Policy S23: Transport and Accessibility

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1. I support provision of link road to reduce traffic volume through Donnington.
2. Realistically I accept need for new housing but would strongly support provision of a new primary school south of A27.
3. Air quality around Stocbridge roundabout must be addressed.
4. Existing SSI and AONB area must be respected.
5. Protect all existing footpaths/cycle ways and in particular improve existing right of way from A286 to join with the Salterns Way.

The SDNPA and all relevant authorities are required to have regard to the purposes of the South Downs National Park (SDNP) as set out in Section 62 of the Evironment Act 1995. The purposes are 'to conserve and enhance the natural beauty, wildlife and cultural heritage of the area' and 'to promote opportunities for the understanding and enjoyment of the special qualities of the national park by the public.' The Authority would appreciate reference to Section 62 being added to
paragraph 1.31 of the draft Plan.

Duty to Cooperate

As set out in our previous response, the SDNPA has a set of six strategic cross-boundary priorities.
I would like to take the opportunity to again highlight these which provide a framework for ongoing Duty to Cooperate discussions:
* Conserving and enhancing the natural beauty of the area.
* Conserving and enhancing the region's biodiversity (including green infrastructure issues).
* The delivery of new homes, including affordable homes and pitches for Gypsies, Travellers and Travelling Showpeople.
* The promotion of sustainable tourism.
* Development of the local economy.
* Improving the efficiency of transport networks by enhancing the proportion of travel by sustainable modes and promoting policies which reduce the need to travel.

Conserving and enhancing the natural beauty

We welcome the requirement in policies S26 (Natural Environment) and DM28 (Natural Environment) to ensure that development proposals have no adverse impact on the openness of views and setting of the SDNP. It is noted that a substantial amount of new homes are proposed on the A259 corridor between Emsworth and Chichester. This is a sensitive stretch of land in the coastal
plain between the coast, the south coast railway and the A27. This corridor provides the connection, including intervisibility, between the protected landscapes of the South Downs National Park and Chichester Harbour AONB, for example views of the channels within the Harbour from the Trundle and Stoke Clump.
We note the intention of identifying settlement gaps and look forward to seeing the evidence base and the proposed gaps in the Regulation 19 iteration of Chichester Local Plan Review 2035, particularly as to how they will contribute to safeguarding the relationship between the SDNP and Chichester Harbour AONB. We would welcome the opportunity to work with CDC on this matter.

Locations identified for development

Development in the CDC Local Plan Review 2035, particularly along the A259 (policies AL7 Highgrove Farm Bosham, AL9 Fishbourne Parish, AL10 Chidham and Hambrook Parish, AL13 Southbourne Parish) corridor, have the potential to deliver a significant cumulative adverse impact on the setting of the National Park and its important relationship with the Chichester Harbour AONB.
We consider that the policy wording for the A259 corridor Strategic Site Allocations could be more robust and proactive with regard to conserving and enhancing the National Park. In particular, it could provide more active direction to applicants in order to ensure adverse impacts are minimised locally, and in relation to the National Park. For example, with regard to green infrastructure, each of the
A259 Strategic Site Allocation policies (AL7, AL9, AL10 and AL13) include a criteria requiring the provision of green infrastructure, and we would suggest this could be re-worded as follows: 'Identify opportunities are taken for and secure the expansion and provision of multifunctional green infrastructure into the wider countryside and protected landscapes of the South Downs National Park, and Chichester Harbour AONB, including between settlements and facilities.'

Reference to considering and minimising impact on the SDNP in each of the A259 Strategic Site Allocation policies (AL7, AL9, AL10 and AL13) is welcomed, for example criterion 5 of policy AL9:
Fishbourne Parish. However, this could be usefully re-worded to ensure that developers do not create a scheme and only consider the impact afterwards. Wording to direct people to 'respect and respond to the National Park landscape, its setting and purposes prior to development design' avoids the risk of relying upon ill-informed and inappropriate mitigation measures This matter could also be usefully
addressed in relevant Strategic and Development Management policies elsewhere in the Local Plan concerning design, landscape, and the South Downs National Park. We would be happy to work with CDC on this matter.

We note Strategic Policy S32, which requires proposals for housing allocations and major development sites to be accompanied by a site-wide design strategy. We would strongly encourage masterplans and development briefs for each allocation (or settlement where the sites are to be allocated through a Neighbourhood Plan) to come ahead of applications and demonstrate positive design interventions which respond directly to landscape/SDNP sensitivities. We would be happy to be involved in shaping these as consultees in order to achieve the best quality scheme. These interventions could be written in to the policy wording.

