Policy S26: Natural Environment

5.51 Church Farm Lane and surrounding area has a very high biodiversity of habitat for wildlife and there are animals and birds on the Red list including nocturnal animals. Building development in fields to the South would have a harmful effect on habitat and light pollution on the nocturnal species. There would be an adverse impact on the openness of views from the Church Farm Lane/Stubcroft Lane footpath. So your policy is directionly correct but is at odds with other areas of your plan

How can you be protecting "distinctive local landscape" by destroying it with so many houses?

Policy S 26. There is no mention of the Chichester Harbour AONB in the Policy while the SDNP, which is outside the Plan Area, is referred to

.S26 in the second bullet at '....and the setting of the SDNP': change to '...and the setting of the Chichester Harbour AONB and of the SDNP

Resident of West Wittering
Acres of very productive agricultural land on the Peninsula has already been taken over by high density urban housing estates and now even more damage is proposed.

The wording is not strong enough. Too many vague terms of " is not unduly compromised" ",
" significant harm", "may be occasions..."

West Sussex Grower's Association's Growing Together Strategic Plan 2017-West Sussex produces over £1billion in annual sales of fruit, vegetables, salads and plants and employs more than 9,000 people, employing 65% in the Chichester area. They proceed to state that their members require additional land for the successful growth of the local horticultural industry. The Local Plan area has the best natural light, longest daylight hours and some of the most fertile agricultural soils in the county, CDC are destroying this prized asset by building on it. This arable land needs protecting from development.

Policy refers to no adverse impacy on the setting of SDNP with no mention of the AONBs. Note that SDNP is outside the Local Plan area. Chichester Harbour AONB is in the front line and vulnerable.

Para 5 51 is wooly. What does " not cause significant harm to the function of the natural environment" mean?

The Spatial Vision and Strategic Objectives 3.6 states that any development west of the city will
" conserve and enhance the local distinctiveness, character and cohesion of existing settlements".
The Sustainability Appraisal states, in relation to Chidham and Hambrook " The scale of the development will completely alter the existing development and there will be significant impact to the existing historic village" These two statements are contradictory . Chichester Harbour Trust have expressed concerns regarding the impact on the AONB The magnitude of an additional 500 homes {growth of 55%) will patently alter the local distinctiveness and character of Chidham & Hambrook

Night time light associated with current planned and proposed development adjacent to the Pagham SPA will impact on the wildlife and diminish the current 'dark sky'

Natural England broadly supports policy S26 on the Natural Environment. However, we recommend that explicit reference is made to Chichester Harbour AONB in the second bullet point (though recognising that DM19 is the policy for the AONB). We would also like the Plan to acknowledge the importance of views from the SDNP (at Kingley Vale) to the AONB, and strive to protect this connection. We suggest the visual link between the two protected landscapes could be referred to in the supporting text.

We welcome the policy regarding best and most versatile land. Though we note that the Sustainability Appraisal concluded that the majority of greenfield allocations would impact BMV land.

Support.

The natural environment is dependent on a safe level of global warming being maintained. The IPCC has made clear that we are not on course to keep to low temperatures rises unless we take urgent and unprecedented measures to keep global warming within the recommended 1.5 degrees centigrade.
All governments (national and local) have a duty to limit the negative impacts of climate change. This Plan fails to consider measures to protect the natural environment and the residents' health and well being in this respect. Other councils are declaring a climate change emergency and taking action to update their Carbon Management Plans in light of the recent IPCC report. This Plan should include the setting of a carbon neutral target for Chichester District and a governance structure to ensure close monitoring of the Plan. This should be integrated into the Council's commitments and leadership to businesses and strategic partners to deliver widespread carbon reductions across the District.

