Policy S25: The Coast

After reading the Chichester Local Plan Review 2035, for the local plan to be found sound there should be a clear inclusion of marine planning in line with the NPPF and Marine and Coastal Access Act (MCAA).

NPPF: 166. In coastal areas, local planning authorities should take account of the UK Marine Policy Statement and marine plans and apply Integrated Coastal Zone Management across local authority and land/sea boundaries, ensuring integration of the terrestrial and marine planning regimes.

MCAA: 58(1). A public authority must take any authorisation or enforcement decision in accordance with the appropriate marine policy documents.

MCAA: 58(3). A public authority must have regard to the appropriate marine policy documents in taking any decision which relates to the exercise of any function capable of affecting the whole or any part of the UK marine area.

The PAS soundness self-assessment checklist also states a recommended requirement to "take account of marine planning".

We recommend reference to the legal duty to co-operate with the Marine Management Organisation, as well as reference to Marine Planning, the Marine Policy Statement, and the South Marine Plan.

The marine planning remit is directly for coastal and marine waters up to the mean high water spring mark where Chichester district council extends to the mean low spring water mark (we can supply a GIS layer of the spatial extent for any policy maps if you wish). The area covered by the Chichester Local Plan Review 2035 lies within the South Marine Plan Area therefore, it is recommended to ensure your plan is 'sound' that it includes a reference to the South Marine Plan. There are policies within the Chichester Local Plan Review 2035 that have marine relevance and so it is recommended that the South Marine Plan and specific policies are referred to in these sections. For example, policies: S18, S25, S27, S31. Please also note that any works undertaken in the development of flood risk management may require a marine licence.

Examples of South Marine Plan policies that you may wish to consider are listed below. Hyperlinks are provided for further information (in original email). These policies are provided only as a recommendation and we suggest that your own interpretation of the South Marine Plan is completed.
* S-CC-1: Proposals must consider their contribution to greenhouse gas emissions arising from unintended consequences on other activities. Where such consequences are likely to result in increased greenhouse gas emissions, proposals should demonstrate in order of preference:
a) avoid
b) minimise
c) mitigate unintended consequences on other activities.
* S-CC-2: Proposals should demonstrate for the lifetime of the proposal that:
1. they are resilient to the effects of climate change
2. they will not have a significant adverse impact upon climate change adaptation measures elsewhere.
In respect of 2) proposals should demonstrate that they will, in order of preference:
avoid
b) minimise
c) mitigate the significant adverse impacts upon these climate change adaptation measures.
* S-CC-3: Proposals in and adjacent to the south marine plan areas that are likely to have a significant adverse impact on coastal change should not be supported.
* S-CC-4: Proposals that may have a significant adverse impact on habitats that provide a flood defence or carbon sequestration ecosystem service must demonstrate that they will, in order or preference:
a) avoid
b) minimise
c) mitigate significant adverse impacts.
* S-EMP-1: Proposals that develop skills related to marine activities, particularly in line with local skills strategies, will be supported.
* S-EMP-2: Proposals resulting in a net increase to marine related employment will be supported, particularly where they are in line with the skills available in and adjacent to the south marine plan areas.
* S-SOC-1: Proposals that enhance or promote social benefits will be supported. Proposals must demonstrate that they will, in order of preference:
a) avoid
b) minimise
c) mitigate significant adverse impacts which result in the displacement of other existing or authorised (but yet to be implemented) activities that generate social benefits.
* S-ACC-1: Proposals, including in relation to tourism and recreation, should demonstrate that they will in order of preference:
a) avoid
b) minimise
c) mitigate significant adverse impacts on public access
* S-ACC-2: Proposals demonstrating enhanced public access to and within the marine area will be supported.
* S-TR-1: Proposals supporting, promoting or facilitating tourism and recreation activities, particularly where this creates additional utilisation of related facilities beyond typical usage patterns, should be supported.
* S-TR-2: Proposals that enhance or promote tourism and recreation activities will be supported. Proposals for development must demonstrate that they will, in order of preference:
a) avoid
b) minimise
c) mitigate significant adverse impacts on tourism and recreation activities.
* S-BIO-1: Proposals that may have significant adverse impacts on natural habitat and species adaptation, migration and connectivity must demonstrate that they will, in order or preference:
a) avoid
b) minimise
c) mitigate significant adverse impacts
* S-BIO-2: Proposals that incorporate features that enhance or facilitate natural habitat and species adaptation, migration and connectivity will be supported.
* S-BIO-3: Proposals that enhance coastal habitats where important in their own right and/or for ecosystem functioning and provision of goods and services will be supported. Proposals must take account of the space required for coastal habitats where important in their own right and/or for ecosystem functioning and provision of goods and services and demonstrate that they will, in order of preference:
a) avoid
b) minimise
c) mitigate for net loss of coastal habitat.
* S-EMP-1: Proposals that develop skills related to marine activities, particularly in line with local skills strategies, will be supported.
* S-EMP-2: Proposals resulting in a net increase to marine related employment will be supported, particularly where they are in line with the skills available in and adjacent to the south marine plan areas.
* S-WQ-1: Proposals that may have significant adverse impacts upon water environment, including upon habitats and species that can be of benefit to water quality must demonstrate that they will, in order of preference:
a) avoid
b) minimise
c) mitigate significant adverse impacts
* S-WQ-2: Activities that can deliver an improvement to water environment, or enhance habitats and species which can be of benefit to water quality should be supported.

You may wish to refer to the South Marine Plan, the UK Marine Policy Statement (MPS), our online guidance, the Marine Information System and the Planning Advisory Service soundness self-assessment checklist.

Resident of West Wittering
This Plan totally misses the point. The continued over-development on the Peninsula is creating an unattractive environment for tourists. Also the issue of 'adaptation to climate change' should be addressing the fall back area as defined in the NPPF.

Your comments are half hearted. yes it affords views of the SDNP...it is a flood plain so will be flat. Yes it is an area of SSI, AONB, Ramsar and Special Area of Conservation so why do you seek to vandalise it with a link road and housing when the land to the south of the SNDP does not have such protected status , is largely hidden by the topography and again is excluded !!! Unless this is adequately addressed in future iterations I will raise it with examiner at the appropriate time.

Existing permitted and proposed development areas extending the urban areas of Selsey and Pagham erode the intention of the policy which is to safeguard the character and environment of the coast. This development does not constitute protection and enhancement of the coast identified in the policy.

Thank you for the consultation on the above document. We have reviewed the document and have the following comments to make in response.

Summary
Overall we are pleased to see that the Plan provides a framework to ensure that new
development will take place in a considered manner to address environmental constraints as well as provide policy hooks for the delivery of environmental enhancements. However, to ensure that the Plan is as effective as possible and meets necessary policy and legislative requirements we have made some recommendations for improvements. These are set out in detail below. Where we support a policy we have also highlighted this below.

We have highlighted concerns with policy AL6 - Land SW of Chichester and have made recommendations for more significant changes to policies in relation to flood risk management (both strategic and development management) and wastewater management and water quality.

As a general comment we note that a significant proportion of the housing numbers
proposed through the Local Plan will be delivered by Neighbourhood Plans. We have
highlighted key criteria for individual locations that we would wish to see considered by those Plans when allocating sites. Where possible we would wish to see these included within the Local Plan policy but as you will be aware we have produced a checklist for Neighbourhood Plan groups in your District which will guide the identification of sites and other key issues and opportunities to be addressed in their Plans.
We would be happy to meet with you to discuss further any of our comments and support the rewording of the policies prior to the production of a pre-submission Plan.

Specific comments

Strategic policies
Policy S12 - Infrastructure
Overall we support the policy. We would recommend that paragraph 3 be amended to
include reference to flood risk management infrastructure.

Policy S17 - Thorney Island
We are currently exploring opportunities for habitat creation in an area on Thorney Island. This is part of our Habitat Creation Programme which seeks to create new habitat to offset losses elsewhere as a result of sea level rise and implementation of coastal and flood risk management infrastructure.
Whilst the policy as drafted, along with other policies in the Plan, would not restrict this opportunity we would like you to consider whether further wording could be included to provide specific support for habitat creation.

Policy S18 - Integrated Coastal Zone Management
We support the continued inclusion of this policy and the specific references to key Plans.
We also support the intention that financial contributions should be sought to deliver both flood risk management infrastructure as well as improvements to the quality of watercourses in the area.

Policy S20 - Design
We support the specific requirements of this policy in point 5 and 8 with regard to green infrastructure and enhancing biodiversity and climate change resilience.

Policy S23 - Transport and Accessibility
The policy includes a new road connecting Birdham Road to the A27 Fishbourne
roundabout. The site includes areas within flood zones 2 and 3 and will cross a number of watercourse. It is essential that the requirements of the NPPF paras 157-8 are satisfied prior to the allocation. We have made detailed comments on this in relation to policy AL6 - Land South West of Chichester.