There is an opportunity for allocation policies to seek to deliver the joining up of existing, and/or improvements to, the network of RoW (Equestrians, Cyclists and Pedestrians) to enable and encourage access into the National Park in accordance with the National Park's Second Purpose.
Further comments on specific allocations:
* Policy AL1 (Land West of Chichester) - We welcome the consideration of the Centurion Way in criteria 10. However, we would ask for stronger policy wording to explicitly state that development must not adversely affect, and preferably enhance usability of, Centurion Way connecting Chichester with the SDNP.
* We note that Policy AL4 (Land at Westhampnett/NE Chichester) still refers to Lavant Valley greenspace but we query if this is likely to be secured now based on planning applications submitted. We would suggest that criteria 12, last sentence, could also refer to securing offsite improvements/upgrades for cycleway links
* Policy AL6 (Land South-West of Chichester (Apuldram and Donnington Parishes)) should address the important opportunity to secure a safe off-road connection between the Centurion Way and Salterns Way as the two flagship and largely safe off-road multi-user trails linking Chichester with (respectively) SDNP and Chichester Harbour AONB. We would welcome the opportunity for further dialogue and joint working on this matter with CDC.
* We welcome criterion 5 of policy AL14 (Land West of Tangmere). It is a sensitive site due to the impact on clear views of the site from important locations in the SDNP such as the Trundle and Halnaker Hill. We therefore ask that criterion 5 is expanded to emphasise and address the sensitivity of the site
Specific wording comments on other policies/paragraphs:

We have the following comments on the following specific paragraphs:
* Para 2.29 (challenges and opportunities facing the Plan Area): We suggest that the 7th bullet point should say 'Protect and enhance the character of the area including the Chichester Harbour AONB and the setting of the SDNP'.
* Policy S20 (Design): As mentioned above regarding the A259 Strategic Site Allocation policies, we consider that the wording of this policy could be more proactive by including wording to direct people to 'respect and respond to the National Park landscape, its setting and purposes prior to development design'.
* Policy S25 (The Coast): Paragraph 5.44: We suggest adding 'serves to provide important scenic views from the water across to the SDNP which should be conserved'.
* Policy S26 (Natural Environment): We suggest deleting reference to 'openness' and to include reference to views from and to the National Park.
* Policy S32 (Design Strategies for Strategic and Major Development Sites): We suggest that the policy requires such design strategies to be informed by landscape character and the sites landscape context. We also suggest that criteria h. includes a requirement to state maximum building heights.
* Policy DM17 (Stand-alone Renewable Energy): The policy requirement for demonstrating no significant adverse impact upon landscape or townscape character is welcomed. We request reference is also made specifically of views of the SDNP.
* Policy DM19 (Chichester Harbour AONB): We request criterion three also identifies the relationship by way of intervisibility between the AONB and SDNP.
* Policy DM22 (Development in the Countryside): Further to comments on the A259 Strategic Site Allocation policies and S20 (Design), we consider that the wording of this policy could be more proactive by including wording to direct people to 'respect and respond to the National Park landscape, its setting and purposes prior to development design'.
* Policy DM23 (Lighting): The reference to the South Downs International Dark Skies Reserve is welcomed. However, proposals that aren't immediately adjacent to the Reserve may have significant adverse impact, for example due to the site's particular visibility within the landscape or sky glow; we suggest that wording is amended to reflect this.
* Policy DM32 (Green Infrastructure): We suggest that this policy could benefit from specifically citing that green infrastructure should be 'multifunctional'. We also recommend reference to opportunities to make better green infrastructure connections in line with Lawton Principles of 'bigger, better, more joined up', to ensure these spaces can function and therefore deliver benefits.

Conserving and enhancing the region's biodiversity (including green infrastructure).

The SDNPA welcomes the approach taken by CDC to identify green infrastructure and habitats networks as cross boundary issues in paragraph 1.26 of the Plan. The SDNPA looks forward to continuing to work with CDC on green infrastructure matters particularly as your Plan is progressed to pre-submission.

We note that an open space study has been prepared and this could be linked up with other work into a wider green infrastructure approach incorporating the identified strategic wildlife corridors, areas for natural flood management, PROW and connections between the settlements, protected landscapes and the stations, landscape views/settlement gaps and some land management guidelines
for these really important areas. This would be particularly useful to inform development proposals in the A259 corridor.