Policy S23 A more robust tree and planting policy is required to ensure that Chichester District keeps as many trees and other green planting as possible to mitigate against traffic fumes. All street trees (WSCC) should be given priority over new developments, as mitigation measures (planted afterwards) will never make up for the ecology lost by felling, and removing already established hedges and trees etc. Where the trees aren't stree trees they need to be conserved with TPOs, so that it sends a clear message that Chichester needs its tree cover, particularity in the town centre and along the main roads to provide shade and oxygen, and temperature stability.
Promotion of more sustainable methods of transport, this means building more cycle routes (not just painting lines on roads). West Sussex CC are plainly failing to do this, (28 km planned over 5 years for the whole of the county) so District must work towards this by making sure that all developments have workable junctions onto main roads or off road routes built parallel and then sign posted. District Council may not build these, but it can find funding streams and push for them to be applied locally, and hold the developers to these plans promised, so that CIL money is spent wisely.
Support integration of trains and buses, again this should be a county function, but a unique opportunity to work to integrate the railway station and bus station will be lost in Chichester if the Southern Gateway goes ahead in its current form. And as for losing the taxi rank outside the station too, that beggars belief. Where are the fast charging points for electric cars at the station and throughout our town, West Sussex lags behind the rest of the country in provision, and Chichester especially with just two slow charging points outside the CDC offices which are always full.
Wildlife corridors need to be wider and bolder, and to allow crossings of the roads that block access. The ones on the east side of Chichester are particularly miserly. Most wildlife seems to be seen dead on the roads rather than in the wild. The whole reason for being in this area is that it hasn't got coastal development right along, but has access to the wider landscape of the sea and sky.
Objection to the building of a new road between the A27 and the Birdham Road A286. This particular part of Fishbourne being listed as floodplain 2 will need piling to support a road, which will destroy the character of the Fishbourne meadows and paths to the harbour/sea. This area should instead be a wildlife corridor rather than the site of industrial units.
S26 and S27 Concrete for housebuilding or industrial units or road building is at odds with the provisions for natural environment, and in dealing with floodplains. Any sea level rise or storm surge will make our natural environment more required as a buffer. Where is the provision for climate change? Unless we halt the use of fossil fuels and use more renewable energy there is no way out of this crisis. Building of houses and industry does not give us resilience to be able to cope with the future.
S28 Pollution. We already have three AQA zones, how about more robust measures to counter private cars running on diesel and petrol? Where are the Park and Ride schemes out of town? I don't see any areas designated for this?
S29 Green Infrastructure, the policies map showed no new green infrastructure, which is an opportunity missed.

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

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

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

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

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

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

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

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

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

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

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

Changes Insert
1 while protecting its biodiversity

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

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

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

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

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

Changes Insert
1 and ecosystem links

Justification
See above 5.36

Policy S24: Countryside
Paragraph comment
Outside settlement boundaries as defined on the policies map, development will be permitted in the countryside provided that:
1. It conserves and, where possible, enhances the key features and qualities of the rural and landscape character1 of the countryside setting; 

2.It is of an appropriate scale, siting and design that is unlikely to cause unacceptable harm to the appearance of the countryside;2 and 

Changes Insert
1 rural, landscape and ecosystem character of the countryside setting

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

Justification
See above 5.36 5.38 5.40

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

Changes Insert
1a range of demands that are often conflicting

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

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

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

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

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

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

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

Changes Insert
evaluate these conflicting1 demands

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

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

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

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

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

Delete and replace

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

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

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

S26
Paragraph object
Bullet point 4
Cons Considering the quality of the agricultural land, with the development of poorer quality agricultural land being preferred to the best and most versatile land. 

Delete and replace
Where loss of agricultural land may be thought necessary, this can only be granted when all other options have been fully explored and it has been comprehensively demonstrated that there is no alternative. The biodiversity value of all agricultural land must be considered.

Justification
Poorer quality agricultural land may have significant biodiversity value.

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

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

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

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

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

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

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

Policy DM28

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

Changes Replace
1 and biodiversity
2 only be considered

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

* The tranquil and rural character of the area.1

Changes Insert
* 1 The biodiversity of the area

Paragraph Comment
3. Development of poorer quality agricultural land has been fully considered in preference to best and most versatile land; 1 

Changes Insert
Poorer quality land will also be assessed for its biodiversity potential, and where this proves to be significant the land should be subject to the biodiversity protection measures.