Policy S25 - The Coast
We are pleased to see the support in this policy for future habitat creation as well as the delivery of flood defences and adaptation to climate change. This supports principles of net environmental gain advocated through the NPPF and the 25 Year Environmental Plan as well as providing necessary policy hooks to support our future plans through our Habitat Creation Programme.
As we highlighted through the Issues and Options consultation this Programme was set up to deliver the compensatory habitat required to address the losses in habitat that would take place as a result of the flood and coastal risk management measures identified in the Shoreline Management Plans. There are specific locations within Chichester District which offer opportunities to provide saltmarsh and coastal grazing marsh in the medium to longer term. These locations include areas in Fishbourne, Chidham and Hambrook and on Thorney Island.

Policy S26 - Natural Environment
We would recommend that the policy wording be extended to say "protect and enhance biodiversity". This is consistent with the NPPF requirements in para 170 regarding net gain and current Government proposals to mandate biodiversity net gain for all new developments.

Policy S27 - Flood Risk Management
We support the intention of the policy, however, we would wish to see changes made to ensure the policy is as clear as possible. We would also recommend you consider what a strategic policy on flood risk management is seeking to achieve in addition to the development management policy. As drafted there are some duplications and/or inconsistencies between the two policies.
It may be more prudent to have a shorter overarching policy that seeks to ensure that flood risk will be taken account of at all stages in the planning process in order to avoid inappropriate development in areas at current or future risk (taking into account climate change) and to direct development away from areas of highest risk. Reference could and should be made to the Strategic Flood Risk Assessment to enable this. We would also support a requirement here for development to seek to achieve a reduction in flood risk for existing communities on and off site.
The principle of point 3 is supported but again should be considered whether it sits best within the development management policy.
We would recommend removing point 4. It is not clear entirely what the rationale behind this is but as drafted it suggests that development within areas with a certain level of flood risk would be approved. This should only be the case when the sequential and exception test have been satisfied in accordance with the NPPF paragraph 157- 8. I would be happy to discuss this further if the intention behind the statement is different.

Policy S29 - Green Infrastructure
We support the policy and are pleased to see specific reference to "blue" infrastructure.

Policy S30 - Strategic Wildlife Corridors
We are supportive of this policy and believe it provides a strong framework for the protection and enhancement of biodiversity within the Plan Area. In particular we support the corridors along watercourses and the links with Biodiversity Opportunity Areas.
As previously highlighted in our Issues and Options response to the Local Plan the
Environment Agency are looking to deliver more natural flood management (NFM) measures to complement and support traditionally engineered flood defenses. This is about working with natural processes in whole catchments and has the potential to help us manage and reduce flood risk in a more efficient, cost effective and sustainable way whilst securing wider environmental benefits. We would be interested to discuss whether the Strategic Wildlife Corridors Background Paper could be expanded upon to consider these opportunities.
A nationally consistent set of opportunity maps to indicate potential for natural flood
management have been produced and I have attached a briefing not which shows how you can access this screening information. The identification and safeguarding of wildlife corridors could support our further work on NFM in the Chichester District and we would welcome the opportunity to discuss this further. In particular we would be interested to discuss whether the Strategic Wildlife Corridors Background Paper could be expanded upon to consider these opportunities.

Policy S31 - Wastewater Management and Water Quality
We support the intention of this policy, however, we recommend that the policy is amended to ensure that specific issues associated with the Apuldram WwTW catchment are addressed and that wider opportunities for the necessary protection and enhancements of water quality in the catchments across the Plan area are taken forward through development. As drafted the supporting text to the policy talks primarily around wastewater treatment capacity and impacts on water quality. However, we would recommend that this is expanded to discuss wider water quality and water resources issues within the Plan area.
This should include reference to the Water Framework Directive and the South East River Basin Management Plan, for which the Council has an obligation to support their delivery.
We would wish to see the Plan include a policy that will ensure that the design and location of development will both protect and enhance water bodies, both surface and groundwater.
We are aware of a few adopted policies regarding water quality that you may wish to review ahead of the further iteration of your Plan. These include policy W DM1 - Water supply and quality in the Arun Local Plan and Policy 31 - Integrated Water Management and the water cycle in the Cambridge Local Plan. The Policy in the Arun Local Plan is subdivided in to 3 sections to cover issues of water supply, water quality and catchment specific measures.
This approach or layout may be useful for you to consider here.
You may also wish to consider whether there are elements of this policy that would be better situated in a development management policy to direct decision making on individual sites.
I would be happy to work with you further to develop this policy, however, to support this the following identifies some key wording that could be included:
"All new development must demonstrate:
* That it has no adverse impact on the quality of water bodies and groundwater, or will prevent future attainment of good status;
* That development contributes positively to the water environment and its ecology and does not adversely affect surface and ground water quality"
This will reflect that impacts on water quality will not solely relate to wastewater infrastructure but can include diffuse pollution as well as physical changes to watercourses.
With regard to the specific requirements for the Apuldram WwTW the policy as drafted broadly reflects the current adopted Plan policy. Would there be an opportunity here for the policy to reflect elements of the recently endorsed Position Statement between the Environment Agency and Southern Water in terms of managing development in the catchment?
The policy makes reference to the higher building regulations standard of 110 l per person per day. We support this standard but would recommend you consider whether this detail is needed in this strategic policy as well as development management policy DM16 - Sustainable Design and Construction.

Site Allocations
Please note we have no additional comments to make on the sites that are being taken forward from the current adopted Local Plan as we consider that the key policy criteria we sought at that stage has been transposed across. We continue to support these requirements.

Policy S32 - Design Strategies for Strategic and Major Development Proposals
We support this policy and specifically requirements for issues such as green infrastructure and SuDS to be fully considered through a Masterplan. Without this overarching vision for larger sites it is often difficult to provide a comprehensive scheme to address key environmental constraints and opportunities.

Policy AL13 - Land East of Chichester
There is a small area within the site located in Flood Zone 2, along with an additional surface water body (lake). We would recommend that the masterplan for this site fully considers these constraints in designing the site including the adopting the sequential approach. We would wish to see built development located solely within Flood Zone 1.

Policy AL 5 - Southern Gateway
We have previously made comments on the proposals for the Southern Gateway through the adopted masterplan for the site. As highlighted there are a number of constraints to development in this area, however, we are pleased to see specific criteria in the policy toensure that these key constraints to the site within our remit are fully considered.
These are:
- Bullet 8 which requires the provision of a wastewater management plan which
demonstrates no net increase in flow to the Apuldram WwTW. This is in line with the
Surface Water and Foul Drainage SPD and the Position Statement on managing new
housing development in the Apuldram (Chichester) Wastewater Treatment Works
Catchment agreed between the Environment Agency and Southern Water.
- Bullet 10 which sets out the requirement for a Flood Risk Assessment to address the
specific flood risk issues on the site. We would recommend that this policy criteria
could be expanded upon to require the sequential approach within the site and to
ensure that more vulnerable uses such as housing be located in the lowest areas of
flood risk.

Policy AL6 - Land SW of Chichester
At this stage we do not support the inclusion of this site within the Plan.
The allocation is composed of housing, employment and a road scheme. Large areas of the allocation falls within flood zones 2 and 3 and we would wish to see further evidence to support this allocation. This may be as part of a Level 2 Strategic Flood Risk Assessment for this site which would then inform a Sequential and if necessary an Exceptions Test. The assessment would need to consider how the proposals could be delivered and identify any mitigation and/or compensation measures that may be necessary to ensure that the development is safe and that there is no increase in flood risk to third parties.
Whilst we note that there are areas outside of the flood plain within the allocation and that some of the development could avoid these areas it is anticipated that the road would cross the flood plain and therefore further detailed understanding of this risk and how it would be managed should be provided.
As drafted the policy makes no reference to flood risk and we would wish to see this
amended.
With regard to housing development we would wish to ensure that all development be located in Flood Zone 1 and that the policy criteria would reflect this.
Other issues include the crossing of watercourses and impacts on biodiversity and water quality. This should be referenced within the policy criteria with requirements for any watercourse crossings to be clear span in design. This will ensure that flood water conveyance is not impeded and protect the habitat associated with those watercourses.
In addition to flood risk we also have concerns with regard to where the sites wastewater would drain to. In line with our Position Statement on managing new housing development in Apuldram (Chichester) Wastewater Treatment Works Catchment allocations within the Local Plan should not drain to the Apuldram WwTW but be directed to alternative WwTW catchments, notably Tangmere WwTW via the new sewer pipeline connection once operational.
It is difficult to understand how this site would connect to an alternative WwTW and therefore would question whether the site would be deliverable.

Policy AL9 - Fishbourne
Fishbourne parish falls within the Apuldram WwTW catchment and we would recommend that the policy makes specific reference to the issues that the Neighbourhood Plan group should consider when identifying sites for their Local Plan.
We would also recommend that specific reference is made to the Source Protection Zone that covers part of the parish in order to ensure that the groundwater, and in turn the drinkingwater supply, is protected.