Policy SD30 - Strategic wildlife corridors

The SDNPA very much welcomes and supports the inclusion into policy of wildlife corridors which traverse the district connecting the two protected landscapes of the Chichester Harbour AONB and the SDNPA.

It is important to note that there is no corresponding policy within South Downs Local Plan, currently at examination, to continue protection of the wildlife corridors within the SDNP. We have concerns that it is unlikely to be sufficient for the corridors just to reach the SDNP boundary. We also note that several of the corridors appear to be quite narrow, especially to the east of the City, and we query whether they are substantial enough to perform the intended function.

We note the detailed evidence outlined in the background paper and the SDNPA would like to work with CDC on the continued development of the strategic wildlife corridors, in particular with regard to their connection points with the National Park and how we can work together on robustly delivering this strategic cross boundary objective.

Ebernoe Common, The Mens, and Singleton & Cocking Special Areas of Conservation

The SDNPA has been working together on technical advice to facilitate sustainable development within proximity Ebernoe Common, The Mens, and Singleton & Cocking Special Areas of Conservation, which are designated for their populations of Bechstein and barbastelle bats. The draft Sussex Bat Special Area of Conservation Planning and Landscape Scale Enhancement Protocol was published in 2018 in the Core Document Library as part of the South Downs Local Plan Examination. The Protocol is based on published data which identifies key impact zones, one of 6.5km and one of 12km, around each of the three SACs. It also sets out avoidance, mitigation, compensation and enhancement measures to inform and be addressed by development proposals. Parts of the Chichester District Local Plan area are within these key impact zones. These zones have been incorporated into policy SD10 of the South Downs Local Plan and the policy has not been modified by the Inspector as a result of the examination in public. The SDNPA would welcome the opportunity for further discuss with CDC and Natural England on this work.
Solent Recreation Mitigation Partnership

Both CDC and the SDNPA are members of the Solent Recreation Mitigation Partnership (SRMP) (also known as Bird Aware Solent) which has provided a strategic mitigation solution to address potential harm to the protected habitat at Chichester Harbour and ensuring compliance with the Habitats Regulations. We note that the SRMP mitigation solution is reflected in Policy DM30 and we look forward to continuing to work with CDC and other members of the SRMP on this matter.
With regard to paragraph 7.185 we suggest reference to the Medmerry Realignment be a new bullet point: 'Medmerry realignment, which is intertidal habitat created in 2013 to compensate for historic losses across the Solent to SSSI and Natura 2000 sites'.
We also suggest the following wording amendment to paragraph 7.187: '...This is particularly relevant to Chichester and Langstone Harbour and Pagham Harbour and the impact of recreational pressure on the birds that use these Special Protection Areas. Any negative impacts that the development may have should will be weighed against the benefits of the proposal. This may include looking at whether the assets are surplus to requirements, if the proposal impacts on a small area or corridor or if a wider need exists for the development and there is no alternative location....'

The delivery of new homes, including affordable homes and pitches for Gypsies,
Travellers and Travelling Showpeople

Policy S4: Meeting Housing Needs
The SDNPA welcomes the uplift to the housing target to address unmet need arising in that part of the SDNP within Chichester District (estimated at 44 dpa at the time the last Statement of Common Ground was agreed in April 2018). The provision of 41 dpa broadly meets this need.
We note that the Objectively Assessed Need is calculated only for the area outside the SDNP using the 'capping' method set out in the Government's standard methodology (the currently adopted target of 435 dwellings per annum plus 40% = 609) - this is helpful as it makes a clear distinction between the assessed need for Chichester District Local Plan area and that for the SDNPA, notwithstanding
the Duty to Cooperate.

Policy S5: Parish Housing Requirements 2016-35
We support identification of parish specific housing requirements providing certainty to local communities. This is the same approach as we have taken in the South Downs Local Plan.

Affordable housing
We note that there is a need for 285 affordable homes per annum (source: HEDNA) which underlines the need for a strong policy which seeks to maximise affordable housing delivery. This high level of need is common to the wider sub-region and is an issue relevant to the wider housing market area.
The SDNPA supports CDC's approach of taking opportunities arising from new residential development to contribute to the supply of affordable housing, to meet local needs in terms of type and tenure (paragraph 4.35). In this respect, it is important that the whole plan viability testing currently being undertaken should fully reflect Planning Practice Guidance on viability, such that as high as possible a percentage of affordable housing is sought. We also support the positive approach to Community Land Trusts (CLTs) as a mechanism for delivering affordable housing (paragraph 4.45). Chichester District Council may also wish to note that SDNPA has, subject to main modifications consultation, received the go-ahead from its Local Plan Inspector for unmodified inclusion of Strategic Policy SD28: Affordable Housing in the South Downs Local Plan. This includes a lower threshold than that advised in Government policy, and also seeks on-site affordable housing from small sites below the 11 threshold stipulated in Government policy.