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

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

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

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

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

Continued below in D 29

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

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

Changes Insert/Replace
1 required

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

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

Changes Insert/Replace
1 Only be considered

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

Changes Insert/Replace
1 will

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

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

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

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

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

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


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


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


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


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


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


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


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

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

Policy S17:
This policy appropriately highlights the environmental sensitivity of the location within the Chichester Harbour AONB and the proximity of the Chichester Harbour
SAC/SPA/Ramsar, however, there is no mention of the Core and Supporting Areas on the Thorney Island which are within the SWBGS.

As per the SWBG strategy, Core Areas are considered essential to the continued function of the Solent waders and brent goose ecological network and have the strongest functional-linkage to the designated Solent SPA in terms of their frequency and continuity of use by SPA features. We strongly urge that development proposals which are likely to affect these non-designated sites are referenced within the policy.

Policy S26
We welcome Policy S26 and support its intention to protect and enhance the natural
environment of the Plan Area. There is however is no specific reference to designations within the policy and or the supporting text (para 5.51).
The specific conservation designations relevant to the Chichester Local Plan in respect of both international and national designations should be detailed within the Local Plan.

The inclusion of site designations; SPAs, SACs, SSSIs etc. rather than 'biodiversity of the site'. We would also recommend the outcome of the net gain consultation to be referenced in Policy S26 and reflected in the regulations 19 draft

Policy AL6
The policy for this housing allocation appropriately highlights the need to provide
mitigation to ensure the protection of the adjacent SPA, SAC, SSSI and Ramsar at
Chichester Harbour. However, the land in this policy is across the road from site 'C23' in the Solent Brent Goose and Wader Strategy (SWBGS) and has been designated as a 'Candidate area'.

As per the SWBG strategy, development proposals which are likely to affect these sites will need to undertake survey work to confirm the site's classification prior to assessing off-setting and mitigation requirements. We urge that reference to this is made within the policy.

Policy AL8
We note that allocation AL8 is proposed to be delivered through a review of East
Wittering Neighbourhood Plan (NP), which will allocate sites to meet the housing figure. The District Council have therefore not identified any sites at this stage.
The lack of detail as to where these sites (or site) will be located raises concerns given the sensitivity of area and the potential of conflict with the legislation protecting the designated wildlife interests. This also raises questions around the deliverability of the Chichester Local Plan given this allocation is roughly 10% of the overall housing target and there is currently no indication of time frames of the NP review. It could also impact on the Council's ability to undertake a sound Habitats Regulations Assessment of the Local Plan.

If the Parish are to take a lead in identifying new development site(s), attention must be drawn to the details of the Solent Waders and Brent Goose Strategy and the Solent Recreation Mitigation Partnership to ensure suitable sites are identified that do not conflict with the designated site interests.

The RSPB would like clarification as to whether the sites identification process is expected to be competed in time for the submission of the Local Plan, and if not what measures are being taken to ensure that this approach will not affect the overall deliverability of the plan?

Policy AL9
We note that allocation AL9 is proposed to be delivered through a review of Fishbourne Neighbourhood Plan (NP), which will allocate sites to meet the housing figure. The District Council have therefore not identified any sites at this stage.
The lack of detail as to where these sites (or site) will be located raises concerns given the sensitivity of area and the potential of conflict with the legislation protecting the designated wildlife interests. This also raises questions around the deliverability of the Chichester Local Plan given this allocation is roughly 10% of the overall housing target and there is currently no indication of time frames of the NP review. It could also impact on the Council's ability to undertake a sound Habitats Regulations Assessment of the Local Plan.

If the Parish are to take a lead in identifying new development site(s), attention must be drawn to the details of the Solent Waders and Brent Goose Strategy and the Solent Recreation Mitigation Partnership to ensure suitable sites are identified that do not conflict with the designated site interests.

