accessing either side of the A27.

Full text:

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

AL1 Land West of Chichester

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

AL2 Land at Shopwhyke (Oving Parish)

No update to original response for this allocation is required.

AL3 Land East of Chichester - previously South of Shopwhyke

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

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

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

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

AL4 Land at Westhampnett / North East Chichester

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

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

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

AL5 Southern Gateway

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

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

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

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

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

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

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

AL7 Bosham

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

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

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

AL9 Fishbourne

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

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

AL8 East Wittering

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

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

AL10 Chidham and Hambrook area

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

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

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

AL11 Hunston

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

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

AL12 Selsey

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

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

AL13 Southbourne

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

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

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

AL14 Tangmere

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

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

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

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

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

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

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

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

Additional Policy Comments

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

AL6 extent

Current Flood Zone 3 extent.

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

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

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

Key:
AL6 boundary.

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

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

Map 2 Groundwater flood risk JBA

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

Attachments:

West Sussex County Council [1038].pdf (618.43 KB)