Policy AL11 - Hunston
There are parts of Hunston that fall within flood zones 2 and 3. We would recommend that if possible the policy makes reference to the fact that built development should be located solely in Flood Zone 1. If this is not possible some reference would need to be made to flood risk and the requirement for the Neighbourhood Plan group to fully consider this through their site allocation process. If sites were to be allocated in flood zone 2 or 3 it is likely that the Plan would need to be supported by a Level 2 SFRA or equivalent.

Policy AL13 - Southbourne Parish
Point 16 identifies the need to ensure that sufficient capacity is available at the relevant Wastewater Treatment Works prior to the delivery of development. This could be expanded to include sewer network capacity. Liaison with Southern Water regarding any necessary phasing of development would be encouraged.

Development Management Policies

Policy DM5 - Accommodation for GTTTS
We support the specific criteria in this policy to ensure that GTTS sites are not located in areas at risk of flooding.

Policy DM14 - Caravan and Camping Sites
We support the particular reference to restricting the occupancy of these sites in flood risk areas. However, there is no specific mention that flood risk areas should be avoided where possible. We would recommend that this should be included within the policy criteria.

Policy DM15 - Horticultural Development
We are pleased to see specific reference to the need to demonstrate adequate water
resources are available and/or water efficiency measures.

Policy DM16 - Sustainable Design and Construction
We support the requirement for new development to achieve a water usage of a maximum of 110litres per head per day.
For completeness we recommend that point 5 should be expanded to include compensation as well as make reference to net gain. This is in line with NPPF para 170.
We support the requirement in point 8 with regard to measures to adapt to climate change.

Policy DM18 - Flood Risk and Water Management
para. 7.115 - reference to the Environment Agency should be removed from this sentence.
The responsibility for surface water drainage and consideration of SuDS sits with West Sussex County Council as the Lead Local Flood Authority for this area.
para. 7.116 - vulnerability - it should be noted that not all development types would be appropriate in all flood zones. Basement dwellings would not be supported in flood zone 3. This paragraph should be amended to reflect this.
We would recommend that you review this policy alongside the strategic policy on flood risk to ensure that they are complementary. Whilst the intention of the policy is good some further clarity could be provided to ensure that all sources of flood risk are considered through decision making.
As drafted there is no reference to the Sequential Test which is a key step in decision
making with regard to proposals in a flood zone. It appears that a number of the criteria included in policy 42 of the current adopted Local Plan have been stripped out. We would recommend further consideration of this for the next iteration of the Plan.
We note that the policy also makes reference to wider water management and does refer tothe South East River Basin Management Plan, however, as per our comments on policy S31 we would wish to see a specific policy that provides for the protection and enhancement of water quality. It may be prudent to consider whether an overarching strategic policy to address flood risk and water management would be best with separate detailed development management policies for each topic.
We would be happy to work with you regarding this detail.

Policy DM20 - Development around the coast
We support this policy and the requirement to safeguard a strip of land behind existing or proposed sea defence or coastal works. Please note that the Environment Agency would seek a 16 metre buffer behind any of our tidal defences.
We support the specific requirement to ensure that development for boat or marine use would not be detrimental to water quality.

Policy DM24 - Air Quality
We are pleased to see that this policy recognises that new development may be located near to existing uses that may be potentially polluting to housing. It is important that the onus should be on the developer/applicant to manage any impact to ensure that they don't leave the existing user affected, e.g. by complaints.

Policy DM26 - Contaminated Land
We support this policy as drafted.

Policy DM29 - Biodiversity
We support this policy as drafted and are pleased to see that specific reference has been
provided to ensure that net gain in biodiversity is actively pursued. Consideration should be
given to the current Government consultation on mandating biodiversity net gain in all new
development and whether this may require further strengthening of the policy wording.
Policy DM32 - Green Infrastructure
We support policy.

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.

S3, S4, AL13
Strategic policy should be included that consider the area west of Chichester as a whole rather than as a series of unrelated settlements along the A259 transport route, which is implied by it being referred to as the "east-west corridor". A number of common issues would benefit from collective and co-ordinated attention eg waste water treatment, traffic congestion/management, landscape protection, wildlife corridors and the need to prevent coalescence (para 6.87). The area is expected to provide for a minimum 2250 new dwellings, in addition to the allocations in the current Local Plan (475), and is under great pressure due to its being squeezed between Chichester Harbour and the National Park, both being areas having the benefit of particular protection. This pressure is exacerbated by the National Park not accommodating its fair share of new development and by substantial development in neighbouring Emsworth, Hampshire, that adds to the pressures on the Chichester Harbour AONB and West Sussex infrastructure including road traffic and the capacity of Thornham Wastewater Treatment Works.
Supplementary Planning Guidance is required to address the issues specific to this area, provide clarity of guidance for developers and enable co-ordinated solutions.
S6
Affordable housing should relate more closely to local income levels. Local residents have made the point many times, during the preparation of the current Neighbourhood Plan and more recently in connection with the Neighbourhood Plan review, that local people cannot afford local housing, either to buy or rent. The Parish Council intends to commission a Local Housing Needs Survey which could help identify the quantity and type of need in the Parish.
(add to end of para 4.34) This means housing is unaffordable to many people in the Plan area and why income levels will be taken into account in establishing house prices and rent controls. 80% of the local market rent is the maximum, but lower rents are likely to be justified in some instances.
Developers must deliver their "affordable" requirement if sufficient housing to meet local needs is to be provided. This should not be a problem if proper account is taken of the cost of land acquisitions and development at a sufficiently early stage. Subsections 1 and 5 in Policy S6 allow too much flexibility, especially the use of the word "appropriate" in subsection 1 which is too subjective.
Delete or amend subsections 1 and 5, as appropriate.

DM2
The Parish Council fully supports Policy DM(2). It considers that there is likely to be a need in the Parish for more rented accommodation, especially social rented, than is proposed in Policy DM2. It is understood that this is one of the most expensive areas for housing in the country and young people, in particular, struggle to find accommodation they can afford close to their families. A Local Needs Housing Survey of the Parish is likely to be undertaken in preparing the review of the Neighbourhood Plan to help identify the extent of local need and investigate ways to meet it. Accordingly, an alternative housing mix may be prepared for Southbourne Parish (para 7.19)
Local consultation has revealed a shortage of specialist housing, especially for the elderly and the disabled. It is considered that creative policies promoting adaptable "lifetime" dwellings are required to enable the elderly to remain in the community for longer. The Local Housing Needs Survey of the Parish is expected to confirm this.
The market housing 4+ bedroom % needs to be reduced in favour of more single person accommodation. The Parish Local Housing Needs Survey is expected to confirm this
S20, DM1, DM2
Local consultation has revealed a shortage of specialist housing, especially for the elderly and the disabled. It is considered that creative policies promoting adaptable "lifetime" dwellings are required to enable the elderly to remain in the community for longer. The Local Housing Needs Survey of the Parish is expected to confirm this.
Add "the disabled" into the policy.

AL13

It seems likely that most of the 1250 dwellings proposed (and this is a minimum figure) will be in Southbourne village. Some sections of the local community are very concerned about the change that an over 50% increase in households, over and above the current new development of 300 dwellings, will bring. Some consider that it provides an opportunity to bring some creative thinking to the future format of the village. Whatever increase in development may come, it appears that most residents do share the view that the 30% "affordable housing" proposed in the Local Plan should be truly affordable for those people in the Parish who are in housing need, and the Parish Council has made comments on the relevant policies in this Plan accordingly.
However, at present, it is clear that Southbourne is not in a position to successfully accommodate 1250+ further dwellings due to inadequate infrastructure. While it is recognised that Southbourne village may qualify as a "hub" due to existing services, it must be recognised that a number of these are currently inadequate and substantial improvement is required before development on this scale is delivered. It is understood that new development cannot be required to pay for current deficits, but it is unacceptable to add to these problems without some "up-front" provision to cater for increased needs. Three examples serve to make the point:-
(1) Crossings over the railway, both road and pedestrian, are required before any delivery of 1250 new dwellings. Even if this development is phased, it could be assumed that there will be a completion rate of some 80 dwellings a year (1250÷15). The additional pressure on the Stein Road level crossing arising from a combination of construction traffic and new residents will create unacceptable congestion, pollution and waiting times at the barriers. Inlands Road and Cooks Lane are not suitable for lorry routing. AL13(4) "Opportunities as they arise to improve the situation relating to the various existing or planned railway crossings" is much too weak to secure timely delivery. While this may be addressed in the review Neighbourhood Plan Masterplan, support at District level is required with appropriate priority in the CDC Infrastructure Delivery Plan (IDP) (Policy subsection 14).
In addition, no attention has been given to traffic management, either on the A259 or within the village, in the Preferred Approach. Strategic sites of a broadly similar scale around Chichester have integral transport proposals, but they are lacking in Southbourne. One key issue is that all along the A259 from Emsworth to the Apuldram junction it is becoming increasingly difficult for traffic entering onto the A259 (whether heading east or west) due to the high volume and at times seemingly continuous flow of traffic in either direction: this is a cause of driver frustration and potential cause of road accidents.
(2) The Parish Council has raised the issue of Wastewater treatment many times, and there have been difficulties arising from the current development sites. Reassurance is required that AL13 subsection 16 will be adhered to (16 - Ensure sufficient capacity within the relevant Wastewater Treatment Works before the delivery of development as required).
Stormwater discharges to Chichester Harbour appear to be on the increase and this is not satisfactory. The issue needs to be addressed and resolved by the Wastewater Water Quality Group (para 5.71).
(3) The Parish requires a significant increase in Public Open Space. The proposed Green Ring has received considerable public support and a Trust has been established by the Parish Council to deliver it. Some sections of the Green Ring will not be able to rely on developer delivery and while the project is included in the IDP it is accorded almost no priority (Policy subsection 14). This needs to be remedied.
Specific commitment in the Preferred Approach to the delivery of crossings over the railway, assured delivery of timely and appropriate Wastewater Treatment and specific commitment to the delivery of the Green Ring.
6.88 - To sustain and enhance Southbourne's role as a hub it is VITAL that development is properly phased AND that necessary infrastructure provision is made prior to new occupations.
Policy AL13 item 12: the protection of the SPA, SAC and Ramsar site at Chichester harbour necessitates the reinstatement of the Ham Brook wildlife corridor as part of giving the harbour and wildlife that uses it 'breathing space' and a ladder to the SDNP and as part of the strategy to relieve the pressure imposed upon the harbour by walkers and dogs.
7. Expansion and provision of community infrastructure potentially to include early years' childcare provision, community hall/centre and expansion of doctors' surgery plus flexible space for employment/small-scale leisure use;
As the open space and pitch reports put the improvement of the Bourne college facilities and the recreation ground improvements as a high priority project, this should be mentioned in this point
7. Expansion and provision of community infrastructure potentially to include early years' childcare provision, community hall/centre and expansion of doctors' surgery plus flexible space for employment/small-scale leisure use;