The RSPB would like clarification as to whether the sites identification process is expected to be completed in time for the submission of the Local Plan, and if not what measures are being taken to ensure that this approach will not affect the overall deliverability of the plan?

Policy AL12
The RSPB would like to express concern over the potential impact site allocations AL12 could have on brent geese. Since 2017 the Pagham Harbour reserves team and SOS have been working together, carrying out brent geese surveys around Pagham Harbour since 2017, with the aim to map out how wintering brent geese are using land off the designated sites and to distinguish if these sites are functionally linked to the SPA.

This site is close to the Pagham Harbour SPA (approximately 350m) and over the last 10 years Sussex Ornithological Society (SOS) have recorded over 900 records of birds at Park Farm and Church Norton Greenlease, of which include brent geese.
This area currently falls outside of the SWBGS and therefore would not be picked up by this strategy. Until we have a full understanding of what fields are used by brent geese we will oppose any development on fields potentially used by them for foraging.

Policy AL13
We note that allocation AL13 is proposed to be delivered through a review of Southbourne Neighbourhood Plan (NP), which will allocate sites to meet the housing figure. The District Council have therefore not identified any sites at this stage.
The lack of detail as to where these sites (or site) will be located raises concerns given the sensitivity of area and the potential of conflict with the legislation protecting the designated wildlife interests. This also raises questions around the deliverability of the Chichester Local Plan given this allocation is roughly 10% of the overall housing target and there is currently no indication of time frames of the NP review. It could also impact on the Council's ability to undertake a sound Habitats Regulations Assessment of the Local Plan.

If the Parish are to take a lead in identifying new development site(s), attention must be drawn to the details of the Solent Waders and Brent Goose Strategy and the Solent Recreation Mitigation Partnership to ensure suitable sites are identified that do not conflict with the designated site interests.

The RSPB would like clarification as to whether the sites identification process is expected to be completed in time for the submission of the Local Plan, and if not what measures are being taken to ensure that this approach will not affect the overall deliverability of the plan?

4.4.2 and Table 3 4.6.4 , 4.7.3 Sustainability Appraisal 010

This Sustainability Appraisal is full of highly subjective notions which leads its impact assessments to be generally questionable ie on whether an option has a positive or negative impact on eg biodiversity.
In para 4.4.2 who were the "further discussions" with to cause scenario 1a to be added ?
Para 4.6.4. in trying to justify the allocation of 1250 dwellings to Southbourne, it talks of the "potential advantages" but does not mention the obvious disadvantages in almost doubling the population of this village. What provisions will the plan make eg to ensure that the Southbourne railway station is capable of handling possibly a doubling of passenger traffic.? The answer is that it can't because investment in the railway network is outside it's jurisdiction. I would only support an option that shares any new housing more evenly between settlements which is more likely to limit the obvious damage that is going to be caused to natural habitats by this Local Plan review.

What improvements or changes would you suggest?

As above.

003 Housing and Econ Devt

This document appears to rely for it's conclusion of new housing numbers on the unbridled continuation of economic growth levels through the Plan period to 2035[par a 1.17].I believe that this is an unsustainable model on which to plan the future for our children and grandchildren.
There is no attempt that I can see to apply some sort of sensitivity analysis to the single end figure of 609 dwellings per annum so that lower numbers could be chosen as a preferred option. There are many factors which could influence housing numbers over the long Plan period so it would seem sensible to start with lower numbers to try and reduce the inevitable negative impact on natural habitats that any increase in human numbers will cause.

What improvements or changes would you suggest? As stated above

5.5 in particular Strategic Wildlife Corridors Background Paper

Whilst supporting the concept of Wildlife Corridors in the Plan [why was this not done 20 years ago ?] I do object to the removal from the Plan Review of the Chidham/East of Nutbourne Wildlife Corridor. If the Southbourne Neighbourhood Plan Review [SNPR] wishes to give more priority to natural habitats then it can devise policies which avoid "the close proximity of...proposed development" cited in paragraph 5.5.
Glossary - Wildlife Corridors are not defined in the Glossary and should be included.

