Chichester Local Plan 2021 - 2039: Proposed Submission
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Chichester Local Plan 2021 - 2039: Proposed Submission
Policy H11 Meeting Gypsies, Travellers and Travelling Showpeoples' Needs
Representation ID: 5296
Received: 16/03/2023
Respondent: National Highways
Legally compliant? Not specified
Sound? Not specified
Duty to co-operate? Not specified
[National Highways letter dated 24/07/23 confirmed representation should be categorised as Comment - Seeking to understand further e.g., digital nomads.] This policy does not acknowledge or address Motor Homes, Caravans, Vans, converted Buses, Tiny Homes, or other forms of mobile housing in response to the housing crisis and low rental vacancy rates. Nor does this policy address the rise in nomadic and digital-nomad lifestyles. Both have the potential to generated large numbers of additional vehicle movements on the SRN and to create new impacts, for example van dwellers sleeping in road lay-bys.
We have reviewed the publicly available Local Plan documents and provided comments in the attached letter, in relation to the transport implications of the plan for the safety and operation of the SRN.
Our comments include issues to resolve, comments, requests for further information and recommendations. A brief summary of our main comments are:
- the reliance on the delivery of the A27 Chichester bypass improvements project.
- the requirements for new, additional, and adapted processes and assessments, especially in assessing Transport Assessments, mandating Travel Plans and monitoring traffic associated with new developments.
- collaborative working between agencies in combination with a robust monitor and manage policy.
We hope our comments assist.
To date National Highways have worked collaboratively with Chichester District Council (the Council) and West Sussex County Council (WSCC) and we will continue to work with the Council and other key stakeholders. We look forward to continuing to participate in future consultations and discussions.
Once you have had the opportunity to digest all the representations received, we would welcome a meeting to run through all the transport related matters and agree how to progress any required evidence gathering or other work.
Background
National Highways has been appointed by the Secretary of State for Transport as strategic highway company under the provisions of the Infrastructure Act 2015 and is the highway authority, traffic authority and street authority for the strategic road network (SRN).
National Highways is responsible for operating, maintaining, and improving the Strategic Road Network (SRN) i.e., the Trunk Road and Motorway Network in England, as laid down in Department for Transport (DfT) Circular 01/2022 (Strategic Road Network and the delivery of sustainable development).
The SRN is a critical national asset and as such we work to ensure that it operates and is managed in the public interest, both in respect of current activities and needs as well as in providing effective stewardship of its long-term operation and integrity.
Our responses to Local Plan consultations are guided by relevant policy and guidance including the National Planning Policy Framework (2021) (NPPF):
• Transport issues should be considered from the earliest stages of plan-making and development proposals so that the potential impact of development on transport networks can be addressed (para 104).
• The planning system should actively manage patterns of growth such that significant development is focused on locations which are or can be made sustainable, through limiting the need to travel and offering a genuine choice of transport modes. (para 105).
• Planning policies should be prepared with the active involvement of highways authorities and other transport infrastructure providers so that strategies and investments for supporting sustainable transport and development patterns are aligned. (para 106).
• In terms of identifying the necessity of transport infrastructure, NPPF confirms that development should only be prevented or refused on highways grounds if there would be an unacceptable impact on highway safety, or the residual cumulative impacts on the road network would be severe. (para 111).
• Planning policies and decisions should support development that makes efficient use of land, taking into account the availability and capacity of infrastructure and services – both existing and proposed – as well as their potential for further improvement and the scope to promote sustainable travel modes that limit future car use. (para 124).
In relation to the tests of soundness set out at paragraph 35 of the NPPF, in the context of transport, these are interpreted as meaning:
a) Positively prepared - has the transport strategy been prepared with the active involvement of the highway authorities, other transport infrastructure providers and operators and neighbouring councils?
b) Justified – Is the transport strategy based on a robust evidence base prepared with the agreement in partnership, or with the support of the highway authorities?
c) Effective – Does the transport strategy and policy satisfy the transport needs of the plan and is it deliverable at a pace which provides for and accommodates the proposed progress and implementation of the plan?
d) Consistent with national policy – Does the transport strategy support the economic, social, and environmental objectives of the Plan and the NPPF/NPPG?
We will be concerned with proposals that have the potential to impact on the safe and efficient operation of the SRN; in this case, the A27 trunk road (Chichester Bypass and its junctions) which is the main access route in the Chichester area. We have particular interest in any allocation, policy or proposals which could have implications for the A27 and the wider SRN network. We are interested as to whether there would be any adverse road safety or operational implications for the SRN. The latter would include a material increase in queueing or delay or reduction in journey time reliability during the construction or operation of the development set out in the plan.
National Highways is a key delivery partner for sustainable development promoted through the plan-led system, and as a statutory consultee we have a duty to cooperate with local authorities to support the preparation and implementation of development plan documents.
In accordance with national planning and transport policy and our operating licence, we are entirely neutral on the principle of development as it is for the local planning authority to determine whether development should be allocated or permitted; albeit it must comply with national policy on locating development in locations that are or can be made sustainable. Therefore, while always seeking early and fulsome engagement with local plans and/or developers, we will simply be assessing the transport and related implications of plans or proposals and agreeing any necessary transport improvements and relevant development management policy.
In progressing Local Plans, we will seek to agree the following:
• Assessment tools and methodology
• Baseline Assessment i.e., to demonstrate that the assessment tool accurately reflects current transport conditions
• Comparator case assessment i.e., to forecast the transport conditions that would occur in the absence of the plan
• Forecast modelling i.e., to forecast the transport conditions that would arise with the plan in place, this will include an assessment at the end of the Plan period; and, if required, at full build out if that occurs after the end of the Plan period
• Outputs and outcomes of modelling, demonstrating, as appropriate, what transport infrastructure is necessary to support the plan o It should be noted that a suite of transport modelling tools may be required. This includes strategic modelling covering an area at least one major junction beyond the district boundary, localised network modelling where several links/junctions are close together and/or individual junction modelling
o A DMRB (Design Manual for Roads and Bridges) compliancy assessment may also be required for certain highway features, such as
Merge/Diverge assessment at Grade separated junctions, link capacity assessments, and others.
• The design of any necessary transport infrastructure, to an extent suitable for establishing deliverability during the plan period at the time that it becomes necessary for the purpose of ensuring that unacceptable road safety impacts or severe operational impacts do not arise as a result of development. This may be to at least General Arrangement design stage or preliminary design stage. Whichever degree of detail is agreed, the products must be in full compliance with the DMRB.
• Industry standard transport intervention costings.
• The delivery/funding mechanisms for necessary transport interventions. It should not be assumed that National Highways will have any responsibility to identify or deliver necessary transport interventions.
• If considered appropriate, a “Monitor & Manage” (M&M) framework, aimed at managing the pace of development in line with the pace of funding and delivery of necessary highway interventions in a manner which responds to the realworld impacts of development may be agreed for inclusion in the plan subject to the adequacy of risk control measures included therein. This can include the move from a ‘predict & provide’ style of delivery to ‘a vision & validate’ style. o Any M&M framework must be based on a “worst case scenario” whereby necessary mitigation is understood, as well as setting out the desired alternative scenario. It must set out details of responsibility, funding and governance of the framework together with the methodology for determining the timing for any mitigation delivery while remaining clear on the fallback position where identified mitigation or desired alternatives are not ultimately achievable. It must be translated into development management plan policy and policy relating to development allocations.
Further detail on the above can be provided by National Highways.
While ideally all the above should be agreed prior to the Submission of the Local Plan for examination, we recognise that this is not always possible. However, all parties should work towards all matters being agreed and reflected in a Statement of Common Ground (SoCG) by the start of the Local Plan Examination at the latest. Ideally the SoCG between the Council and National Highways would be prepared well in advance of plan submission in order to guide resource input and to track progress towards final agreement on all relevant matters starting from the earliest plan iterations until the final version is agreed.
It is acknowledged that Government policy places much emphasis on housing delivery as a means for ensuring economic growth and addressing the current national shortage of housing. The NPPF is very clear that:
“Strategic policy-making authorities should establish a housing requirement figure for their whole area, which shows the extent to which their identified housing need (and any needs that cannot be met within neighbouring areas) can be met over the plan period.”