As the open space and pitch reports put the improvement of the Bourne college facilities and the recreation ground improvements as a high priority project, this should be mentioned in this point

DM3

The Preferred Approach advocates a flexible approach to housing density. While an average of 35 dwellings per hectare is recognised as a reasonable guideline, the Parish Council considers that some areas of a higher density would be appropriate, especially where single person accommodation could include small privet patios, terraces or balconies (for flats) in recognition that not all householders want a large private garden, provided that appropriate public open space is delivered as an alternative. Higher densities, as appropriate, also reduce land take.
S23
Southbourne Parish Council responses on the Jacobs Chichester Area Transport Model Report (March 2013), Chichester District Council Chichester Local Plan - Key Policies 2014-2029 and Chichester Local Plan Issues and Options Consultation has consistently drawn attention to the restricted scope of the transport studies undertaken to establish the impact of proposed development allocations within the Plan area. Studies have been concentrated on establishing the effects in the immediate vicinity of Chichester, particularly on the junctions of the A27. Traffic movements generated within/or destined for Southbourne Parish are assigned to a single Traffic Zone (TZ73). These movements are aggregated with other movements in the other TZs of the Western Corridor in order to assess the impacts at the cordon boundaries of the County boundary with Havant/Hampshire but most significantly the point of contact with the A27. Mitigation requirements have been assessed solely in respect of reducing increased congestion at A27 junctions. In respect of Southbourne generated movements these relate to the Fishbourne Roundabout.
CDC, in association with WSCC Highways, has failed consistently to examine local network impacts other than those projected to arise on the 19 junctions in the immediate vicinity of Chichester and the A27. This remains the situation with the update by Peter Brett associates of the Jacobs Study. However, in respect of the Bourne Villages this approach fails to take into account the impacts likely to arise within the local road network of the respective traffic zones. In particular, this lack of examination fails to take account of the potential impact arising from the scale of proposed housing allocations in this corridor. The adopted Chichester Local Plan Key Policies 2014 - 2029 document allocated a total of 620 additional houses comprising: Westbourne 45, Southbourne/Nutbourne 350, Chidham & Hambrook 35, Bosham 70 and Fishbourne 70. The Review Document proposes additional housing allocations (minimum) at Southbourne 1250 houses, Chidham & Hambrook 500, Fishbourne 250, Broadbridge/Bosham 250 - a total of 2,250 additional houses, an increase of + 246% over previous allocations and with these villages taking a 46% share of proposed total additional allocations in the Local Plan Review area.
CDC together with WSCC Highways should undertake to provide specialist advice to those Parish Councils chosen to implement proposed strategic housing allocations through Neighbourhood Plans in order to assess the impacts of the scale of such allocations on the local highway network. Such advice should be provided in order to aid site selection prior to any master planning of the subsequent development proposal and to help find solutions to traffic problems arising.
The above comments/representations also relate to the following Plan references:
Strategic Development/Design Strategies, pages 92-93, paras 6.1-6.6. Policy S32
Strategic Site Allocations - Southbourne, pages 127-129, paras 6.68-6.90; Policy AL13
Transport & Accessibility, pages 148-149, paras 7.4-7.52; Policy DM8.
Spatial Vision and Strategic Objectives
Objection
3.4 Given the huge amount of development proposed for the settlements to the west of Chichester we object to the emphasis placed on Chichester in the special strategy at the expense of the settlements on the receiving end.
There needs to be a fresh look at the cumulative impact on the settlements along the A259. We are not primarily an East-West corridor; we have our own distinct identities and histories. While the term 'East-West corridor' describes the road and rail links to the west of Chichester it is not a sufficient description of the Bourne villages.

3.7 Maintaining and enhancing the relationship between the SDNP and the Harbour AONB requires the reinstatement of the proposed Wildlife Corridor at Ham Brook. Without this corridor, this aspiration has no teeth.
3.8 Southbourne's "good transport links" have recently been downgraded with loss of all north-south buses which will be needed to connect any new housing growth north of the railway line to both the station and the A259. The station itself needs nearby parking and/or drop-off points, electric car chargers and secure cycle storage.
We suggest that the Bourne villages area be considered a 'green / blue ladder' between the AONB and the National Park rather than an East-West transit corridor. Varied countryside views from the Bourne villages towards the SDNP and AONB should be protected, as should views from the A259 and railway of the local countryside and countryside gaps. This will require properly contoured development and good screening.
Sustainable Development Principles
Objection
A reliance upon national 'sustainable development' principles is insufficient as these national policies are inadequate for delivering genuinely sustainable development.
There needs to be an emphasis on economic, social and environmental sustainability. The built environment and history, so frequently lumped in with environmental sustainability, should be considered as part of economic and social sustainability where this conflicts with natural environmental sustainability.
The construction industry is a significant contributor of carbon emissions and while we recognise that there is limited scope to make requirements beyond those mandated by national legislation the Local Plan should nevertheless indicate the direction of travel. It should set out what the community will increasingly come to expect from the industry in the years ahead, including the increasing weight that may in future be given to developments and developers which are making serious attempts to become carbon neutral.
The objective of the Local Plan should be to aim higher. While recognising that not everything is possible, we suggest referring to the principles set out in the Wildlife Trust's 'Homes for People and Wildlife' policy guidance: https://www.wildlifetrusts.org/sites/default/files/2018-05/homes_for_people_and_wildlife_lr_-_spreads.pdf and the World Health Organisation's 'Urban Green Spaces - A Brief For Action': http://www.euro.who.int/en/health-topics/environment-and-health/urban-health/publications/2017/urban-green-spaces-a-brief-for-action-2017 .
See comments in section above.
S17
Object
We welcome the presence of the military base and recognise that the needs of the military will determine policy while the base is maintained, including the need for an upgrade of the housing stock on the base.
However, should Thorney Island cease to be required for military purposes, rather than masterplanning for new development, the island should receive at least equal protection to other areas within the AONB, including the presumption against new development. Any proposed development should follow the principles laid out in the Chichester Harbour Conservancy's Planning Principles policy: www.conservancy.co.uk/page/planning.
In addition, while not seeking anything that would compromise the base's security, the policy should be to expand the Dark Skies sites and, where necessary, to take additional steps to support the existing ones e.g. by upgrading or redirecting street lighting. It should be possible to reduce vertical light pollution without any negative consequences for the existing use of the base. Further information on possible measures that could be considered may be found in the SDNP Technical Note here: https://www.southdowns.gov.uk/wp-content/uploads/2018/04/TLL-10-SDNPD-Dark-Skies-Technical-Advice-Note-2018-2018.pdf
We welcome the presence of the military base and recognise that the needs of the military will determine policy while the base is maintained, including the need for an upgrade of the housing stock on the base.
However, should Thorney Island cease to be required for military purposes, rather than masterplanning for new development, the island should receive at least equal protection to other areas within the AONB, including the presumption against new development. Any proposed development should follow the principles laid out in the Chichester Harbour Conservancy's Planning Principles policy: www.conservancy.co.uk/page/planning.
In addition, while not seeking anything that would compromise the base's security, the policy should be to expand the Dark Skies sites and, where necessary, to take additional steps to support the existing ones e.g. by upgrading or redirecting street lighting.
S24
Support
However, much of the language in this section is weak and aspirational rather than strong and definitive.
5.37 The coastal, alluvial agricultural plain has a particular historic and environmental character which we value greatly. This includes, but is not limited to recognition of its value for agriculture / food production. While we do not expect that this landscape will have the same protection as that inside the SDNP, it forms part of the setting for the National Park and deserves some recognition of the threats facing it from piecemeal (though rapid) development.