What improvements or changes would you suggest? As stated above.

All but especially sub-areas 82 and 83 Landscape Capacity Study - 007

Apart from it being a useful inventory of landscape types in Chichester District, this document appears to me a rather pointless exercise in Planning fudge. For example on page 496 in is saying that development could be accommodated etc etc at the same time as avoiding any "landscape or visual harm " This sort of language is found all over this document and givers too many opportunities for misunderstanding or misinterpretation.
It would have been helpful to have page numbers for the sub-areas. As it is the location of sections is prolonged.

What improvements or changes would you suggest?

Avoid attempts to give facile conclusions and recommendations.

Paras 5 and 7 various Natural Environment

Para 5.51 [Strategic Policies] suggests the Council will only object to development that causes "significant harm" to the function of the natural environment but there is no definition of this phrase
7.168 Is stating that "providing open space, sport and recreation is part of "protecting and enhancing the natural environment" This is not true as these are all man-made features designed for humans, not for nature.
Para 7.189 and others mention "priority habitats" but I can see nowhere in the Plan Review that identifies the 21 types of these habitats mapped in Sussex* either by list or on a map of the District.These important habitats are often overlooked when development applications are made [eg ref 16/03569/OUT] and this Plan is a good opportunity to draw the public's attention to those in their area.
Para 7.189 refers to a Map 5.1 but gives no easy reference to where this can be found ?
Note: *Sussex Biodiversity Record Centre records these as "Habitats of Principal Importance" - which designation is correct ?
Glossary issues: Priority Habitats are missing and should be included in the Glossary in the Plan Review.

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.

See reps

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.

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

See attachment

Characteristics of the Plan Area: a spatial portrait
The term East-West Corridor used with in regard to west of the City of Chichester is ill defined and the use of this term 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 AONB and Chichester
Harbour AONB

Policy S2 Settlement Hierarchy
Object
Chidham & Hambrook, among the other Bourne villages, is characterised as a 'service village' with no definition or explanation of what this means. This term does not reflect the special and unique character of any of these areas, it designates them as no more than utilitarian dormitory communities.
"The largest level of growth is expected in the service villages and settlement hubs, able to accommodate higher levels of growth without adversely impacting the character of the settlement". An increase in growth of housing stock by 55% will undoubtedly negatively impact Chidham & Hambrook.

Policy S3 development Strategy
We believe the rationale for how the number of 500 dwellings for Chidham & Hambrook was arrived at to be wanting and the supplementary evidence to be inconsistent and contradictory. Figures in the 2018 HELAA report suggest that there is available land from achievable sites for 565 new dwellings. This is a completely unrealistic expectation. If these are assessed against the suggested CDC figure of 30- 35 per hectare and 80% developable this gives a total of 360 - 420. The figures seem to be almost entirely based on projections put forward by promoters. Consequently, we were told to put a call out for additional sites. Several of those that have come forward are on sites previously rejected by CDC on the grounds of impact on the AONB, significant access constraints, adverse impact on the landscape and detachment from the settlement boundary.
The Sustainability Appraisal sets out to select numbers in the Potential Distribution Strategies. Assuming a figure of 650 pa, across Chichester District, the predicted numbers for Chidham & Hambrook stay within a narrow range of 500-750, whereas other Parishes fluctuate widely eg Fishbourne 250-1000, Hunston 0-1000.Unlike other parishes, it did not consider a figure of less than 500 for Hambrook.
The Strategic Development Location Assessments seek to assess each district against sustainability criteria. Chidham & Hambrook has been scored with 11 negative and 7 neutral with only 12 positive.
We agree with your judgements with the following additions:
1a in addition to the bat population North of Priors Leaze Lane the Ham Brook is home to water voles.
4b This is a significant constraint. Without adequate public transport and no local facilities or services this will put considerable strain on both the A259 and A27 at both Emsworth and Fishbourne.
5a There is considerable risk of surface water flooding on a number of identified sites.
6a This should be a negative score. To speculate that Southern Rail might increase the service is no justification for assuming a shift to sustainable transport. The hourly service east and west is not adequate for commuters.
9 This should be a negative. There are no local shops apart from a very small and poorly stocked Post Office, which has erratic opening hours, and a charity shop. This doesn't constitute some shops. There are no medical facilities, sports facilities or recreation ground.
10a-12b There are extremely limited employment opportunities in Chidham & Hambrook so difficult to see how any of these would apply.
13a The Local Plan diminishes our rural economy by taking farmland and nurseries for development
13b We have high quality Grade 1 and Grade 2 agricultural land .
We believe these judgements demonstrate that Chidham & Hambrook is less suitable for large scale housing numbers than other areas.