However, new DfT C1/22 and the NPPF are equally clear that any development, including housing delivery, must be tempered by the requirement to ensure that the associated transport demand can be accommodated without unacceptable impacts on the safety of the SRN or severe impacts on the operation of the SRN including reliability and congestion. Therefore, as necessary and appropriate, any plan and/or development must be accompanied by suitable mitigation in the right places at the right time, that is to the required design standards and is deliverable in terms of land availability, constructability and funding.
We would also draw your attention to the then Highways England document ‘The Strategic Road Network, Planning for the Future: A guide to working with National
Highways on planning matters’ (September 2015). This document sets out how National Highways intends to work with local planning authorities and developers to support the preparation of sound documents which enable the delivery of sustainable development. https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachmen t_data/file/461023/N150227_-_Highways_England_Planning_Document_FINAL-lo.pdf
Responses to Local Plan consultations are also guided by National Planning Policy Framework (NPPF) revised on 20 July 2021 which sets out the government’s planning policies for England and how these are expected to be applied.
Updated Circular (01/2022)
It should be noted that since the start of the Local Plan consultation process, on the 23 December 2022, the Department for Transport released a new circular on the ‘Strategic road network and the delivery of sustainable development’ (Circular 01/2022), which replaces all of the policies in Circular 02/2013 of the same name. These representations take account of the new circular and the requirements in terms of the Local Plan evidence base and process.
We request that the Local Plan is prepared in line with all aspects of the new circular. Particularly, the principles of sustainable development (paragraphs 11 to 17), new connections and capacity enhancements (paragraphs 18 to 25), and engagement with plan-making (paragraphs 26 to 38).
Regulation 18 submission
In our Regulation 18 submission we noted several matters including:
• The need to mitigate the adverse impacts of strategic development traffic to the A27 Chichester Bypass and its junctions at Portfield Roundabout, Bognor Road Roundabout, Whyke Roundabout, Stockbridge Roundabout and Fishbourne Roundabout and Oving junction.
• The need to identify a mechanism to calculate contributions towards the delivery of the previously agreed Local Plan A27 improvements
• The need to confirm the number of dwellings needed within the plan period
• The need to establish National Highways acceptance of the traffic model reference and future case scenarios
• The need to confirm costs, viability, and funding associated with mitigating the safety and congestion impacts of the development included within the plan.
Local Plan context
This Local Plan (Chichester Local Plan 2021 – 2039), prepared by the Local Planning Authority (LPA) Chichester District Council, sets out the vision for future development in the district and will be used to help decide on planning applications and other planning related decisions including shaping infrastructure investments.
The draft sets out how the district should be developed over the next 18-years to 2039 including for the full Plan period (1 April 2021 to 31 March 2039) the total supply of
- 10,359 dwellings
- 114,652 net additional sqm new floorspace
Minus the completions this is equivalent to around 530 dwellings and 6,150 sqm of floorspace a year.
National Highways Representations
To date National Highways have worked collaboratively with Chichester District Council (the Council) and West Sussex County Council (WSCC) and we will continue to work with the Council and other key stakeholders.
We have undertaken a review of the Chichester Local Plan 2021-2039 proposed submission version and accompanying evidence documents, our comments are set out in the tables below (following pages). [see table within attachment]
Summary
We have reviewed the publicly available Local Plan documents and provided comments above in relation to the transport implications of the plan for the safety and operation of the SRN. We understand that other technical information is available, but this was not presented as part of this consultation.
Chichester, and the A27, are already heavily congested, infrastructure in the existing Local Plan remains undelivered and the growth set out in the new Plan will further increase travel demand.
As presented, satisfying the transport needs of the plan is clearly reliant on the delivery of the A27 Chichester bypass improvements project. The A27 Chichester bypass improvements project is one of 32 pipeline schemes being considered for possible inclusion in National Highways third Road Investment Strategy (RIS3) covering 1 April 2025 to 31 March 2030.
On 9 March 2023 the UK Transport Secretary ensured record funding would be invested in the country’s transport network, sustainably driving growth across the country while managing the pressures of inflation. The announcement cited the A27 Arundel Bypass as being deferred from RIS2 to RIS 3 (covering 2025-2030). The transport secretary also identified a number of challenges to the delivery of the road investment strategy and cited the benefit of allowing extra time to ensure schemes are better planned and efficient schemes can be deployed more effectively.
At present, there is no commitment by DfT to carry out the A27 Chichester bypass improvements project. Until the A27 Chichester bypass improvements project is published in the RIS3, consented and a decision to invest is made it cannot be assumed to be a committed project.
We note that the Plan does not address any uncertainty of delivery of the A27 Chichester bypass improvements project and we strongly recommend that there is either no reliance placed on RIS3 to realise capacity for growth in the Plan or that contingency measures are included to cover the eventuality that RIS3 funding is not forthcoming within the plan period. It is not clear that the potential impact of development on transport networks can be addressed in the absence of the A27 Chichester bypass improvements project.
Achieving net zero, reducing emissions reduction, acting on climate, and supporting thousands of new homes and new employment developments will be problematic with existing processes. New, additional, and adapted processes and assessments will likely be required, especially in assessing Transport Assessments, mandating Travel Plans and monitoring traffic associated with new developments. We acknowledge that change is complex, expensive, and time-consuming, especially for smaller district level Councils. But the hard work will deliver benefits for the Council and residents in the longer-term.
National Highways seeks to continue working with the Council and WSCC to progress coordinated and deliverable packages of interim mitigation measures and alternative transport solutions while a long-term strategic solution is considered by government. This must however be in combination with a robust monitor and manage policy that appropriately manages the risk of unacceptable road impacts resulting from new housing
and other development over the Plan period.
We have been in discussion with Chichester District Council regarding their proposed Monitor and Manage Strategy. At present, we do not consider the current strategy to be robust and we seek further information and detail especially on who, when and when monitoring and management will be undertaken. Developments in the right places and served by the right sustainable infrastructure delivered alongside or ahead of occupancy must be a key consideration when planning for growth in all local authority areas. Any M&M framework must be based on a “worst case scenario” whereby necessary transport mitigation is understood, as well as setting out the desired alternative scenario. It must set out details of responsibility, funding and governance of the framework together with the methodology for determining the timing for any mitigation delivery while remaining clear on the fallback position where identified mitigation or desired alternatives are not ultimately achievable. The M&M framework must set out that the alternative to mitigation not being delivered is that development does not proceed where that development would give rise to unacceptable road safety risk or severe cumulative impacts on the road network in the absence of that mitigation. The M&M framework must be translated into development management plan policy and policy relating to development allocations.
As we have reiterated throughout our comments, we welcome the opportunity to work with you to address these outstanding matters and we will continue to liaise over submitted Transport Assessment, Travel Plan policy and Monitor and Manage Policy to help to work towards a viable plan.
We hope our comments assist.
We look forward to continuing to participate in future consultations and discussions. Please do continue to consult us as the Plan progresses so that we can remain aware of, and comment as required on, its contents.
Once you have had the opportunity to digest all the representations received, we would welcome a meeting to run through all the transport related matters and agree how to progress any required evidence gathering or other work.
Attachments:
- Written representation (356.49 KB)
The policy is focused on the accommodation needs of gypsies and travellers as people, rather than on particular forms of mobile accommodation per se.
The wider needs of those living in caravans and houseboats is a legal requirement and the Council will be addressing this in an additional evidence base document, which will be available at the Examination.
In terms of the impact of nomadic and digital nomad lifestyles, National Highways have not presented any evidence that such lifestyles are associated with the Chichester plan area or are having a significant impact on the strategic highways network and therefore it is difficult for the Council to address this issue.
Support
Chichester Local Plan 2021 - 2039: Proposed Submission
6.3
Representation ID: 5297
Received: 16/03/2023
Respondent: National Highways
[National Highways letter dated 24/07/23 confirmed representation should be categorised as Comment - Supporting collaborative working.] Achieving good design, particularly for larger scale proposals, requires early engagement with relevant statutory bodies (para 6.3).
We welcome the opportunity be invited to be involved in the pre-application scoping stage and to review Sustainability Statements to reduce impacts associated with traffic.
We have reviewed the publicly available Local Plan documents and provided comments in the attached letter, in relation to the transport implications of the plan for the safety and operation of the SRN.
Our comments include issues to resolve, comments, requests for further information and recommendations. A brief summary of our main comments are:
- the reliance on the delivery of the A27 Chichester bypass improvements project.
- the requirements for new, additional, and adapted processes and assessments, especially in assessing Transport Assessments, mandating Travel Plans and monitoring traffic associated with new developments.