The draft Plan in its present form does not give sufficient recognition to the inherent value of the land. It would make sense for this to be rectified as part of a strategy or vision for the whole of the Bournes area, perhaps in a supplementary planning document.
We would like to see the preservation, protection and even reintroduction of bees and their habitats be given real consideration, given their ecological importance. It makes sense to do this as part of a policy covering countryside gaps so as to avoid conflict with humans.
We call for greater support to be offered to the establishing of community orchards and nut plantations. Doing so would also contribute to improving the balance between people and nature, enhancing social sustainability goals and promoting wellbeing.
5.40 We strongly support the "encouragement of proposals that enhance the woodlands and recreational links to and within this area."
5.41 There needs to be greater engagement with the SDNP and greater recognition from the SDNP that it is at risk of becoming an island, which will have serious negative impacts upon the park. We need the National Park to be more flexible in accepting a greater amount of housing within the park in order to relieve some of the pressure on the park's surroundings. While development is concentrated around the Park, we need to know that the Park will not object to the provision of infrastructure that such development needs to be sustainable, provided that it is planned sensitively.
5.42 We strongly support the maintenance of individual settlement identities. Southbourne would like to have a significant input into the formation of a settlement gap policy (and expects other communities along the A259 to feel the same). We would like a meaningful input at an early stage so that we can help shape a policy that commands wide public support.
S25
Object
This policy is very weak. A policy for protecting and managing the coast simply must address the wholly inadequate waste water infrastructure capacity and the frequent discharging of untreated waste into the Harbour.
It must also include a robust strategy for mitigating pressure on the harbour and coastal habitats from walkers and dog walkers by providing for alternative, attractive routes. This should clearly link up with policies promoting wildlife corridors, countryside gaps and green/ blue space.
The Plan should also seek to work with agriculture and horticulture businesses to reduce the impact of chemical and nutrient run-off into the Harbour. We recognise that there are constraints both in terms of national policy and market forces but the Plan should make clear that the direction of travel is towards greater environmental sustainability and reducing the environmental impact from businesses.
S26
Object

This policy is too weak.
5.52 & 5.53 The Plan should seek to work with agriculture and horticulture businesses to reduce the impact of chemical and nutrient run-off into the Harbour. We recognise that there are constraints both in terms of national policy and market forces but the Plan should make clear that the direction of travel is towards greater environmental sustainability and reducing the environmental impact from businesses.
We note that the adopted Local Plan links its Natural Environment strategy to that which protects and promotes biodiversity, but this link seems to have been dropped in the draft proposal. We recognise that there is a section on biodiversity but question the implication of the breaking of this link.
The policy needs to be strengthened.
S27 and S30
Object
It is very disappointing not to see a much stronger role for the use of green / blue space in mitigating flood risk. E.g. reed banks and areas designated for wildlife can form both a natural flood defence and promote other environmental goals of the Plan. Tree planting should also form part of this strategy, as should other measures to strengthen the land's resistance to flood degradation.
The reinstatement of the Ham Brook Wildlife Corridor would provide an opportunity to introduce many of these features in a part of the District prone to the flooding of homes and to storm-related discharges of untreated wastewater into the harbour.
The policy must think beyond what individual sites can do to mitigate the risk of flooding on small areas of land and look at the wider picture and what a more ambitious strategy could achieve.
The reinstatement of the Ham Brook Wildlife Corridor would provide an opportunity to introduce many of these features in a part of the District prone to the flooding of homes and to storm-related discharges of untreated wastewater into the harbour.
The policy must think beyond what individual sites can do to mitigate the risk of flooding on small areas of land and look at the wider picture and what a more ambitious strategy could achieve.
S28
Object
We are astonished that this policy is so thin. There needs to be a strategy which recognises different forms of pollution, including air quality, inland and coastal water and carbon emissions (not least from the construction industry). We need more detail on strategies to address the different forms of pollution and to be looking to a less polluted future, not simply mitigating against the deterioration of the status quo.
S29
Support
However, there needs to be an explicit recognition of the sometimes conflict of interest between green infrastructure primarily intended to be of human / community use and enjoyment and that intended to protect natural habitats and which may require restrictions upon access by the community.
There also needs to be much more thought given to coordinating the creation and protection of multiple green / blue infrastructure sites across the Plan area (or sub-sections of it). Many opportunities will be lost if sites are considered separately rather than as part of something larger. 'Islands' of green space are of much less benefit to humans and wildlife than larger, linked green and blue infrastructure. Again, this supports the reinstatement of the Ham Brook Wildlife corridor.
S30
Support
We are delighted to see a wildlife corridor policy included within the Neighbourhood Plan, as this builds upon the aims pursued in the made Southbourne Neighbourhood Plan and the work of the Southbourne Environment Group. We do however very strongly object to the removal of the previously proposed Hambrook Wildlife Corridor, referred to only obliquely in the Background Paper. It should be reinstated.

Doing so would work towards the policy objectives of S30 and complement its specific proposals.
1) There are a great many "preferable sites available outside the wildlife corridor" so reinstatement would not hinder the District or Parish's ability to meet its housing target.
2) Without prejudging the community consultation, it is conceivable that proposed development sites WITHIN the proposed corridor could be approved provided they do "not have an adverse impact on the integrity and function of the wildlife corridor".

In considering alternatives to the Chidham / East of Nutbourne Wildlife Corridor, paragraph 5.5 of the Background Paper states that "West of Nutbourne there are a number of ecological features but the close proximity of residential areas and proposed development, mean that the [proposed] corridor may be too narrow to act as a suitable functional strategic corridor." This actually prejudges the review of the Southbourne Neighbourhood Plan and we reject this argument. The proposed Ham Brook Wildlife Corridor is or could easily be as wide as others in the policy paper and it is for the community - through the Neighbourhood Plan - to determine where development goes ahead. The community cares very deeply about the local environment and could easily choose to focus development outside of the proposed route of the Ham Brook Wildlife Corridor.

There is no national or local policy reason why there should be no more than one wildlife corridor in a single Parish, especially where there is no conflict with the points above / in policy S30 and where the parish is one of the largest in the District and is home to several distinct communities. On the contrary, reinstating the Ham Brook corridor would strengthen the goals set out in paragraphs 5.64 and 5.65 of the Local Plan, namely, allowing the "movement of species between areas of habitat by linking wildlife sites and reducing the risk of small, isolated populations becoming unsustainable and dying out... They also function as green infrastructure."

This last point is itself emphasised by the Plan's policy AL13 for Southbourne and many objectives would be advanced by reinstating this particular Wildlife Corridor. i.e.:

8. It COULD provide for some public open space for the Parish (not all of which is, will be part of or will be connected to Southbourne VILLAGE's Green Ring).
9. It would enhance the setting of the SDNP and reduce settlement coalescence (without restricting development elsewhere in the Parish).
10. It would expand provision for green infrastructure.
11. As per background paper paragraph 5.5. referenced above, it would reconcile the need to avoid an adverse impact on the nature conservation interest of identified sites and habitats while maintaining a wildlife corridor wide enough to be of ecological value.
12. It would provide mitigation to ensure the protection of the SPA, SAC, Ramsar site at Chichester Harbour.

As per Supporting Document 024, Solent Recreation Mitigation Strategy, paragraph 2.12, there is a requirement for the creation of a Suitable Alternative Natural Greenspace (SANG). Furthermore, Southbourne's made Neighbourhood Plan's Green Ring policy specifically aims to provide alternative routes for dog walkers to relieve pressure on the harbour. As per paragraph 4.12 "these could be created by a developer as part of a very large housing scheme [such as is proposed for Southbourne] or alternatively will be implemented through the Solent Recreation Mitigation Partnership."

The Background Paper does not present any, let alone the full picture of the area's ecological importance. The Ham Brook follows a natural environmental feature from the AONB to the SDNP. This natural water course is home to water voles (seen by CDC Wildlife Officer and local environmental volunteer as recently as January 2019) and the land north of Priors Leaze Lane is a Barn Owl Habitat (as referenced in Chidham and Hambrook Parish's made Neighbourhood Plan). There is ancient woodland either side of the railway line next to the trout farm and this is a dormouse habitat too.

In conclusion, S30 is an excellent policy but it MUST be strengthened by the reinstatement of the Ham Brook Wildlife Corridor. Doing so would not compromise any development objectives of the Local Plan. Indeed, doing so would advance several objectives and policies within it.