Policy S12 Infrastructure Provision
Infrastructure Delivery Plan
This gives us no confidence that the development of 500 homes in Chidham & Hambrook will give us the infrastructure we need at the time it is required.
Despite the rapid growth in housing numbers over the last five years there has been little infrastructure development. We have no medical centre, local convenience store, employment opportunities, early years or child care provision ,sports or recreational facilities.
Transport: there is no mention of any upgrades to any of the roads or junctions serving the Parish to alleviate congestion and to improve safety. There is no mention of cycling routes and walking provision to provide safe routes. This will be exacerbated by the 1,110+ homes proposed in the Southbourne Parish which will have a coalescent impact on Chidham & Hambrook, particularly Priors Lease Lane and Broad Road.
Education: the suggestion here is that Chidham & Hambrook will be contributing funding to a new school in Southbourne rather than a replacement school in Policy AL10. This represents yet another contradiction. It is unclear where or at which development Early Years and Child Care places would be accommodated.
Health: The nearest provision would be Southbourne

Policy S8 Employment
Object
7.1 Part Two Development Management states " place housing in locations which are accessible by public transport to jobs, shopping, leisure, education and health facilities."
There are limited employment opportunities in Chidham & Hambrook and it appears there is no demand for commercial premises in the area. Industrial units built by Taylor Wimpey on the Lion Park development were not taken up and consequently converted to housing. In the last few years three employment opportunities have closed down to be replaced by housing - two garages which sold, serviced and repaired vehicles, one of which sold petrol and a small stock of essentials, and a plant nursery. This will put an added pressure on traffic as more people drive to their areas of employment west or east using the A259. Public transport is limited and expensive.





Policy S23 Transport /DM8
Object
In Chidham & Hambrook the vast majority (80%) of the proposed new dwellings would be built off Broad Road and some sited on the adjoining Main Road, the A259. There is no provision for the road infrastructure impact of 2250 new homes along this road between Southbourne and Fishbourne. And this will impact the travel survey.
Currently Broad Road has significant safety issues for pedestrians, drivers and cyclists. There is limited visibility due to lack of off-road parking facilities for current residents which has resulted in a number of near accidents. Where it meets the A 259 there is a staggered junction with Cot Lane which, even at present, is difficult to negotiate. The combination of new housing leading to increased traffic in Broad Road and the potential significant volume of increased traffic coming from the 1100+ new dwellings in Southbourne will make this junction dangerous and untenable.
To the North of the Parish there will be increased traffic on the Common Road to Funtington and then the B2178 as a route into the city. Opportunities for any access to housing developments without using Broad Road or Main Road are extremely limited. All other roads in the Parish are essentially lanes, mostly restricted to single lane traffic and could not be used as access to developments.
Pedestrian access in Broad Road is very poor with footways in places too narrow to accommodate buggies, wheel chairs or motorised disabled scooters. As a consequence residents are heavily reliant on cars.