- collaborative working between agencies in combination with a robust monitor and manage policy.
We hope our comments assist.
To date National Highways have worked collaboratively with Chichester District Council (the Council) and West Sussex County Council (WSCC) and we will continue to work with the Council and other key stakeholders. We look forward to continuing to participate in future consultations and discussions.
Once you have had the opportunity to digest all the representations received, we would welcome a meeting to run through all the transport related matters and agree how to progress any required evidence gathering or other work.
Background
National Highways has been appointed by the Secretary of State for Transport as strategic highway company under the provisions of the Infrastructure Act 2015 and is the highway authority, traffic authority and street authority for the strategic road network (SRN).
National Highways is responsible for operating, maintaining, and improving the Strategic Road Network (SRN) i.e., the Trunk Road and Motorway Network in England, as laid down in Department for Transport (DfT) Circular 01/2022 (Strategic Road Network and the delivery of sustainable development).
The SRN is a critical national asset and as such we work to ensure that it operates and is managed in the public interest, both in respect of current activities and needs as well as in providing effective stewardship of its long-term operation and integrity.
Our responses to Local Plan consultations are guided by relevant policy and guidance including the National Planning Policy Framework (2021) (NPPF):
• Transport issues should be considered from the earliest stages of plan-making and development proposals so that the potential impact of development on transport networks can be addressed (para 104).
• The planning system should actively manage patterns of growth such that significant development is focused on locations which are or can be made sustainable, through limiting the need to travel and offering a genuine choice of transport modes. (para 105).
• Planning policies should be prepared with the active involvement of highways authorities and other transport infrastructure providers so that strategies and investments for supporting sustainable transport and development patterns are aligned. (para 106).
• In terms of identifying the necessity of transport infrastructure, NPPF confirms that development should only be prevented or refused on highways grounds if there would be an unacceptable impact on highway safety, or the residual cumulative impacts on the road network would be severe. (para 111).
• Planning policies and decisions should support development that makes efficient use of land, taking into account the availability and capacity of infrastructure and services – both existing and proposed – as well as their potential for further improvement and the scope to promote sustainable travel modes that limit future car use. (para 124).
In relation to the tests of soundness set out at paragraph 35 of the NPPF, in the context of transport, these are interpreted as meaning:
a) Positively prepared - has the transport strategy been prepared with the active involvement of the highway authorities, other transport infrastructure providers and operators and neighbouring councils?
b) Justified – Is the transport strategy based on a robust evidence base prepared with the agreement in partnership, or with the support of the highway authorities?
c) Effective – Does the transport strategy and policy satisfy the transport needs of the plan and is it deliverable at a pace which provides for and accommodates the proposed progress and implementation of the plan?
d) Consistent with national policy – Does the transport strategy support the economic, social, and environmental objectives of the Plan and the NPPF/NPPG?
We will be concerned with proposals that have the potential to impact on the safe and efficient operation of the SRN; in this case, the A27 trunk road (Chichester Bypass and its junctions) which is the main access route in the Chichester area. We have particular interest in any allocation, policy or proposals which could have implications for the A27 and the wider SRN network. We are interested as to whether there would be any adverse road safety or operational implications for the SRN. The latter would include a material increase in queueing or delay or reduction in journey time reliability during the construction or operation of the development set out in the plan.
National Highways is a key delivery partner for sustainable development promoted through the plan-led system, and as a statutory consultee we have a duty to cooperate with local authorities to support the preparation and implementation of development plan documents.
In accordance with national planning and transport policy and our operating licence, we are entirely neutral on the principle of development as it is for the local planning authority to determine whether development should be allocated or permitted; albeit it must comply with national policy on locating development in locations that are or can be made sustainable. Therefore, while always seeking early and fulsome engagement with local plans and/or developers, we will simply be assessing the transport and related implications of plans or proposals and agreeing any necessary transport improvements and relevant development management policy.
In progressing Local Plans, we will seek to agree the following:
• Assessment tools and methodology
• Baseline Assessment i.e., to demonstrate that the assessment tool accurately reflects current transport conditions
• Comparator case assessment i.e., to forecast the transport conditions that would occur in the absence of the plan
• Forecast modelling i.e., to forecast the transport conditions that would arise with the plan in place, this will include an assessment at the end of the Plan period; and, if required, at full build out if that occurs after the end of the Plan period
• Outputs and outcomes of modelling, demonstrating, as appropriate, what transport infrastructure is necessary to support the plan o It should be noted that a suite of transport modelling tools may be required. This includes strategic modelling covering an area at least one major junction beyond the district boundary, localised network modelling where several links/junctions are close together and/or individual junction modelling
o A DMRB (Design Manual for Roads and Bridges) compliancy assessment may also be required for certain highway features, such as
Merge/Diverge assessment at Grade separated junctions, link capacity assessments, and others.
• The design of any necessary transport infrastructure, to an extent suitable for establishing deliverability during the plan period at the time that it becomes necessary for the purpose of ensuring that unacceptable road safety impacts or severe operational impacts do not arise as a result of development. This may be to at least General Arrangement design stage or preliminary design stage. Whichever degree of detail is agreed, the products must be in full compliance with the DMRB.
• Industry standard transport intervention costings.
• The delivery/funding mechanisms for necessary transport interventions. It should not be assumed that National Highways will have any responsibility to identify or deliver necessary transport interventions.
• If considered appropriate, a “Monitor & Manage” (M&M) framework, aimed at managing the pace of development in line with the pace of funding and delivery of necessary highway interventions in a manner which responds to the realworld impacts of development may be agreed for inclusion in the plan subject to the adequacy of risk control measures included therein. This can include the move from a ‘predict & provide’ style of delivery to ‘a vision & validate’ style. o Any M&M framework must be based on a “worst case scenario” whereby necessary mitigation is understood, as well as setting out the desired alternative scenario. It must set out details of responsibility, funding and governance of the framework together with the methodology for determining the timing for any mitigation delivery while remaining clear on the fallback position where identified mitigation or desired alternatives are not ultimately achievable. It must be translated into development management plan policy and policy relating to development allocations.
Further detail on the above can be provided by National Highways.
While ideally all the above should be agreed prior to the Submission of the Local Plan for examination, we recognise that this is not always possible. However, all parties should work towards all matters being agreed and reflected in a Statement of Common Ground (SoCG) by the start of the Local Plan Examination at the latest. Ideally the SoCG between the Council and National Highways would be prepared well in advance of plan submission in order to guide resource input and to track progress towards final agreement on all relevant matters starting from the earliest plan iterations until the final version is agreed.
It is acknowledged that Government policy places much emphasis on housing delivery as a means for ensuring economic growth and addressing the current national shortage of housing. The NPPF is very clear that:
“Strategic policy-making authorities should establish a housing requirement figure for their whole area, which shows the extent to which their identified housing need (and any needs that cannot be met within neighbouring areas) can be met over the plan period.”
However, new DfT C1/22 and the NPPF are equally clear that any development, including housing delivery, must be tempered by the requirement to ensure that the associated transport demand can be accommodated without unacceptable impacts on the safety of the SRN or severe impacts on the operation of the SRN including reliability and congestion. Therefore, as necessary and appropriate, any plan and/or development must be accompanied by suitable mitigation in the right places at the right time, that is to the required design standards and is deliverable in terms of land availability, constructability and funding.
We would also draw your attention to the then Highways England document ‘The Strategic Road Network, Planning for the Future: A guide to working with National
Highways on planning matters’ (September 2015). This document sets out how National Highways intends to work with local planning authorities and developers to support the preparation of sound documents which enable the delivery of sustainable development. https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachmen t_data/file/461023/N150227_-_Highways_England_Planning_Document_FINAL-lo.pdf
Responses to Local Plan consultations are also guided by National Planning Policy Framework (NPPF) revised on 20 July 2021 which sets out the government’s planning policies for England and how these are expected to be applied.
Updated Circular (01/2022)
It should be noted that since the start of the Local Plan consultation process, on the 23 December 2022, the Department for Transport released a new circular on the ‘Strategic road network and the delivery of sustainable development’ (Circular 01/2022), which replaces all of the policies in Circular 02/2013 of the same name. These representations take account of the new circular and the requirements in terms of the Local Plan evidence base and process.
We request that the Local Plan is prepared in line with all aspects of the new circular. Particularly, the principles of sustainable development (paragraphs 11 to 17), new connections and capacity enhancements (paragraphs 18 to 25), and engagement with plan-making (paragraphs 26 to 38).