S23 and AL6

Object
To the proposed Birdham Road to the A27 Fishbourne Roundabout.
With so much new development - and traffic - proposed for settlements along the A259, our road is going to be the focus of a huge amount of new congestion, with all of the associated negative impacts on air quality and sustainable transport goals. Feeding more traffic into the Fishbourne roundabout will only make it harder for drivers from the A259 to get onto / across the A27.
In addition, the proposed link road goes straight through a flood plain and site of great environmental importance - one which links the coast to the city of Chichester. Furthermore, the proposed link road would have a significant negative impact upon views from the coast to the city and the SDNP and from the city and SDNP to the coast and Manhood Peninsula. It would also negatively affect the setting of the proposed Fishbourne Wildlife Corridor.
We support creation of an integrated and sustainable transport plan for the District, or at the very least for the area west of Chichester. This plan should draw upon the ongoing work of the ChEmRoute group's investigations and proposals for the National Cycle Route 2 (NCN2) and be coordinated with WSCC with the goal of introducing high quality and separated cycle links between the villages along the A259 and Chichester. The route or routes may include a fast but safe link along the A259 aimed primarily at experienced cyclists and commuters as well as a slower, more meandering and leisurely route north of the A259 (and perhaps the railway). To make these cycle routes sustainable they will need connections and feeder routes from new and existing developments.
In developing a more ambitious and safer scheme for cyclists care must also be taken to ensure that pedestrian routes are protected too. The vision must be to ensure that both cycle and pedestrian traffic is encouraged and supported and not brought into competition with each other.

Spatial Strategy, Transport Infrastructure , Page 78 s5.27
In addition, the County Council is expected to continue to support new development through a package of transport improvements which will continue to aim to reduce congestion and encourage people to use sustainable modes of travel such as walking, cycling and public transport.
This supports Southbourne's desire for a pedestrian bridge over the railway line as that will encourage people to walk rather than drive, as well as supporting a road over the railway line as this will also reduce the walking time for many residents wherever the road is placed. It may avoid current routes which involve walking through fields and over unmanned rail crossings. A road would be safer and more useful to pedestrians. The requirement for bridge should be included in policy S23.
DM34
Object due to issues in the supporting evidence.
Chichester Infrastructure Delivery Plan, Southbourne Parish - Local Plan Review Policy SA13 page 90 section 15.4
In the title, play space (children) is given, when the project is actually children and youth combined.
The heading needs to be amended to Play Space (Children and youth)
Chichester Open Space, Sport Facilities, Recreation Study and Playing Pitch Strategy: Open Space Study Sub Area Analysis (Part 2 of 2) Page 13 table 4
This table says there is good provision for childrens play space, when section 2.3 table 3 shows there to be a shortfall throughout the district.
Object due to issues in the supporting evidence.
Chichester Infrastructure Delivery Plan, Southbourne Parish - Local Plan Review Policy SA13 page 90 section 15.4
In the title, play space (children) is given, when the project is actually children and youth combined.
The heading needs to be amended to Play Space (Children and youth)
Chichester Open Space, Sport Facilities, Recreation Study and Playing Pitch Strategy: Open Space Study Sub Area Analysis (Part 2 of 2) Page 13 table 4
This table says there is good provision for childrens play space, when section 2.3 table 3 shows there to be a shortfall throughout the district.
Water Quality Assessment
Housing allocation: The Thornham evaluations have been based on a housing increase in the Thornham catchment area, over the period covered by the report (2020-35), of 1,000-1,500 dwellings. In view of the fact that the Havant-Emsworth plan also has many hundreds of new builds planned in this catchment area, this estimate would seem to be grossly under-estimated ref. Page 25, Table 26. Page 15: "Westbourne" should be added to Table 1.1. Page 60 para. 3.10.2 claims to include Havant but Havant is excluded in other parts of the report e.g. Table 1.1.
Climate change: it is disappointing that any effects of climate change have been specifically excluded (page 28).
Assessment of Headroom: in assessing headroom, AMEC's report states that the Environment Agency guidelines, specify 150 litres/person/day and five people per dwelling. The report has used different figures i.e. 120 litres/person/day and 21/2 people/dwelling. Their justification for this (para. 3.2.12) is that Southern Water prefer these figures. The effect is to reduce the Thornham WwTW's current headroom from 1,063 dwellings down to 400. Any calculations must be formally agreed with the Environment Agency. Page 29 para 3.2.4 suggests that this has yet to be agreed. There is considerably inconsistence in the quotation of dry weather flow (DWF) and Headroom. Page 60 para. 3.10 indicates that consented DWF (hence Headroom) is already in excess of consent (consented DWF 6,565 m3/day, current DWF is 6,580 m3/day). Statement of headroom, without dates, or methodology are meaningless.
Discharges: some assessments are omitted on WwTW, which discharge directly into estuary/coastal waters and Thornham WwTW has been put into this category (table 2.2). In practice, Thornham discharges onto Eames Farm from where it flows through Little Deep, into Great Deep before discharging into the shellfish beds (already classified as "unfavourable") at Prinsted (Chichester Harbour) as in Page 61 para. 3.10.13. Page 21, Table 2.3 is incorrect. In its objectives (page 10), the report indicates that it should be considering any impact on shellfish. No impact on these shellfish beds seems to have been assessed.
Storm discharges and shellfish: the report (Page 61 para. 3.10.9) states that storm discharges have been a significant problem for the Thornham WwTW. However, it specifically excludes any consideration of storm discharges over this period (2020-2035). It does not assess the effect of large quantities of primary-treated sewage (filtered only) on the Eames Farm marshland or the Prinsted shellfish beds (Page 23 para. 2.2.12, Page 25 para. 2.2.19). The AMEC report seems to suggest that the discharges processed through Thornham WwTW will have a minimal affect. This observation does not take into account, the very large levels of (Grade 1) untreated storm discharge.
Data: There are significant areas, where Thornham WwTW's data has not been provided and National Average data used instead.
Objectives not met: Page 9 Objective "investigate demonstrably deliverable ways of dealing with Wastewater treatment capacity". The MWH Report (2010) page 17 clearly indicates that expansion of Thornham WwTW was not viable. No comment or way of dealing with capacity limitation has been investigated.
Clear statements of exactly what additional works and what realistic dates are required.
5.69-5.72 , Section 9.1 of the Surface Water and Foul Drainage SPD and its referenced Headroom Tables are out of date, need to be updated, and its guidance amplified, to cover the timescale of the Local Plan Review 2019 to 2035 and the impact of future housing development.
Reasoning
Headroom Table 2 of the Water Quality Assessment Report states that as at 31st October 2018 the Estimated remaining headroom (households) was 1,020. This is well below the combined Southbourne and neighbouring West Sussex parishes Local Plan Review planned housing development numbers without even taking into account that Thornham WwTW also serves the Emsworth area in Hampshire which is is the subject of increased and significant additional housing development.
This issue is of particular importance given the large scale development proposed for the Southbourne Parish under the Local Plan Review, that this SPD is "a material consideration when assessing planning applications or appeals for any new dwelling(s)" and that the Local Plan Review itself states that "measures will need to be put in place at each WwTW and their associated catchments and sewer networks in order to tackle current and future water quality issues to support future housing growth." These measures include "Upgrades to physical capacity and Upgrades to sewer networks".

5.72, Policy S31 states that "Proposals for development within the Plan area should be able to demonstrate no adverse impact upon the quality of receiving waters" It is proposed that this statement should be amended to be clearer and more appropriate to local circumstances, as follows: "Proposals for development within the Plan area must be able to demonstrate no adverse impact upon the quality of receiving waters including with regard to the capacity and condition of existing wastewater and sewage systems, local storm discharge risk and the capacity of the Wastewater Treatment Works. The Council as planning authority will look to satisfy itself on these matters including to ensure sufficient capacity within the relevant Wastewater Treatment Works before the delivery of development as required."
Reasoning
The referenced Surface Water and Foul Drainage SPD is out of date and insufficiently clear and rigorous in its guidance and requirements. The SPD needs strengthened with regard to new development requirements and potential adverse impacts on Chichester Harbour AONB, on the small watercourses feeding into the Harbour waters, given known local problems with the sewer network (as referenced in Para. 2.4) e.g. at Nutbourne, and as Para. 2.3 of the Surface Water and Foul Drainage SPD states "The condition of the water environment is not currently good enough to meet the required standards (of the European Water Framework Directive). Policy AL13 for Southbourne Parish also states that "Development will be expected to address the following requirements (including), !6. Ensure sufficient capacity within the relevant Wastewater Treatment Works (i.e. Thornham) before the delivery of development as required".

Characteristics of the Plan

Proposed Supplementary Planning Guidance
Object
Objection is raised to the use of the term East-West Corridor with regard to west of the City of Chichester. The use of the term corridor implies the focus of policy is on transport and through movement to the detriment of a more balanced focus on local settlement, existing residential, local countryside and amenity issues.