Policy S7: Meeting Gypsies, Travellers, Travelling Showpeoples' Needs
The SDNPA supports the principle of the policy and whilst noting the significant need arising. It is not clear whether the intention is to allocate sites to meet the need in a separate DPD. Paragraph 4.49
refers to 'the forthcoming DPD' and policy S7 to sites being allocated in a Site Allocation DPD 'where there is a shortfall in provision'. Has this work already been triggered by the scale of need? The policy and associated text could be clearer on this matter.
We would like to highlight that there is limited capacity within the National Park to allocate sites for Gypsies and Travellers through DtC, given significant landscape constraints. We suggest that the coastal authorities and SDNPA continue to work closely with regards addressing the need.

Improving the efficiency of transport networks by enhancing the proportion of travel by sustainable modes and promoting policies which reduce the need to travel
The SDNPA supports in principle Policy S23 (Transport and Accessibility). In particular, we support emphasis on encouragement of use of sustainable modes. We suggest explicit support in the text for improving links into the National Park, particularly by sustainable and active transport modes.
Allocation policies should also should seek to deliver the joining up of existing, and/or improvements to, the network of Public Rights of Way.

SDNPA notes reference in the policy to a coordinated package of improvements to the A27 Chichester Bypass, as well as to a new road from the Fishbourne roundabout. The SDNPA would urge that any such schemes be fully assessed, including streetlighting, for potential adverse impacts on landscape where there is a relationship with the National Park and its setting. Any such impact will
need to be mitigated, and opportunities taken to enhance green infrastructure networks and public rights of way networks. CDC may wish to consider whether the Policy S23 should include additional wording to reflect these principles.

Centurion Way
The SDNPA supports the reference to Centurion Way in paragraph 7.185 in relation to Green Infrastructure & resistance to dissection of green movement corridors. There are opportunities to improve these links, for example, suggest explicit reference to protecting and enhancing the Centurion Way. The reference to Salterns Way is also supported. Centurion Way and Salterns Way are two flagship off-road routes for the SDNP and AONB respectively and do not currently benefit
from safe off-road connection. The SDNPA would strongly support policy to secure this connection and would welcome opportunities to discuss this further and work jointly with CDC on this strategic issue.

With regard to Strategic Policy S14 (Chichester City Transport Strategy) we request that the SDNP is included in the penultimate bullet point as a destination for strategic cycle routes.

Transport evidence
We would highlight that the transport assessment carried out to inform the South Downs Local Plan.
This indicated a potential severe impact on the Petersfield Road / Bepton Road / Rumbolds Hill junction in Midhurst of additional development in the town, in the context of junctions already becoming overcapacity due to background traffic growth, for example, . arising from strategic development in neighbouring planning authorities.
A review of the CDC Transport Study of Strategic Development indicates significant traffic growth arising from Scenario 1 (the preferred strategy). It is not clear from the study how this will impact on the A286 towards Midhurst, which in turn could have a critical impact on junction capacity at Midhurst.
SDNPA may seek further assurance that such potential impacts have been looked at, and appropriate mitigation sought.
Other comments
Page 16 - Local Plan area map: Request clarification whether the Local Plan area includes the following two properties, as not clear from the Local Plan Area map: Stedlands Farm, and The Stable/Little Stedlands, Haslemere GU273DJ
We would like to wish you well in the progression of your Local Plan and would welcome further discussion and joint working on the strategic cross boundary matters raised.

Your policy DM8 states that any development must minimize and not create or add to problems of highway safety, congestion , air pollution or other damage.

I have been involved since the early 1980's in Sussex traffic issues, including the A27 Forum and I predicted that the BABA27 result would not be successful. The Conservative Government have not spent money in Sussex for decades and there has been little done since the Brighton Bypass. I believe from experience that there is a policy, or a non written agenda that money will not be spent on the south's transport infrastructure. It is time they were honest. London, Runcorn, the motorways and the north billions, the south nothing! This lack of investment brings the actual and proposed increase in housing and transport problems into sharp focus.

I have looked at the range and planning verbiage in the review, and it is so wide ranging that for any individual or Parish Council to assimilate and prepare a full response would be very difficult given the ridiculous time constraint. I can only give a snapshot of my thoughts, without any real evidence as back up. Given that you must have taken a very long time to write a wish list of properties to be built without much evidence either, this is may be acceptable.