Regulation 18 submission
In our Regulation 18 submission we noted several matters including:
• The need to mitigate the adverse impacts of strategic development traffic to the A27 Chichester Bypass and its junctions at Portfield Roundabout, Bognor Road Roundabout, Whyke Roundabout, Stockbridge Roundabout and Fishbourne Roundabout and Oving junction.
• The need to identify a mechanism to calculate contributions towards the delivery of the previously agreed Local Plan A27 improvements
• The need to confirm the number of dwellings needed within the plan period
• The need to establish National Highways acceptance of the traffic model reference and future case scenarios
• The need to confirm costs, viability, and funding associated with mitigating the safety and congestion impacts of the development included within the plan.
Local Plan context
This Local Plan (Chichester Local Plan 2021 – 2039), prepared by the Local Planning Authority (LPA) Chichester District Council, sets out the vision for future development in the district and will be used to help decide on planning applications and other planning related decisions including shaping infrastructure investments.
The draft sets out how the district should be developed over the next 18-years to 2039 including for the full Plan period (1 April 2021 to 31 March 2039) the total supply of
- 10,359 dwellings
- 114,652 net additional sqm new floorspace
Minus the completions this is equivalent to around 530 dwellings and 6,150 sqm of floorspace a year.
National Highways Representations
To date National Highways have worked collaboratively with Chichester District Council (the Council) and West Sussex County Council (WSCC) and we will continue to work with the Council and other key stakeholders.
We have undertaken a review of the Chichester Local Plan 2021-2039 proposed submission version and accompanying evidence documents, our comments are set out in the tables below (following pages). [see table within attachment]
Summary
We have reviewed the publicly available Local Plan documents and provided comments above in relation to the transport implications of the plan for the safety and operation of the SRN. We understand that other technical information is available, but this was not presented as part of this consultation.
Chichester, and the A27, are already heavily congested, infrastructure in the existing Local Plan remains undelivered and the growth set out in the new Plan will further increase travel demand.
As presented, satisfying the transport needs of the plan is clearly reliant on the delivery of the A27 Chichester bypass improvements project. The A27 Chichester bypass improvements project is one of 32 pipeline schemes being considered for possible inclusion in National Highways third Road Investment Strategy (RIS3) covering 1 April 2025 to 31 March 2030.
On 9 March 2023 the UK Transport Secretary ensured record funding would be invested in the country’s transport network, sustainably driving growth across the country while managing the pressures of inflation. The announcement cited the A27 Arundel Bypass as being deferred from RIS2 to RIS 3 (covering 2025-2030). The transport secretary also identified a number of challenges to the delivery of the road investment strategy and cited the benefit of allowing extra time to ensure schemes are better planned and efficient schemes can be deployed more effectively.
At present, there is no commitment by DfT to carry out the A27 Chichester bypass improvements project. Until the A27 Chichester bypass improvements project is published in the RIS3, consented and a decision to invest is made it cannot be assumed to be a committed project.
We note that the Plan does not address any uncertainty of delivery of the A27 Chichester bypass improvements project and we strongly recommend that there is either no reliance placed on RIS3 to realise capacity for growth in the Plan or that contingency measures are included to cover the eventuality that RIS3 funding is not forthcoming within the plan period. It is not clear that the potential impact of development on transport networks can be addressed in the absence of the A27 Chichester bypass improvements project.
Achieving net zero, reducing emissions reduction, acting on climate, and supporting thousands of new homes and new employment developments will be problematic with existing processes. New, additional, and adapted processes and assessments will likely be required, especially in assessing Transport Assessments, mandating Travel Plans and monitoring traffic associated with new developments. We acknowledge that change is complex, expensive, and time-consuming, especially for smaller district level Councils. But the hard work will deliver benefits for the Council and residents in the longer-term.
National Highways seeks to continue working with the Council and WSCC to progress coordinated and deliverable packages of interim mitigation measures and alternative transport solutions while a long-term strategic solution is considered by government. This must however be in combination with a robust monitor and manage policy that appropriately manages the risk of unacceptable road impacts resulting from new housing
and other development over the Plan period.
We have been in discussion with Chichester District Council regarding their proposed Monitor and Manage Strategy. At present, we do not consider the current strategy to be robust and we seek further information and detail especially on who, when and when monitoring and management will be undertaken. Developments in the right places and served by the right sustainable infrastructure delivered alongside or ahead of occupancy must be a key consideration when planning for growth in all local authority areas. Any M&M framework must be based on a “worst case scenario” whereby necessary transport mitigation is understood, as well as setting out the desired alternative scenario. It must set out details of responsibility, funding and governance of the framework together with the methodology for determining the timing for any mitigation delivery while remaining clear on the fallback position where identified mitigation or desired alternatives are not ultimately achievable. The M&M framework must set out that the alternative to mitigation not being delivered is that development does not proceed where that development would give rise to unacceptable road safety risk or severe cumulative impacts on the road network in the absence of that mitigation. The M&M framework must be translated into development management plan policy and policy relating to development allocations.
As we have reiterated throughout our comments, we welcome the opportunity to work with you to address these outstanding matters and we will continue to liaise over submitted Transport Assessment, Travel Plan policy and Monitor and Manage Policy to help to work towards a viable plan.
We hope our comments assist.
We look forward to continuing to participate in future consultations and discussions. Please do continue to consult us as the Plan progresses so that we can remain aware of, and comment as required on, its contents.
Once you have had the opportunity to digest all the representations received, we would welcome a meeting to run through all the transport related matters and agree how to progress any required evidence gathering or other work.
Attachments:
- Written representation (356.49 KB)
Support and comments noted
Object
Chichester Local Plan 2021 - 2039: Proposed Submission
Policy P1 Design Principles
Representation ID: 5298
Received: 16/03/2023
Respondent: National Highways
Legally compliant? Not specified
Sound? Not specified
Duty to co-operate? Not specified
[National Highways letter dated 24/07/23 confirmed representation should be categorised as Comment - Noting SRN policies and NH processes.] Policy 6 does not cover signage. No reference is currently made to the SRN or National Highways.
It is a requirement of the local planning authority to consult National Highways on the road safety aspects of advertisements proposed alongside the SRN, for example development advertisements.
Advertisements that are likely to distract motorists are unlikely to be approved. Ordinarily we will need to consider location, if visible from the SRN, size, brightness/lighting (if any) and effect on public safety as well as the type of intended advertising.
We have reviewed the publicly available Local Plan documents and provided comments in the attached letter, in relation to the transport implications of the plan for the safety and operation of the SRN.
Our comments include issues to resolve, comments, requests for further information and recommendations. A brief summary of our main comments are:
- the reliance on the delivery of the A27 Chichester bypass improvements project.
- the requirements for new, additional, and adapted processes and assessments, especially in assessing Transport Assessments, mandating Travel Plans and monitoring traffic associated with new developments.
- collaborative working between agencies in combination with a robust monitor and manage policy.
We hope our comments assist.
To date National Highways have worked collaboratively with Chichester District Council (the Council) and West Sussex County Council (WSCC) and we will continue to work with the Council and other key stakeholders. We look forward to continuing to participate in future consultations and discussions.
Once you have had the opportunity to digest all the representations received, we would welcome a meeting to run through all the transport related matters and agree how to progress any required evidence gathering or other work.
Background
National Highways has been appointed by the Secretary of State for Transport as strategic highway company under the provisions of the Infrastructure Act 2015 and is the highway authority, traffic authority and street authority for the strategic road network (SRN).
National Highways is responsible for operating, maintaining, and improving the Strategic Road Network (SRN) i.e., the Trunk Road and Motorway Network in England, as laid down in Department for Transport (DfT) Circular 01/2022 (Strategic Road Network and the delivery of sustainable development).
The SRN is a critical national asset and as such we work to ensure that it operates and is managed in the public interest, both in respect of current activities and needs as well as in providing effective stewardship of its long-term operation and integrity.
Our responses to Local Plan consultations are guided by relevant policy and guidance including the National Planning Policy Framework (2021) (NPPF):
• Transport issues should be considered from the earliest stages of plan-making and development proposals so that the potential impact of development on transport networks can be addressed (para 104).
• The planning system should actively manage patterns of growth such that significant development is focused on locations which are or can be made sustainable, through limiting the need to travel and offering a genuine choice of transport modes. (para 105).