There is a lack of vision, clarity and coherence of planning policy towards the Bourne Villages, their character and the surrounding countryside that lies between the South Downs National Park and Chichester Harbour AONB. The current piecemeal policies approach that focuses on the individual settlements and individual thematic policies is detrimental to the coherence and effectiveness of planning policy, the character of these settlements and their surroundings and to the South Downs National Park and Chichester Harbour AONB.
The Preferred Approach fails to take account of the potential impact arising as a result of the scale of proposed allocations. The adopted Chichester Local Plan Key Policies 2014 - 2029 document allocated a total of 620 additional houses: Westbourne 45, Southbourne/Nutbourne 350, Chidham & Hambrook 35, Bosham 70 and Fishbourne 70. The Review Document proposes additional housing allocations (minimum) at Southbourne 1250 houses, Chidham & Hambrook 500, Fishbourne 250, Broadbridge/Bosham 250 - a total of 2,250 additional houses, an increase of + 246% over previous allocations and with these villages taking a 46% share of proposed additional allocations in the Local Plan Review area.
The absence of a Countryside Settlement Gaps Policy at Local Plan Review stage is regretted and one is only verbally promised for June 2019. The lack of a coherent vision for the Bourne Villages is at odds with the approach taken to other Chichester areas and their communities which is reflected in a statement made by Cllr Tony Dignum (Leader of CDC) on 18 October 2018 in the Chichester Observer: "there is no doubt that we live and work in one of the most beautiful areas of the country and we want to keep it that way. We aim to deliver improvements within our city and towns so that our area continues to be one of the best places to live, work, and visit in the UK. These improvements are being expressed through 'vision' projects for the city and for each of our towns" (Selsey, Midhurst and Petworth are cited as examples).
There is at least an equally strong case for there to be a vision for the Bourne Villages, the band of settlements, countryside and amenity land that lies between Emsworth and Chichester, the South Downs National Park and Chichester Harbour AONB. Not to have a coherent vision for this area is detrimental to the Bourne villages and to the neighbouring areas. Much of the character of these settlements, especially Southbourne, derives from the wider area within which they are situated.
1 Chichester District Council should prepare Supplementary Planning Guidance on a vision for the Bourne Villages, comprising Westbourne, Lumley, Hermitage, Prinsted, Southbourne, Nutbourne, Chidham, Hambrook, Bosham and Fishbourne, the surrounding countryside and their relationship with neighbouring Emsworth/Havant, the City of Chichester, the South Downs National Park and Chichester Harbour AONB.
2 The use of the term East-West Corridor with regard to west of the City of Chichester be restricted and only be used for transport issues and the A27 itself, and not be applied to the Bourne Villages and their surroundings..
The above comments/representations also relate to the following Plan references:
i) Page/para nos: page 22 §2.29
Policy reference: Character of the Plan Area.

ii) Page/para nos: p24 - 25; §3.3 - §3.10
Policy reference: Spatial Vision & Strategic Objectives: East-West Corridor
iii) Page/para p35
Policy reference: Spatial Strategy - Policy S3: Development Strategy
iv) Page/para nos: p82 - 84; §5.34 - §5.42 & §5.44
Policy reference: Strategic Policies - Countryside S24: Coast S25
v) Page/para nos: p 92; §6.4 - §6.6
Policy reference: Strategic Development - S32

INTRODUCTION - strategic and local importance of A27 improvement

The PC is concerned that the strategic context of the Plan, whilst making reference to the importance of the A27 trunk road, fails to realise the impact of the lack of the implementation of a scheme has on the future sustainability of new development proposed, let alone the completion of those proposed under the current plan.

Reliance on S106 and CIL contributions to mitigate, for instance increased traffic, will have little impact on alleviating the problem that the current A27 represents to communications and, importantly, the city of Chichester's future economic viability.

The plan makes little attempt to future proof Chichester and its hinterland with its continued reliance on relatively low paid employment in tourism, horticulture and areas such as retail.
The Coastal West Sussex and Gt Brighton Local Strategic Statement makes strong reference to the
Inter-relationship between the Bognor Regis northern bypass on the A259, the Arundel bypass and the A27 improvement at Chichester - the impact of these two schemes on Chichester, already apparent at the Bognor roundabout, could be catastrophic congestion.

Comments on Main policies.

S4 Meeting housing need

The Manhood Peninsula is expected to deliver 1993 units during the Plan period. Of this figure, 600 are in Selsey, East Wittering and Hunston, 175 as parish housing requirement in Birdham and North
Mundham. It is not clear what proportion of the residual 1208 fall into the category planning permissions, committed or made as of 2017 and what are expected to be small windfall sites.
Without this breakdown the potential impact on parishes such as Sidlesham, that are deemed unsustainable for housing, cannot be assessed. This is particularly important in Sidlesham where, due to prior consent approvals through the conversion of agricultural / horticultural buildings there is potential for 100 plus new units. This potential that would appear to be categorised as "windfall" obviously does not fit the definition, especially as to date (32 approvals in Sidlesham and Earnley), none are social housing but all are full market and some, costing £600k, are beyond any prospect of meeting the needs of first time buyers. The parish considers the majority of the conversions inappropriate and the potential scale of the number of conversions challenges the District's sustainability definition that is well founded for the parish. Whilst the Parish Council appreciates that the guiding legislation stands outside the local plan process, the potential distortion the developments, which are essentially on the ex Land Settlement Estate, needs to be specifically addressed in the local plan. Additionally, there are implications for policies S11 and DM15.

S6 Affordable Housing, DM4 Affordable Housing Exception Sites (S12 Infrastructure Provision)

The policy and supporting text gives too great a flexibility to developer, especially in terms of the economic viability of development. The renegotiation by developers of the proportion of social housing post original consent appears to have characterised many developments arising from the existing plan and consents that were granted prior to its approval. The fact that the plan seeks to control the artificial sub division of sites to avoid the social housing "trigger" gives a strong indication of many volume builders' reluctance to truly engage in meeting the true scope of overall housing demand. Whilst the hybrid of shared ownership meets a particular aspect of overall demand, it fails to address the increasing necessity of proper social housing. The true economic viability of sites needs rigorous independent assessment and, if not viable as market led development, the appropriateness of the site for development should be reassessed or its consideration for acquisition by, for instance, a community land trust scheme or compulsory purchase to provide social housing should be considered.

Policy S12 is welcomed, but the range of provision to be supported, especially if whole life costs are to be met will place great demands on funding streams such as S106, CIL and other funding streams and there must be doubt as to whether your council's Infrastructure Development Plan can be fully met.

S7 Gypsy and Travellers and Travelling Show People, DM5 Accommodation for Gypsies

It is noted that separate provision is required in the 5yr housing supply for this category. The eligibility for inclusion is that the individual still has an itinerant life style, ie travelling from place to place. Many of the gypsy families/individuals that seem to qualify under this category patently do not exhibit this form of life style. Local experience fully supports this position with gypsy communities simply using their caravan homes as a base to engage in trade, with the site often becoming the builders' type yard for the storage of materials or the waste from their trade. This form of occupation does not distinguish the use from any other individual living in an area and consequently should not qualify for any special recognition; in fact, in many cases such use under normal planning powers would be contrary to policy.

This "special treatment" causes a great deal of resentment in local communities especially where there is a social housing need - that is most areas - and where school places are under pressure.
The qualifying criteria must be fully investigated and a change in status over time reviewed as many sites, originally for itinerate use, simply become settled locations and do not therefore meet the criteria. It seems that the process from itinerant to settled status is a common progression and has the result of the "need" for new pitches continually increasing.

The substantial increase from the 2015 plan requirement to the 90 plus gypsy pitches now identified illustrates how the process is being used to bypass Planning that would restrict the provision of such "housing" if it were built development and that areas become favoured by gypsy communities as other gypsies are already located there and a sub community established. The criteria for assessment of eligibility must be reviewed together with the transition to settled status and additionally the degree to which concentrations of gypsy and other travellers are occurring in specific areas - this is considered to be the case in Sidlesham.

DM6 Accommodation for Agricultural Workers

The reintroduction of this qualifying criteria is welcomed. However, there is a major issue with enforcement and the policy needs to be strengthened to ensure the occupant continues to be employed in agriculture or horticulture. The change away from agricultural/horticultural occupation is often not declared and after the requisite elapse of time, ELD status is applied for. The need to register agricultural/horticultural occupation on an expiry time basis that would exclude qualification under ELD should be considered in the policy and/or the surrounding text. The subdivision of land and the separation of the original accommodation from the land is an increasing aspect of land holding in areas such as Sidlesham. On many sites an agricultural viability assessment is made as to whether a subdivided holding is viable and whether a constant presence on site is required to maintain the use and therefore accommodation required. However, this potential position should be a consideration at the original point of separation and a condition made that the subdivided land should not benefit from a subsequent consent for another house/residential caravan. This subdivision has and continues to be a trait on the ex LSA estate and, particularly within the HDA's, undermines their priority for horticultural production. At least in the HDA's the approval of agricultural worker accommodation should be restricted and perhaps limited to a residential caravan on a temporary consent and not lead to a progression to a permanent building as currently happens.