The areas of objection for Fishbourne, Bosham and Chidham are considerable, but I will concentrate on the traffic and access problems set out by statements in the main Plan, and an assessment of the proposed Bethwines development.

I set out my reasoning herewith:-

2.5 The A27 does not serve communities west of Chichester unless they use the A259 as a feeder road. We all know about the congestion and danger of Fishbourne Roundabout now.

2.13 There are no major employers in Fishbourne making travel to work a necessity.

2.29 I have to ask what employment needs? What employment? Much of this document must be speculation and entirely subjective. There is no employment in Fishbourne, and no plans to provide it, and no one I know can see where the employment will be unless the new resident travels a considerable distance - using the A259 to access the A27.

Where are you going to create new open space? The open space currently exists as a buffer between villages but this report is actually planning to take it away. Views from Apuldram to the Cathedral, and the loss of the buffer zone west of Fishbourne. Your statement on the preservation of landscapes is therefore ridiculous set against the building of houses on current landscapes and views.

3.2 This is all speculative. Where is the evidence of local need, demography and transport. It is not set out in this document.

3.6 How can this conserve and enhance local distinctiveness? It is unsupported verbal junk. The impact of such huge traffic increases on the A259 cannot be over emphasized. This Local Plan report will seek to add to the problem already agreed from the increase of 1600 houses currently in the expansion development to the west of the City, and the proposed 100 houses and commercial development south of the A27.

3.7 Fishbourne is designated as a service village. The definition is that the village can provide a reasonable range of basic facilities, or have reasonable access to nearby facilities. Fishbourne has no facilities being wholly residential, in fact only two pubs and the Fishbourne Centre. Reasonable access - This is not so due to huge traffic problems currently on the A259 accessing the Fishbourne roundabout which will greatly deteriorate given the building scale. The 700 bus is excellent, but it is nationally accepted that unless a bus stop is within 400 metres of the house, residents will not use it. The 56 bus runs every one and a half hours up Salthill Road but will again still be out of reach of Bethwines residents. The railway provision is a halt, not a station, and only has one train an hour in each direction, and again is out of reach of Bethwines development.
We also need to add the destructive effects of pollution if we have miles of standing traffic in Fishbourne and on the A27 west of the city.

6.49 Development south of the A27 between Stockbridge and Fishbourne.

I am very aware of the history of Fishbourne roundabout, which was a disaster from its initial construction. It was proved then to the Agency that it was possible to negotiate the roundabout east/west at 70mph, and is still the same. The Highways Agency of course would not agree to their error despite proof, but they have left this over stretched and dangerous roundabout as their legacy to us.

Any attempt to add a further junction from a link road onto the current A27 Fishbourne roundabout must be rejected. There will still be huge obstruction to A259 eastbound gaining access onto the roundabout as it struggles now, but if an additional junction is given precedence over A259, entry to the roundabout will be even more clogged and more dangerous. Not only will Fishbourne traffic be required to give way to growing A27 westbound traffic, it will also have to give way to traffic from any proposed new link from the south. The only possible alternative to a grade separated junction is a signalized and re-created hamburger roundabout. We all know that signals will improve safety, but would never cure the future serious congestion. Even if the dangerous traffic problems on the roundabout are mitigated by signalisation, the congestion will remain heavy and excessive. The huge proposed increase in traffic along the corridor will make this junction unusable with consequences to surrounding minor roads such as Salthill Road, Clay Lane, Funtington Road and Hunters Race.

6.54 The development at Highgrove Farm, Bosham where 250 homes are planned will also reduce the strategic gap between Bosham and Fishbourne and impact upon the A259.


Bethwines development Traffic problems.

The previous application for Bethwines development submitted a transport plan that was frankly ludicrous. Such suggestions as car sharing and extensive use of cycling/walking would never work to reduce regular car use out of the village.

Public transport is not a viable option for the new estate unless a new bus route was created, or the 56 diverted, and I doubt that this is an option. The 700 bus route along the A259 is too distant.

Traffic will therefore have to access the new development via Blackboys Lane.

Blackboys Lane at the south end is narrow, with ditches either side and properties closely border the roadway. The exit onto the A259 is narrow with limited visibility, and an exit almost impossible with the proposed traffic flow. North of the railway crossing the road is open and wider, but leads to Clay Lane that is itself not satisfactory for this growth in car use. Road upgrades would be necessary and roads such as Halfrey Road would have a significant increase in rat run traffic .