• Planning policies should be prepared with the active involvement of highways authorities and other transport infrastructure providers so that strategies and investments for supporting sustainable transport and development patterns are aligned. (para 106).
• In terms of identifying the necessity of transport infrastructure, NPPF confirms that development should only be prevented or refused on highways grounds if there would be an unacceptable impact on highway safety, or the residual cumulative impacts on the road network would be severe. (para 111).
• Planning policies and decisions should support development that makes efficient use of land, taking into account the availability and capacity of infrastructure and services – both existing and proposed – as well as their potential for further improvement and the scope to promote sustainable travel modes that limit future car use. (para 124).
In relation to the tests of soundness set out at paragraph 35 of the NPPF, in the context of transport, these are interpreted as meaning:
a) Positively prepared - has the transport strategy been prepared with the active involvement of the highway authorities, other transport infrastructure providers and operators and neighbouring councils?
b) Justified – Is the transport strategy based on a robust evidence base prepared with the agreement in partnership, or with the support of the highway authorities?
c) Effective – Does the transport strategy and policy satisfy the transport needs of the plan and is it deliverable at a pace which provides for and accommodates the proposed progress and implementation of the plan?
d) Consistent with national policy – Does the transport strategy support the economic, social, and environmental objectives of the Plan and the NPPF/NPPG?
We will be concerned with proposals that have the potential to impact on the safe and efficient operation of the SRN; in this case, the A27 trunk road (Chichester Bypass and its junctions) which is the main access route in the Chichester area. We have particular interest in any allocation, policy or proposals which could have implications for the A27 and the wider SRN network. We are interested as to whether there would be any adverse road safety or operational implications for the SRN. The latter would include a material increase in queueing or delay or reduction in journey time reliability during the construction or operation of the development set out in the plan.
National Highways is a key delivery partner for sustainable development promoted through the plan-led system, and as a statutory consultee we have a duty to cooperate with local authorities to support the preparation and implementation of development plan documents.
In accordance with national planning and transport policy and our operating licence, we are entirely neutral on the principle of development as it is for the local planning authority to determine whether development should be allocated or permitted; albeit it must comply with national policy on locating development in locations that are or can be made sustainable. Therefore, while always seeking early and fulsome engagement with local plans and/or developers, we will simply be assessing the transport and related implications of plans or proposals and agreeing any necessary transport improvements and relevant development management policy.
In progressing Local Plans, we will seek to agree the following:
• Assessment tools and methodology
• Baseline Assessment i.e., to demonstrate that the assessment tool accurately reflects current transport conditions
• Comparator case assessment i.e., to forecast the transport conditions that would occur in the absence of the plan
• Forecast modelling i.e., to forecast the transport conditions that would arise with the plan in place, this will include an assessment at the end of the Plan period; and, if required, at full build out if that occurs after the end of the Plan period
• Outputs and outcomes of modelling, demonstrating, as appropriate, what transport infrastructure is necessary to support the plan o It should be noted that a suite of transport modelling tools may be required. This includes strategic modelling covering an area at least one major junction beyond the district boundary, localised network modelling where several links/junctions are close together and/or individual junction modelling
o A DMRB (Design Manual for Roads and Bridges) compliancy assessment may also be required for certain highway features, such as
Merge/Diverge assessment at Grade separated junctions, link capacity assessments, and others.
• The design of any necessary transport infrastructure, to an extent suitable for establishing deliverability during the plan period at the time that it becomes necessary for the purpose of ensuring that unacceptable road safety impacts or severe operational impacts do not arise as a result of development. This may be to at least General Arrangement design stage or preliminary design stage. Whichever degree of detail is agreed, the products must be in full compliance with the DMRB.
• Industry standard transport intervention costings.
• The delivery/funding mechanisms for necessary transport interventions. It should not be assumed that National Highways will have any responsibility to identify or deliver necessary transport interventions.
• If considered appropriate, a “Monitor & Manage” (M&M) framework, aimed at managing the pace of development in line with the pace of funding and delivery of necessary highway interventions in a manner which responds to the realworld impacts of development may be agreed for inclusion in the plan subject to the adequacy of risk control measures included therein. This can include the move from a ‘predict & provide’ style of delivery to ‘a vision & validate’ style. o Any M&M framework must be based on a “worst case scenario” whereby necessary mitigation is understood, as well as setting out the desired alternative scenario. It must set out details of responsibility, funding and governance of the framework together with the methodology for determining the timing for any mitigation delivery while remaining clear on the fallback position where identified mitigation or desired alternatives are not ultimately achievable. It must be translated into development management plan policy and policy relating to development allocations.
Further detail on the above can be provided by National Highways.
While ideally all the above should be agreed prior to the Submission of the Local Plan for examination, we recognise that this is not always possible. However, all parties should work towards all matters being agreed and reflected in a Statement of Common Ground (SoCG) by the start of the Local Plan Examination at the latest. Ideally the SoCG between the Council and National Highways would be prepared well in advance of plan submission in order to guide resource input and to track progress towards final agreement on all relevant matters starting from the earliest plan iterations until the final version is agreed.
It is acknowledged that Government policy places much emphasis on housing delivery as a means for ensuring economic growth and addressing the current national shortage of housing. The NPPF is very clear that:
“Strategic policy-making authorities should establish a housing requirement figure for their whole area, which shows the extent to which their identified housing need (and any needs that cannot be met within neighbouring areas) can be met over the plan period.”
However, new DfT C1/22 and the NPPF are equally clear that any development, including housing delivery, must be tempered by the requirement to ensure that the associated transport demand can be accommodated without unacceptable impacts on the safety of the SRN or severe impacts on the operation of the SRN including reliability and congestion. Therefore, as necessary and appropriate, any plan and/or development must be accompanied by suitable mitigation in the right places at the right time, that is to the required design standards and is deliverable in terms of land availability, constructability and funding.
We would also draw your attention to the then Highways England document ‘The Strategic Road Network, Planning for the Future: A guide to working with National
Highways on planning matters’ (September 2015). This document sets out how National Highways intends to work with local planning authorities and developers to support the preparation of sound documents which enable the delivery of sustainable development. https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachmen t_data/file/461023/N150227_-_Highways_England_Planning_Document_FINAL-lo.pdf
Responses to Local Plan consultations are also guided by National Planning Policy Framework (NPPF) revised on 20 July 2021 which sets out the government’s planning policies for England and how these are expected to be applied.
Updated Circular (01/2022)
It should be noted that since the start of the Local Plan consultation process, on the 23 December 2022, the Department for Transport released a new circular on the ‘Strategic road network and the delivery of sustainable development’ (Circular 01/2022), which replaces all of the policies in Circular 02/2013 of the same name. These representations take account of the new circular and the requirements in terms of the Local Plan evidence base and process.
We request that the Local Plan is prepared in line with all aspects of the new circular. Particularly, the principles of sustainable development (paragraphs 11 to 17), new connections and capacity enhancements (paragraphs 18 to 25), and engagement with plan-making (paragraphs 26 to 38).
Regulation 18 submission
In our Regulation 18 submission we noted several matters including:
• The need to mitigate the adverse impacts of strategic development traffic to the A27 Chichester Bypass and its junctions at Portfield Roundabout, Bognor Road Roundabout, Whyke Roundabout, Stockbridge Roundabout and Fishbourne Roundabout and Oving junction.
• The need to identify a mechanism to calculate contributions towards the delivery of the previously agreed Local Plan A27 improvements
• The need to confirm the number of dwellings needed within the plan period
• The need to establish National Highways acceptance of the traffic model reference and future case scenarios
• The need to confirm costs, viability, and funding associated with mitigating the safety and congestion impacts of the development included within the plan.
Local Plan context
This Local Plan (Chichester Local Plan 2021 – 2039), prepared by the Local Planning Authority (LPA) Chichester District Council, sets out the vision for future development in the district and will be used to help decide on planning applications and other planning related decisions including shaping infrastructure investments.
The draft sets out how the district should be developed over the next 18-years to 2039 including for the full Plan period (1 April 2021 to 31 March 2039) the total supply of
- 10,359 dwellings
- 114,652 net additional sqm new floorspace
Minus the completions this is equivalent to around 530 dwellings and 6,150 sqm of floorspace a year.
National Highways Representations
To date National Highways have worked collaboratively with Chichester District Council (the Council) and West Sussex County Council (WSCC) and we will continue to work with the Council and other key stakeholders.