S11 Horticultural Need, DM15 Horticulture

There appears to be a weakening of the distinction between what in the 2015 Plan were termed
"hub" sites at Runcton and Tangmere and the other HDA sites in Sidlesham and Almodington.
Para 7.92 is particularly troubling ". It is not expected that large scale glasshouse development
(228,000 sq m required) will occur in Sidlesham and Almodington HDA's to the same extent as at
Runcton and Tangmere. The statement introduces doubt over the distinction between large scale industrial type of production and what is termed "market garden" horticulture expected at Sidlesham and Almodington.

The statement about "land adjacent to an HDA" previously related to Runcton and Tangmere. Its extension to Sidlesham and Almodington again introduces doubt over your council's true intentions about the scale of the industry envisaged outside the old hub sites and undermines the strong position it took on large scale such the Madestien proposal in Almodington. Your council stresses the importance of the HDA but continues to allow the break-up of the land within the smaller ones through conversion of buildings to residential and the take of land for gardens under "prior consent" as mentioned above. This approach is contrary to the proposed policy and will lead to further fragmentation and inefficient use of the land that remains. This approach could lead to requests for land outside the current smaller HDA's and bring glasshouse development into conflict with the overall environment. Many of the largest glasshouse developments are outside the HDA's but in established glasshouse areas and lead to the possibility that the HDA's need review and at least two new areas established based on the Fletchers Estate and Jakes Nursery and on Street End Lane. These area are equal or probably exceed production in many parts of the two HDA's.

S23 Transport and Accessibility

The strategic need for a solution to the A27 has already been mentioned but the impact locally cannot be overstressed in respect of the Manhood Peninsula. The high levels of out commuting for employment and many services are all dependent on a functioning A27 and further development in reality can only aggravate a non-functioning situation.

The cul-de-sac position of Selsey presents major problems for the town - the second largest in the district - in terms of emergency services and, for instance, the levels of congestion when heavy domestic traffic flows are combined with the summer tourist traffic that swells the population to approaching four to five times its winter levels. The sustainability of this situation in terms of environmental impact, the economic viability and overall acceptability must be doubtful. This is apparent to the road users but increasingly the areas that the road passes through, such as
Sidlesham, suffer pollution from exhaust emissions, noise, unacceptable delay in access from adjoining roads and properties, just simply crossing the road by pedestrians is made almost impossible as traffic is so often two way with no gaps. This situation cannot be ignored and just allow the road to be loaded with more traffic. The carrying capacity of the B2145 must be seen as a limiting factor in any future development in Selsey. This situation is mirrored on the A286 with The Witterings and Bracklesham.

It will be important that development in Selsey contributes to traffic management on the B2145 and that the whole of the road is eligible for any S106 and CIL contributions and not just the immediate locality of Selsey. The overall intention should be to improve safety, ensure speed is observed and allow safe road crossing. These factors will be considered within the Sidlesham Neighbourhood Plan.

Pollution is an increasing concern and in line with the Plan's policy objectives for greening of the environment, structural tree planting will be proposed within the B2145 corridor. The plan makes reference to sustainable transport but there are no specific proposals. It is suggested that for the Manhood Peninsula the proposed Greenway Selsey to Chichester is part of a specific policy that seeks to protect the adopted route and that Neighbourhood Plans for Hunston, Sidlesham and Selsey then adopt the route into their plans.

S24 Countryside, DM22 Development in the countryside, DM31 Trees, hedgerow and
woodland, DM29 Biodiversity

These policies and accompanying text is supported and will form the basis of Sidlesham's Neighbourhood Plan. Para 5.39 indicates conversions of existing buildings will be favourably considered where they lead to uses needed to support the rural economy and create 'rural affordable housing'. Currently, many conversions do not meet these criteria, especially the latter where often large upper market houses are developed way out of the range of meeting any local social need. The policy needs to reflect this problem with more specific criteria covering what is acceptable within the scope of any conversion.

The identity of the rural areas is an important consideration in maintaining their character if they are not to become just the spaces between larger settlements. This is particularly important on the
Manhood Peninsula and in the countryside associated with the transport corridors of the A286 and
B2145. The open countryside along these routes with their small settlements are in danger of encroachment by development and urbanisation. A specific policy is suggested to protect such areas and enhance their character by schemes of tree planting, improvement to the roadside environment and strong traffic management. Again, this approach will feature in the Neighbourhood Plan.
Whilst it is appreciated that agriculture is currently in a state of uncertainty, a policy that seeks to promote the balance between agricultural production, the environment and amenity would be welcome as a basis for whatever system of agricultural subsidy eventually is formulated. Particular emphasis should be placed on the protection of high grade agricultural land (grade 1 - 3a), biodiversity , and for instance structural tree planting for drainage and co2 reduction. A positive approach to recreational access in support of green tourism should also form part of a strengthened countryside policies.

S25 The Coast, S30 Strategic Wildlife Corridors

The policy makes reference to Chichester Harbour Management Plan but should also make reference to the Pagham Harbour Management Plan - although this currently only covers the period to 2018, the RSPB can be expected to bring forward a new plan for the next 5-10yr period.
The significant changes to the Pagham Spit over a relatively short period of time could have significant impact on the drainage of the harbour and particularly the surrounding land and including the R. Lavant flood relief channel. The importance of the Harbour's drainage function should be reflected in a specific policy that balances the significance of the habitat with the land drainage issues.

The Medmerry Scheme has created a significant change in the coastal geography creating a significant new coastal habitat extending westward from the margins of Pagham Harbour to within a short distance of the edge of Chichester Harbour AONB. An important corridor for wildlife is developing over the short distance between the two and should be considered as a designated area under policy S30.

S27 Flood Risk Management

The plan makes reference to flood risk but does not fully realise its significance to the Manhood
Peninsula and the constraints it places on development, the future of its economy and the resilience of its communities.

Whilst SUDS has its uses in localised drainage it often simply drains an area into a downstream network that has to cope with the additional run off. The Peninsula has an extremely high water table for the majority of the year that makes most soakaway drainage ineffective. An integrated network utilising the existing ditch system and augmenting this with attenuation areas with good clear outlets to the sea must be developed and maintained.

Many new housing developments rely on SUDS but simply only cover the development site. Developers have to be responsible for the water they produce from the point of generation to its disposal to the sea or main river. This should form a requirement of any planning agreement and a policy within the plan should reflect and formalise this responsibility. Realisation of the true infrastructure cost of drainage should be fully reflected in the site evaluation process and its economic viability. The development of many coastal locations or those on flood plain may be proven uneconomic if the real cost for drainage were realised and not the passing on of the problem
downstream as currently occurs.

Reference is made to Surface Water Management Plans. It is the responsibility of the lead strategic flood authority (in this case WSCC) to produce and maintain these plans. As a material consideration there should be policy and text to ensure the plans are kept up to date and that priorities identified in plans are brought forward for action and funding such as CIL directed to their implementation.

S31 Wastewater Management and Water Quality

Southern Water needs to have information on future demand foul drainage - detailed discussions with SW have shown that the levels of development known to them, especially in respect of
Sidlesham Waste Water Treatment Works, do not appear to reflect the development levels and question the capacity of the facility. Additionally, the size and overall functioning of the pipe network is very troublesome, for example, the "trunk main" from the Witterings. It would appear that calculations are primarily based on dry flow rates where much of the pre 1960's housing on the
Peninsula has mixed drainage and the foul system suffers from ground water inundation. The Parish requests that a clear reappraisal of the wastewater capacity of SWWTW and of the network is made and the infrastructure costs of a system that has the required headroom and a network that will support existing and any new development is made and factored into the plan.

DM35 Equestrian Development

The parish is concerned about the high level of horse related development that is occurring on the
Peninsula, especially on the settlement boundary margins, within the ex LSA estates, and associated with gypsy sites. Much of this development is often deemed as "agricultural use" when it is really a "change of use" as the livestock are not supported by grazing of the land. The use for "horse culture" often removes high quality land form agricultural/ horticultural use, despoils the land creating a strong visual intrusion often close to residential areas. The Plan policy should ensure that the change of use is properly applied and enforced. Clarity should also be sought as to the true recreational nature of much of the horse keeping and as there is no bridleway network on the Peninsula how often large numbers of horses kept on a small acreage might be exercised.

We object to the allocation site at Highgrove Farm, Bosham with approximately 13 ha of open countryside allocated to a minimum of 250 houses.

This development in the countryside directly conflicts with policy S24 Countryside and Policy S26 the Natural Environment; which clearly states there should be no adverse impact on the openness of views in and around the coast, designated environmental areas (i.e. the AONB) and the setting of the South Downs National Park. The proposed development at Highgrove Farm directly contradicts these policies.

We strongly believe that this development would cause irretrievable harm to the landscape character, setting and context of Chichester Harbour AONB and the intervisibility with the South Downs National Park. We feel that the measures proposed within the policy would not be able to sufficiently mitigate for the damage this development would cause.

See attachment

See attachment

See attachment

See attachment