The added volume of traffic will cause significant congestion and decreased air quality. Accessing the A27 at Fishbourne will be further exacerbated by the lack of plans to introduce an additional junction and slip roads onto the A27 between Emsworth and Fishbourne, and for no right turns from the Stockbridge and Whyke roundabouts. The only suggested mitigation is to create a hamburger junction. The increased commuter traffic combined with beach traffic in good weather, will cause gridlock at this roundabout at every junction.
We object to the proposal to build a link road to Birdham which would go straight through a flood plain and a site of environmental significance and would have a negative impact on the views from the coast to the City and SDNP.
Public transport is limited to one bus service along the A259 and an hourly train in either direction from Nutbourne station. The bus is very expensive and the vast majority of passengers are those with bus passes. There is no bus service south to north. The train frequency is too limited as a viable alternative to car travel. We would like to see a more robust policy focussing on public transport links.

We support the 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 and be coordinated with WSCC with the goal of introducing high quality and separated cycle links between the villages along the A259 and Chichester.

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 along the A259 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 potential traffic problems





Policy S6 Affordable Housing
Support
There is a disproportionate number of detached and 4 bed houses currently in our housing stock. We would like to see a commitment for Social Housing in addition to Affordable Housing, which many local people cannot afford to rent or buy. This means many young people leave the area. There is too much flexibility given to developers here in delivering the housing need for the area. They must deliver their "affordable" requirement if sufficient housing to meet local needs is to be provided.

Policy DM 2 Housing Mix
Support
As above we have a high number of 4+ bed and detached homes. Young, low income and single households are being priced out of their neighbourhoods.

Policy DM3 Housing Density
Support
Specialist housing and housing for the elderly will require a lower density as it will be single story. It is essential that there are robust measures that will enable high quality homes to be built to enable elderly people to remain in their community should they need to move into adapted housing more appropriate to their needs. Similarly, life long homes for those with a disability who need specialist housing.

Policy S26 / DM19 Natural Environment
Object
The Spatial Vision and Strategic Objectives 3.6 states that any development west of the city will
" conserve and enhance the local distinctiveness, character and cohesion of existing settlements".
The Sustainability Appraisal states, in relation to Chidham and Hambrook " The scale of the development will completely alter the existing development and there will be significant impact to the existing historic village" These two statements are contradictory .
The magnitude of an additional 500 homes {growth of 55%) will patently alter the local distinctiveness and character of Chidham & Hambrook and risk coalescence with Southbourne. The landscape is characterised by extensive arable land with some nurseries and pasture. Hedges, bushes, orchards and groups of trees contribute to the landscape, as do streams which pass through the Parish. The South Downs National Park is to the North and the AONB of Chichester Harbour to the South.
The CDC Landscape Capability Study reinforces the detrimental effect development will have on the landscape and character in all areas within the Parish
Nutbourne East - Ham Brook Mosaic
Potential development is said to impact on:
valued views, visual corridor for views from Nutbourne Channel towards the SDNP, separation of Southbourne, Hambrook, Nutbourne East, the rural landscape setting, existing pattern of low density settlement.
It will also contribute to the loss of:
Pasture, arable fields, hedgerows, trees, woodland (ancient and semi natural) copses. The area is constrained by its remaining rural character.
Nutbourne West-Nutbourne East Coastal Plain
Potential development will impact on:
valued views, characteristics views to the harbour and the SDNP, views from the AONB and nearby peninsulas: wider separation between Nutbourne West and Nutbourne East, the rural landscape setting,of the AONB, the existing pattern of low density settlement, the well treed landscape setting.
It will also contribute to the loss of:
Pasture, arable fields, hedgerows, trees, woodland copses, characteristic landscape field patterns. The area is constrained by its rural and treed character which contributes to the open setting and character of the AONB.
Upper Chidham Coastal Plain
Potential development will impact on:
Valued views- to the harbour, hills of the SDNP, Bosham Church, setting of Nutbourne Channel and Bosham Harbour, setting of listed buildings, strong rural and tranquil character, views from the SDNP.
Contribute to the loss of:
Arable and paddock fields, hedgerows, trees, tree belts, patches of coastal grassland and wetland, characteristic landscape field patterns.
The area is constrained by its rural and tranquil character, the visually sensitive open large scale fields, its contribution to the open, rural setting of the settlements of Chidham, Nutbourne East and West and their wider separation and its contribution to the wider AONB landscape, including the setting of Nutbourne Channel and Bosham.
Nutbourne East North - Eastern Coastal Plain
Potential development will impact on:
Valued views, rural character, separation between Hambrook and Nutbourne East, semi enclosed and more open character,
Contribute to the loss of: pasture and arable fields, hedgerows, trees, and characteristic field patterns
Nutbourne East Nurseries
Potential development will impact on:
Valued views, characteristic views to the Harbour and SDNP, rural character, separation between Bosham and Nutbourne East, semi enclosed and more open character, the pockets of orchards and small copses.
Contribute to the loss of: pasture and arable fields, hedgerows, trees, and characteristic field patterns