The junction of Clay Lane and Salthill Road, and Salthill Road and the Funtington Road would need an assessment using current models to establish the correct junction control. The Funtington Road/Salthill junction has very poor visibility. The narrow Clay Lane throughout it's length to Fishbourne Road East, that is a 20mph residential road would also need to be upgraded including pavements and/or cycle routes.

It is inevitable that Salthill Road, Hunters Race and Clay Lane would become a popular route out of the area. It is over stretched now with the road surface deteriorating quickly especially in Lavant.


The A27 and A259

There has been no time to establish current traffic flows on the A259, but as we all know, the congestion to Fishbourne Roundabout is often back to The Woolpack, and encourages the use of Salthill Road out of the village. The A27 daily has six miles of standing traffic eastbound in two lanes to Fishbourne roundabout

The transport corridor is not effective now let alone with the 2250 houses you are suggesting along the corridor between Chichester and Southbourne. 2250 houses mean 4500 cars, established by a study of Flavian Fields development at Fishbourne. This showed that there were two cars per household, 35% of adult residents in the Flavian Fields development do not work, that means that 65% do work and have to travel to employment outside of the village, and must apply equally to Chidham, Bosham and Southbourne. This also takes no account of the fact that mothers will transport their children to school by car. These schools will be outside of the villages due to an already full Fishbourne and Bosham School and the only secondary school at Southbourne being further away than Chichester schools. It has been established that Fishbourne already has the highest car dependency in Chichester District.

Specifically for the A259 between Chidham and Fishbourne roundabout, the huge growth of 1000 houses in Fishbourne, Bosham and Chidham, amounts to 2000 additional cars that will use the A259. I would anticipate that these villages will use Chichester for employment, schools, access to the A27 and facilities. The 1250 houses in Southbourne will further complicate the numbers, but some will probably travel westbound for services.

National statistics reveal that at least half of those additional cars from our villages will use the A259 the only feeder road for travel at peak time to work. The average length of a family car is now 4.8 metres. Allowing for about a one metre+ gap between them, 1000 cars need a stationery road space of about 6000 metres or Fishbourne roundabout to Chidham if lined up. That is a staggering fact, and no thought has been given to this problem in the planning strategy, exacerbated by the lack of an upgraded A27.

This must now be a factor in responding to the Government's demand for housing in this narrow area as I repeat your policy DM 8

'any development must minimize and not create or add to problems of highway safety, congestion , air pollution or other damage.'

This policy cannot be fulfilled!!

The Parish Council challenges the assertion that the provision of new dwellings will make the area more self contained. This needs more robust evidence. Currently the village of East Wittering has lost 4 banks, a holiday centre and a large pub and businesses rely heavily on seasonal tourism for trade. New homes without new local jobs will be a drain on current infrastructure. market homes are likely to add to the number of residents getting off the peninsular for work and will therefore not reduce the areas reliance on Chichester city centre.

In addition:

1 The funding for the £65m to carryout the road mitigation measures for the A27 etc exceeds the figure which could reasonable be obtained by developer contributions. The ability to delivery these measures to mitigate the additional traffic arising from the local plan housing numbers is therefore uncertain. The local plan should therefore set out how it plans to deal with this major uncertainty. This could possibly be achieved by having clearly defined phasing with trigger points which require a change in approach, or the housing numbers reduced. This has happened before with road mitigation works not being delivered because of lack of funding (Selsey Tram)
2 There are major concerns about the strategic industrial / housing site AL6 (Land South West of Chichester Apluldram & Donnington). This requires the construction of a Link road between Fishbourne Birdham Lane at Donnington. This site is at risk of both tidal and fluvial flooding on ground which already has a high-water table and no consideration is given to rising sea level associated with climate change. To quote WSCC who are the Lead Local Flood Authority (LLFA) 'These limits how the site can be effectively drained without a step change from typically employed methods to embrace more innovative and currently expensive options'. This site should be rejected and replaced by AL4, which is in the current Local Plan, even if this requires compulsory purchase powers to acquire it.
3 The above link road combined with the proposed A27 junction designs at Stockbridge and Whyke which bans right turns would result in significant forecast changes to traffic flows on the Manhood Peninsula. As WSCC, as the Highways Authority, points out it requires further feasibility work before the Local Plan is submitted to show that the transport strategy can be delivered and funded.
4 Both CDC and WSCC promoted a Mitigated Northern Route for the A27 at Chichester as the preferred option. Policy S30 which introduces 'wildlife corridors' conflicts with the ability to deliver a Northern Route. Policy S30 requires amending so that it does not exclude the possibility of a Northern Route. There cannot be any policy which excludes the possibility of a Northern route.
5 Additional traffic at the Fishbourne roundabout should be assessed in terms of air quality and accident numbers.