We have undertaken a review of the Chichester Local Plan 2021-2039 proposed submission version and accompanying evidence documents, our comments are set out in the tables below (following pages). [see table within attachment]
Summary
We have reviewed the publicly available Local Plan documents and provided comments above in relation to the transport implications of the plan for the safety and operation of the SRN. We understand that other technical information is available, but this was not presented as part of this consultation.
Chichester, and the A27, are already heavily congested, infrastructure in the existing Local Plan remains undelivered and the growth set out in the new Plan will further increase travel demand.
As presented, satisfying the transport needs of the plan is clearly reliant on the delivery of the A27 Chichester bypass improvements project. The A27 Chichester bypass improvements project is one of 32 pipeline schemes being considered for possible inclusion in National Highways third Road Investment Strategy (RIS3) covering 1 April 2025 to 31 March 2030.
On 9 March 2023 the UK Transport Secretary ensured record funding would be invested in the country’s transport network, sustainably driving growth across the country while managing the pressures of inflation. The announcement cited the A27 Arundel Bypass as being deferred from RIS2 to RIS 3 (covering 2025-2030). The transport secretary also identified a number of challenges to the delivery of the road investment strategy and cited the benefit of allowing extra time to ensure schemes are better planned and efficient schemes can be deployed more effectively.
At present, there is no commitment by DfT to carry out the A27 Chichester bypass improvements project. Until the A27 Chichester bypass improvements project is published in the RIS3, consented and a decision to invest is made it cannot be assumed to be a committed project.
We note that the Plan does not address any uncertainty of delivery of the A27 Chichester bypass improvements project and we strongly recommend that there is either no reliance placed on RIS3 to realise capacity for growth in the Plan or that contingency measures are included to cover the eventuality that RIS3 funding is not forthcoming within the plan period. It is not clear that the potential impact of development on transport networks can be addressed in the absence of the A27 Chichester bypass improvements project.
Achieving net zero, reducing emissions reduction, acting on climate, and supporting thousands of new homes and new employment developments will be problematic with existing processes. New, additional, and adapted processes and assessments will likely be required, especially in assessing Transport Assessments, mandating Travel Plans and monitoring traffic associated with new developments. We acknowledge that change is complex, expensive, and time-consuming, especially for smaller district level Councils. But the hard work will deliver benefits for the Council and residents in the longer-term.
National Highways seeks to continue working with the Council and WSCC to progress coordinated and deliverable packages of interim mitigation measures and alternative transport solutions while a long-term strategic solution is considered by government. This must however be in combination with a robust monitor and manage policy that appropriately manages the risk of unacceptable road impacts resulting from new housing
and other development over the Plan period.
We have been in discussion with Chichester District Council regarding their proposed Monitor and Manage Strategy. At present, we do not consider the current strategy to be robust and we seek further information and detail especially on who, when and when monitoring and management will be undertaken. Developments in the right places and served by the right sustainable infrastructure delivered alongside or ahead of occupancy must be a key consideration when planning for growth in all local authority areas. Any M&M framework must be based on a “worst case scenario” whereby necessary transport mitigation is understood, as well as setting out the desired alternative scenario. It must set out details of responsibility, funding and governance of the framework together with the methodology for determining the timing for any mitigation delivery while remaining clear on the fallback position where identified mitigation or desired alternatives are not ultimately achievable. The M&M framework must set out that the alternative to mitigation not being delivered is that development does not proceed where that development would give rise to unacceptable road safety risk or severe cumulative impacts on the road network in the absence of that mitigation. The M&M framework must be translated into development management plan policy and policy relating to development allocations.
As we have reiterated throughout our comments, we welcome the opportunity to work with you to address these outstanding matters and we will continue to liaise over submitted Transport Assessment, Travel Plan policy and Monitor and Manage Policy to help to work towards a viable plan.
We hope our comments assist.
We look forward to continuing to participate in future consultations and discussions. Please do continue to consult us as the Plan progresses so that we can remain aware of, and comment as required on, its contents.
Once you have had the opportunity to digest all the representations received, we would welcome a meeting to run through all the transport related matters and agree how to progress any required evidence gathering or other work.
Attachments:
- Written representation (356.49 KB)
Policy P1 recognises safety as a design consideration. The reference and the overall policy is purposefully high level and it is not considered necessary to provide an explicit reference to road safety considerations in relation to signage in this policy. Moreover, this issue is addressed in paragraph 141 of the NPPF, and it is considered that there is no need to repeat those requirements in this policy
Object
Chichester Local Plan 2021 - 2039: Proposed Submission
Policy P3 Density
Representation ID: 5299
Received: 16/03/2023
Respondent: National Highways
Legally compliant? Not specified
Sound? Not specified
Duty to co-operate? Not specified
[National Highways letter dated 24/07/23 confirmed representation should be categorised as Comment - Seeking further information.] We support development proposals that make the most efficient use of land however, National Highways seek to understand how constraints, including traffic generation and network capacity will be assessed and reported for optimum density developments. We also seek to understand how ‘car-less’ and ‘carfree’ or ‘low car’ will be managed. Evidence from other UK councils suggests that residents of these developments, and their visitors, park in adjacent or nearby residential streets. When this occurs in close proximity to SRN junctions there is the potential to impact the SRN, for example:
- constraints to junction operations
- safety implications
- limitations to freight movements
We have reviewed the publicly available Local Plan documents and provided comments in the attached letter, in relation to the transport implications of the plan for the safety and operation of the SRN.
Our comments include issues to resolve, comments, requests for further information and recommendations. A brief summary of our main comments are:
- the reliance on the delivery of the A27 Chichester bypass improvements project.
- the requirements for new, additional, and adapted processes and assessments, especially in assessing Transport Assessments, mandating Travel Plans and monitoring traffic associated with new developments.
- collaborative working between agencies in combination with a robust monitor and manage policy.
We hope our comments assist.
To date National Highways have worked collaboratively with Chichester District Council (the Council) and West Sussex County Council (WSCC) and we will continue to work with the Council and other key stakeholders. We look forward to continuing to participate in future consultations and discussions.
Once you have had the opportunity to digest all the representations received, we would welcome a meeting to run through all the transport related matters and agree how to progress any required evidence gathering or other work.
Background
National Highways has been appointed by the Secretary of State for Transport as strategic highway company under the provisions of the Infrastructure Act 2015 and is the highway authority, traffic authority and street authority for the strategic road network (SRN).
National Highways is responsible for operating, maintaining, and improving the Strategic Road Network (SRN) i.e., the Trunk Road and Motorway Network in England, as laid down in Department for Transport (DfT) Circular 01/2022 (Strategic Road Network and the delivery of sustainable development).
The SRN is a critical national asset and as such we work to ensure that it operates and is managed in the public interest, both in respect of current activities and needs as well as in providing effective stewardship of its long-term operation and integrity.
Our responses to Local Plan consultations are guided by relevant policy and guidance including the National Planning Policy Framework (2021) (NPPF):
• Transport issues should be considered from the earliest stages of plan-making and development proposals so that the potential impact of development on transport networks can be addressed (para 104).
• The planning system should actively manage patterns of growth such that significant development is focused on locations which are or can be made sustainable, through limiting the need to travel and offering a genuine choice of transport modes. (para 105).
• Planning policies should be prepared with the active involvement of highways authorities and other transport infrastructure providers so that strategies and investments for supporting sustainable transport and development patterns are aligned. (para 106).
• In terms of identifying the necessity of transport infrastructure, NPPF confirms that development should only be prevented or refused on highways grounds if there would be an unacceptable impact on highway safety, or the residual cumulative impacts on the road network would be severe. (para 111).
• Planning policies and decisions should support development that makes efficient use of land, taking into account the availability and capacity of infrastructure and services – both existing and proposed – as well as their potential for further improvement and the scope to promote sustainable travel modes that limit future car use. (para 124).
In relation to the tests of soundness set out at paragraph 35 of the NPPF, in the context of transport, these are interpreted as meaning:
a) Positively prepared - has the transport strategy been prepared with the active involvement of the highway authorities, other transport infrastructure providers and operators and neighbouring councils?
b) Justified – Is the transport strategy based on a robust evidence base prepared with the agreement in partnership, or with the support of the highway authorities?
c) Effective – Does the transport strategy and policy satisfy the transport needs of the plan and is it deliverable at a pace which provides for and accommodates the proposed progress and implementation of the plan?
d) Consistent with national policy – Does the transport strategy support the economic, social, and environmental objectives of the Plan and the NPPF/NPPG?