There are clearly significant constraints on the landscape and character if large scale development were to take place in Chidham & Hambrook. The principles in the AONB Management Plan must be rigorously applied to any new developments.

Policy S29, S30, DM 32 Wildlife Corridor
Support
We welcome a specific Policy on wild life corridors located between the SDNP, the Chidham peninsula and Chichester Harbour. The Chidham / East Nutbourne wild life corridor linking important Green Infrastructure, is of special sensitivity.
A variety of species commute or forage between the harbour area and the SDNP including mammals, both deer and bats, of which 10 or more species have been recorded. Badgers, while not normally found on the peninsula, have been seen. Smaller species like Hedgehogs, stoats, weasel, moles, and small prey species, including tawny and barn owls, grey heron and migrant species such as Fieldfare and Redwing use these corridors .
The Ham Brook follows a natural environmental course from the AONB to the SDNP. This natural water course is home to water voles (seen by CDC Wildlife Officer and local environmental volunteers as recently
as January 2019) and the land north of Priors Leaze Lane is a Barn Owl Habitat.There is ancient woodland either side of the railway line next to the trout farm and this is a dormouse habitat too. Development in this area should be constrained by proximity to the wildlife corridor identified by CDC.




AL10/SA10 Chidham & Hambrook
Object
In 2014 at the last iteration of the Neighbourhood Plan there were 850 households in the Parish of Chidham and Hambrook. By the time the new Local Plan is published there will have been an increase in the number of properties in the region of 150 to a total of 1003 in the Parish, an 18% increase. The previous Local Plan had set a target increase of 25 houses. Whilst absorbing this number of properties there have been no changes to the infrastructure and services in the area to support the additional population apart from a charity shop and expansion of the Primary School which is now at capacity and has been for the last year. The new Local Plan requires us to accept a further minimum of 500 properties. This will increase our local housing stock by 50% and will undoubtedly increase the population area by a greater percentage given the age demographic of the area.
6.68 states that" opportunities to relocate and expand the school to two form entry will be sought.". We note that there are similar plans for a relocated and expanded school in Bosham with a site allocated for that purpose, in addition to a new school in Southbourne. Discussions with WSCC have made it clear they would not support the creation of two new schools in such close proximity. It is therefore nonsensical to suggest these two schools could be realised. WSCC data does not support it. Their calculations for schools are based on 210 Primary children for 1000 homes so patently 750 homes would not meet support for two 2 form entry schools. However, the current school is at capacity and cannot on its current site be expanded. If a school project is not forwarded in Chidham & Hambrook the additional children coming from 500 homes would need to travel to Bosham or Southbourne to attend school, along with children from 1100+ homes proposed in Southbourne. There needs to be some clarity and certainty on which of these proposed schools can be achieved and how they would be funded. We find it extraordinary that there is no policy statement on Education.


The Parish Council fully acknowledges that it has a responsibility to contribute to the need for more new housing in the District. However, in view of the above, and having carefully scrutinised the evidence, we believe that 500 homes for Chidham & Hambrook is excessive and is not supported by the documentation. The low provision of amenities, the absence of planned sustainable transport, the proximity of the AONB, the sensitive nature of the landscape and the density of housing proposed, limits the development capacity of the land.
For the reasons given we would like this number significantly reduced by at least 50% in line with Bosham and Fishbourne.

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.

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