REMOVE AL6.The plan does exactly the opposite for all local traffic. It decreases road capacity, increases congestion increases air pollution and hinders accessibilty to Chichester City.New road from Birdham to Fishbourne was emphatically rejected as environmental and heritage vandalism and detrimental to local traffic whilst not solving the congestion issue. Should not be included as no funding.Junction upgrades would create 15 yrs of misery and pollution and not solve the issue.Unless this is adequately addressed in future iterations of the plan, I will raise this with the examiner at the appropriate time.

The proposed mitigation link road from Fishbourne to Brirdham surely flies in the face of your objectives. The proposed road is adjacent to some of the most vulnerable and important ecosystems and habitats in the district, internationally designated sites, and would harm some of our most treasured and unique views, those of the cathedral from the harbour, marina and the Salterns Way.

The views and protected habitat, particularly along the canal must be protected!

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?

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?

Highways England has been appointed by the Secretary of State for Transport as strategic highway company under the provisions of the Infrastructure Act 2015 and is the highway authority, traffic authority and street authority for the strategic road network (SRN). The SRN is a critical national asset and as such Highways England works to ensure that it operates and is managed in the public interest, both in respect of current activities and needs as well as in providing effective stewardship of its long-term operation and integrity.

Highways England will be concerned with proposals that have the potential to impact on the safe and efficient operation of the SRN, in this case with particular reference to the A27 Chichester Bypass and its junctions at Portfield Roundabout, Bognor Road Roundabout, Whyke Roundabout, Stockbridge Roundabout and Fishbourne Roundabout.

The current adopted Local Plan sought to provide 7,388 dwellings over the 15 year period 2014 - 2029. As part of the adopted plan there were agreed highway improvements at the above mentioned five A27 junctions along with the addition of improvements at the A27 Oving Cross Roads to mitigate the adverse impacts of strategic development traffic.

The current position with these agreed proposals is as follows:

A27 Portfield Roundabout - Agreed improvements being implemented as part of conditions relating to planning Application No. O/11/05283/OUT Land North Of Shopwhyke Road, Shopwhyke, West Sussex. Works expected to start Spring 2019.

A27 Oving Cross Roads - Agreed improvements being implemented as part of conditions relating to planning Application No. O/11/05283/OUT Land North Of Shopwhyke Road, Shopwhyke, West Sussex. Works expected to start Autumn 2019.
A27 Bognor Road Roundabout - Scheme not fully funded via s278 contributions. Several approved applications given consent outside of the Local Plan proposals have modified the originally agreed improvement scheme including Arun District Councils adopted Local Plan.

A27 Whyke Roundabout - Scheme not fully funded via s278 contributions. Several approved applications given consent outside of the Local Plan proposals including strategic development in Pagham (Arun District) have modified the originally agreed improvement scheme.

A27 Stockbridge Roundabout - Scheme not fully funded via s278 contributions.

A27 Fishbourne Roundabout - Scheme not fully funded via s278 contributions. Several minor developments outside of the Local Plan have contributed to the proposals which will require modification to cater for revised development impacts.

The mechanism used to calculate contributions to the agreed Local Plan A27 improvements is the councils "Planning Obligations & Affordable Housing Supplementary Planning Document (SPD) which came into effect from February 2016. The calculations for contributions were based upon the total construction of the improvements against the number of additional vehicle trips on each of the affected A27 Chichester Bypass junctions. It was hoped that construction work on the remaining four junctions would begin no later than 2023/24 in order to ensure that the improvements were in place when they were needed. However, due to the different stages at which the various strategic developments are currently positioned this seems unlikely as insufficient funding will be available at the appropriate point.

The revised Local Plan proposals now being consulted upon are required to deliver an additional 12,350 dwellings in Chichester District during the period 2016 to 2035. This is an increase of 4962 dwellings above that agreed in the previous plan as the planned housing supply for the new plan period is slight above the requirement at 12,478 dwellings.

To support the revised housing supply for the new plan period Peter Brett Associates were employed to update the existing strategic transport model and apply the proposed strategic development options. Highways England and West Sussex County Council were closely involved with the Transport modelling work and the reference and future case scenarios have been accepted by both Highway Authorities.