We will be concerned with proposals that have the potential to impact on the safe and efficient operation of the SRN; in this case, the A27 trunk road (Chichester Bypass and its junctions) which is the main access route in the Chichester area. We have particular interest in any allocation, policy or proposals which could have implications for the A27 and the wider SRN network. We are interested as to whether there would be any adverse road safety or operational implications for the SRN. The latter would include a material increase in queueing or delay or reduction in journey time reliability during the construction or operation of the development set out in the plan.
National Highways is a key delivery partner for sustainable development promoted through the plan-led system, and as a statutory consultee we have a duty to cooperate with local authorities to support the preparation and implementation of development plan documents.
In accordance with national planning and transport policy and our operating licence, we are entirely neutral on the principle of development as it is for the local planning authority to determine whether development should be allocated or permitted; albeit it must comply with national policy on locating development in locations that are or can be made sustainable. Therefore, while always seeking early and fulsome engagement with local plans and/or developers, we will simply be assessing the transport and related implications of plans or proposals and agreeing any necessary transport improvements and relevant development management policy.
In progressing Local Plans, we will seek to agree the following:
• Assessment tools and methodology
• Baseline Assessment i.e., to demonstrate that the assessment tool accurately reflects current transport conditions
• Comparator case assessment i.e., to forecast the transport conditions that would occur in the absence of the plan
• Forecast modelling i.e., to forecast the transport conditions that would arise with the plan in place, this will include an assessment at the end of the Plan period; and, if required, at full build out if that occurs after the end of the Plan period
• Outputs and outcomes of modelling, demonstrating, as appropriate, what transport infrastructure is necessary to support the plan o It should be noted that a suite of transport modelling tools may be required. This includes strategic modelling covering an area at least one major junction beyond the district boundary, localised network modelling where several links/junctions are close together and/or individual junction modelling
o A DMRB (Design Manual for Roads and Bridges) compliancy assessment may also be required for certain highway features, such as
Merge/Diverge assessment at Grade separated junctions, link capacity assessments, and others.
• The design of any necessary transport infrastructure, to an extent suitable for establishing deliverability during the plan period at the time that it becomes necessary for the purpose of ensuring that unacceptable road safety impacts or severe operational impacts do not arise as a result of development. This may be to at least General Arrangement design stage or preliminary design stage. Whichever degree of detail is agreed, the products must be in full compliance with the DMRB.
• Industry standard transport intervention costings.
• The delivery/funding mechanisms for necessary transport interventions. It should not be assumed that National Highways will have any responsibility to identify or deliver necessary transport interventions.
• If considered appropriate, a “Monitor & Manage” (M&M) framework, aimed at managing the pace of development in line with the pace of funding and delivery of necessary highway interventions in a manner which responds to the realworld impacts of development may be agreed for inclusion in the plan subject to the adequacy of risk control measures included therein. This can include the move from a ‘predict & provide’ style of delivery to ‘a vision & validate’ style. o Any M&M framework must be based on a “worst case scenario” whereby necessary mitigation is understood, as well as setting out the desired alternative scenario. It must set out details of responsibility, funding and governance of the framework together with the methodology for determining the timing for any mitigation delivery while remaining clear on the fallback position where identified mitigation or desired alternatives are not ultimately achievable. It must be translated into development management plan policy and policy relating to development allocations.
Further detail on the above can be provided by National Highways.
While ideally all the above should be agreed prior to the Submission of the Local Plan for examination, we recognise that this is not always possible. However, all parties should work towards all matters being agreed and reflected in a Statement of Common Ground (SoCG) by the start of the Local Plan Examination at the latest. Ideally the SoCG between the Council and National Highways would be prepared well in advance of plan submission in order to guide resource input and to track progress towards final agreement on all relevant matters starting from the earliest plan iterations until the final version is agreed.
It is acknowledged that Government policy places much emphasis on housing delivery as a means for ensuring economic growth and addressing the current national shortage of housing. The NPPF is very clear that:
“Strategic policy-making authorities should establish a housing requirement figure for their whole area, which shows the extent to which their identified housing need (and any needs that cannot be met within neighbouring areas) can be met over the plan period.”
However, new DfT C1/22 and the NPPF are equally clear that any development, including housing delivery, must be tempered by the requirement to ensure that the associated transport demand can be accommodated without unacceptable impacts on the safety of the SRN or severe impacts on the operation of the SRN including reliability and congestion. Therefore, as necessary and appropriate, any plan and/or development must be accompanied by suitable mitigation in the right places at the right time, that is to the required design standards and is deliverable in terms of land availability, constructability and funding.
We would also draw your attention to the then Highways England document ‘The Strategic Road Network, Planning for the Future: A guide to working with National
Highways on planning matters’ (September 2015). This document sets out how National Highways intends to work with local planning authorities and developers to support the preparation of sound documents which enable the delivery of sustainable development. https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachmen t_data/file/461023/N150227_-_Highways_England_Planning_Document_FINAL-lo.pdf
Responses to Local Plan consultations are also guided by National Planning Policy Framework (NPPF) revised on 20 July 2021 which sets out the government’s planning policies for England and how these are expected to be applied.
Updated Circular (01/2022)
It should be noted that since the start of the Local Plan consultation process, on the 23 December 2022, the Department for Transport released a new circular on the ‘Strategic road network and the delivery of sustainable development’ (Circular 01/2022), which replaces all of the policies in Circular 02/2013 of the same name. These representations take account of the new circular and the requirements in terms of the Local Plan evidence base and process.
We request that the Local Plan is prepared in line with all aspects of the new circular. Particularly, the principles of sustainable development (paragraphs 11 to 17), new connections and capacity enhancements (paragraphs 18 to 25), and engagement with plan-making (paragraphs 26 to 38).
Regulation 18 submission
In our Regulation 18 submission we noted several matters including:
• The need to mitigate the adverse impacts of strategic development traffic to the A27 Chichester Bypass and its junctions at Portfield Roundabout, Bognor Road Roundabout, Whyke Roundabout, Stockbridge Roundabout and Fishbourne Roundabout and Oving junction.
• The need to identify a mechanism to calculate contributions towards the delivery of the previously agreed Local Plan A27 improvements
• The need to confirm the number of dwellings needed within the plan period
• The need to establish National Highways acceptance of the traffic model reference and future case scenarios
• The need to confirm costs, viability, and funding associated with mitigating the safety and congestion impacts of the development included within the plan.
Local Plan context
This Local Plan (Chichester Local Plan 2021 – 2039), prepared by the Local Planning Authority (LPA) Chichester District Council, sets out the vision for future development in the district and will be used to help decide on planning applications and other planning related decisions including shaping infrastructure investments.
The draft sets out how the district should be developed over the next 18-years to 2039 including for the full Plan period (1 April 2021 to 31 March 2039) the total supply of
- 10,359 dwellings
- 114,652 net additional sqm new floorspace
Minus the completions this is equivalent to around 530 dwellings and 6,150 sqm of floorspace a year.
National Highways Representations
To date National Highways have worked collaboratively with Chichester District Council (the Council) and West Sussex County Council (WSCC) and we will continue to work with the Council and other key stakeholders.
We have undertaken a review of the Chichester Local Plan 2021-2039 proposed submission version and accompanying evidence documents, our comments are set out in the tables below (following pages). [see table within attachment]
Summary
We have reviewed the publicly available Local Plan documents and provided comments above in relation to the transport implications of the plan for the safety and operation of the SRN. We understand that other technical information is available, but this was not presented as part of this consultation.
Chichester, and the A27, are already heavily congested, infrastructure in the existing Local Plan remains undelivered and the growth set out in the new Plan will further increase travel demand.
As presented, satisfying the transport needs of the plan is clearly reliant on the delivery of the A27 Chichester bypass improvements project. The A27 Chichester bypass improvements project is one of 32 pipeline schemes being considered for possible inclusion in National Highways third Road Investment Strategy (RIS3) covering 1 April 2025 to 31 March 2030.
On 9 March 2023 the UK Transport Secretary ensured record funding would be invested in the country’s transport network, sustainably driving growth across the country while managing the pressures of inflation. The announcement cited the A27 Arundel Bypass as being deferred from RIS2 to RIS 3 (covering 2025-2030). The transport secretary also identified a number of challenges to the delivery of the road investment strategy and cited the benefit of allowing extra time to ensure schemes are better planned and efficient schemes can be deployed more effectively.