The PBA report 'Transport Study of Strategic Development Options and Sustainable Transport Measures' provides resultant outputs from the modelling work and demonstrates that the previously accepted highway schemes on the A27 Chichester Bypass, with the exception of Portfield Roundabout and Oving Cross Roads, are no longer sufficient to bring about a 'no worse' traffic scenario with the revised Local Plan proposals. To this end, Peter Brett Associates have developed and tested a revised set of improvements at the A27 Fishbourne, Stockbridge, Whyke and Bognor Road Roundabouts. The improvements also include a short link road from the A259 Bognor Road to Vinnetrow Road and a link road from the A286 Birdham Road into the Fishbourne Roundabout (Stockbridge Link Road). Highways England agrees
that the improvements shown in the PBA report will sufficiently mitigate the traffic impacts resulting from the Local Plan Review proposals. In accepting that the PBA proposals are agreeable to Highways England there are a number of matters which require further consideration:

1) The revised costing of the A27 Mitigations as indicated in the PBA report are considered unrealistic bearing in mind the work required to deliver these schemes. Further more detailed work will need to be undertaken to establish a realistic estimate of costs for the full package of works. It is noted that this is in hand with consultants to be appointed in the coming weeks.

When revised estimates are completed it is recommended that these are passed through the Highways England commercial team who will provide a cost range and most likely final cost of the proposals. This figure can then be used moving forward.

2) Even as presented the cost proposals could fall beyond site viability and accordingly there is a strong possibility that external funding will be required to deliver the full package of highway improvements required to mitigate the impacts of the revised Local Plan proposal. New viability testing will need to be undertaken to establish what contributions could realistically come forward from development. When set against the agreed costings (when established) the overall deficit can be calculated and a business case developed for any identified shortfall. Highways England have no funding available at present to assist as the current Growth Housing Fund is fully allocated with no prospect at present of any proposals falling out of the funding programme. Highways England will support an application for external funding to assist highway improvements that seek to unlock housing development as promoted in the revised Local Plan.

3) The agreed proposed highway improvements significantly expand and develop the previous incarnations to the extent that there is concern that the improvements may not be deliverable within land owned or under the control of Chichester District Council, Highways England or West Sussex County Council, particularly the two link roads. Accordingly, it may be necessary for the council to exercise its Compulsory Purchase powers in order to deliver the necessary improvements.

4) With point (3) in mind and at this stage in the plan making process it may be prudent to consider what other viable options may be available at the respective A27 junctions in lieu of the provision of the Stockbridge link road. It may be that the Stockbridge link road provides some future benefit in relation to the next Local Plan review in that there could still be flexibility in the network for further minor junction upgrades before full A27 grade separation is required.

5) The councils 'Planning Obligations & Affordable Housing Supplementary Planning Document' (SPD) which came into effect from February 2016 needs to be updated as a matter of priority. The SPD will no longer be appropriate for the Local Plan review proposals and will need to reflect that all new
housing development increases the traffic on the highway network (both local and strategic networks). Accordingly, even relatively small housing developments should be required to contribute to the proposals and it is suggested that this includes housing developments of 10 or more dwellings. The SPD will need to make it clear to developers that the contributions will be required from all sites not just those included within the Local Plan.

6) In view of the fact that the previous Local Plan highway schemes were expected to begin no later than 2023/24 it is suggested that this time table is maintained for the implementation of the reviewed Local Plan proposals. Highways England appreciates that this will ultimately require upfront financing ahead of the additional proposed planned development and accordingly gives further weight towards the business case for external funding.

Referring to para's 5.23 to 5.25 of the 'Chichester Local Plan Review 2035 Preferred Approach - December 2018' document which refers to a potential Road Investment Strategy (RIS) scheme being promoted by the Systra report commissioned by the Council and West Sussex County Council (BABA27 - A27 Northern Bypass or fully grade separated A27 Southern Bypass) it has been confirmed that neither option will be pursued in the forth-coming RIS period as these schemes are not affordable or deliverable. Accordingly, the Local Plan Review should only consider the improvements contained within the supporting PBA report 'Transport Study of Strategic Development Options and Sustainable Transport Measures' as these have a reasonable prospect of coming forward (subject to funding).

Overall, Highways England are, at this point in the plan making process, satisfied that the full package of highways proposals as outlined in the PBA report 'Transport Study of Strategic Development Options and Sustainable Transport Measures' will mitigate the adverse impacts of the Local Plan review proposals on the Strategic Road Network.

We will continue to work with and assist Chichester District Council and West Sussex County Council as the Local Plan review process progresses.