At present, there is no commitment by DfT to carry out the A27 Chichester bypass improvements project. Until the A27 Chichester bypass improvements project is published in the RIS3, consented and a decision to invest is made it cannot be assumed to be a committed project.
We note that the Plan does not address any uncertainty of delivery of the A27 Chichester bypass improvements project and we strongly recommend that there is either no reliance placed on RIS3 to realise capacity for growth in the Plan or that contingency measures are included to cover the eventuality that RIS3 funding is not forthcoming within the plan period. It is not clear that the potential impact of development on transport networks can be addressed in the absence of the A27 Chichester bypass improvements project.
Achieving net zero, reducing emissions reduction, acting on climate, and supporting thousands of new homes and new employment developments will be problematic with existing processes. New, additional, and adapted processes and assessments will likely be required, especially in assessing Transport Assessments, mandating Travel Plans and monitoring traffic associated with new developments. We acknowledge that change is complex, expensive, and time-consuming, especially for smaller district level Councils. But the hard work will deliver benefits for the Council and residents in the longer-term.
National Highways seeks to continue working with the Council and WSCC to progress coordinated and deliverable packages of interim mitigation measures and alternative transport solutions while a long-term strategic solution is considered by government. This must however be in combination with a robust monitor and manage policy that appropriately manages the risk of unacceptable road impacts resulting from new housing
and other development over the Plan period.
We have been in discussion with Chichester District Council regarding their proposed Monitor and Manage Strategy. At present, we do not consider the current strategy to be robust and we seek further information and detail especially on who, when and when monitoring and management will be undertaken. Developments in the right places and served by the right sustainable infrastructure delivered alongside or ahead of occupancy must be a key consideration when planning for growth in all local authority areas. Any M&M framework must be based on a “worst case scenario” whereby necessary transport mitigation is understood, as well as setting out the desired alternative scenario. It must set out details of responsibility, funding and governance of the framework together with the methodology for determining the timing for any mitigation delivery while remaining clear on the fallback position where identified mitigation or desired alternatives are not ultimately achievable. The M&M framework must set out that the alternative to mitigation not being delivered is that development does not proceed where that development would give rise to unacceptable road safety risk or severe cumulative impacts on the road network in the absence of that mitigation. The M&M framework must be translated into development management plan policy and policy relating to development allocations.
As we have reiterated throughout our comments, we welcome the opportunity to work with you to address these outstanding matters and we will continue to liaise over submitted Transport Assessment, Travel Plan policy and Monitor and Manage Policy to help to work towards a viable plan.
We hope our comments assist.
We look forward to continuing to participate in future consultations and discussions. Please do continue to consult us as the Plan progresses so that we can remain aware of, and comment as required on, its contents.
Once you have had the opportunity to digest all the representations received, we would welcome a meeting to run through all the transport related matters and agree how to progress any required evidence gathering or other work.
Attachments:
- Written representation (356.49 KB)
The policy is considered appropriate in terms of supporting efficient use of land and in so doing will support sustainable patterns of development which will be advantageous from a transport perspective. The council acknowledge that parking issues can be complicated in relation to higher density proposals. This will need to be considered on a site by site basis, and ultimately the issues raised will primarily be considered under the transport policies, particularly policy T4
Object
Chichester Local Plan 2021 - 2039: Proposed Submission
Policy P4 Layout and Access
Representation ID: 5300
Received: 16/03/2023
Respondent: National Highways
Legally compliant? Not specified
Sound? Not specified
Duty to co-operate? Not specified
[National Highways letter dated 24/07/23 confirmed representation should be categorised as Comment - Seeking clarity on the approach e.g., severance.] Considerations should be given, and evidence provided, on how new active travel links will integrate with the wider network including the existing A27 pedestrian and cycle footbridges and active travel routes along/intersecting the A27 corridor and how new facilities will be funded, monitored, and maintained. This is an important measure to reduce demand on the A27.
We seek clarity on how severance will be addressed and potential severance impacts.
We have reviewed the publicly available Local Plan documents and provided comments in the attached letter, in relation to the transport implications of the plan for the safety and operation of the SRN.
Our comments include issues to resolve, comments, requests for further information and recommendations. A brief summary of our main comments are:
- the reliance on the delivery of the A27 Chichester bypass improvements project.
- the requirements for new, additional, and adapted processes and assessments, especially in assessing Transport Assessments, mandating Travel Plans and monitoring traffic associated with new developments.
- collaborative working between agencies in combination with a robust monitor and manage policy.
We hope our comments assist.
To date National Highways have worked collaboratively with Chichester District Council (the Council) and West Sussex County Council (WSCC) and we will continue to work with the Council and other key stakeholders. We look forward to continuing to participate in future consultations and discussions.
Once you have had the opportunity to digest all the representations received, we would welcome a meeting to run through all the transport related matters and agree how to progress any required evidence gathering or other work.
Background
National Highways has been appointed by the Secretary of State for Transport as strategic highway company under the provisions of the Infrastructure Act 2015 and is the highway authority, traffic authority and street authority for the strategic road network (SRN).
National Highways is responsible for operating, maintaining, and improving the Strategic Road Network (SRN) i.e., the Trunk Road and Motorway Network in England, as laid down in Department for Transport (DfT) Circular 01/2022 (Strategic Road Network and the delivery of sustainable development).
The SRN is a critical national asset and as such we work to ensure that it operates and is managed in the public interest, both in respect of current activities and needs as well as in providing effective stewardship of its long-term operation and integrity.
Our responses to Local Plan consultations are guided by relevant policy and guidance including the National Planning Policy Framework (2021) (NPPF):
• Transport issues should be considered from the earliest stages of plan-making and development proposals so that the potential impact of development on transport networks can be addressed (para 104).
• The planning system should actively manage patterns of growth such that significant development is focused on locations which are or can be made sustainable, through limiting the need to travel and offering a genuine choice of transport modes. (para 105).
• Planning policies should be prepared with the active involvement of highways authorities and other transport infrastructure providers so that strategies and investments for supporting sustainable transport and development patterns are aligned. (para 106).
• In terms of identifying the necessity of transport infrastructure, NPPF confirms that development should only be prevented or refused on highways grounds if there would be an unacceptable impact on highway safety, or the residual cumulative impacts on the road network would be severe. (para 111).
• Planning policies and decisions should support development that makes efficient use of land, taking into account the availability and capacity of infrastructure and services – both existing and proposed – as well as their potential for further improvement and the scope to promote sustainable travel modes that limit future car use. (para 124).
In relation to the tests of soundness set out at paragraph 35 of the NPPF, in the context of transport, these are interpreted as meaning:
a) Positively prepared - has the transport strategy been prepared with the active involvement of the highway authorities, other transport infrastructure providers and operators and neighbouring councils?
b) Justified – Is the transport strategy based on a robust evidence base prepared with the agreement in partnership, or with the support of the highway authorities?
c) Effective – Does the transport strategy and policy satisfy the transport needs of the plan and is it deliverable at a pace which provides for and accommodates the proposed progress and implementation of the plan?
d) Consistent with national policy – Does the transport strategy support the economic, social, and environmental objectives of the Plan and the NPPF/NPPG?
We will be concerned with proposals that have the potential to impact on the safe and efficient operation of the SRN; in this case, the A27 trunk road (Chichester Bypass and its junctions) which is the main access route in the Chichester area. We have particular interest in any allocation, policy or proposals which could have implications for the A27 and the wider SRN network. We are interested as to whether there would be any adverse road safety or operational implications for the SRN. The latter would include a material increase in queueing or delay or reduction in journey time reliability during the construction or operation of the development set out in the plan.
National Highways is a key delivery partner for sustainable development promoted through the plan-led system, and as a statutory consultee we have a duty to cooperate with local authorities to support the preparation and implementation of development plan documents.
In accordance with national planning and transport policy and our operating licence, we are entirely neutral on the principle of development as it is for the local planning authority to determine whether development should be allocated or permitted; albeit it must comply with national policy on locating development in locations that are or can be made sustainable. Therefore, while always seeking early and fulsome engagement with local plans and/or developers, we will simply be assessing the transport and related implications of plans or proposals and agreeing any necessary transport improvements and relevant development management policy.
In progressing Local Plans, we will seek to agree the following:
• Assessment tools and methodology
• Baseline Assessment i.e., to demonstrate that the assessment tool accurately reflects current transport conditions
• Comparator case assessment i.e., to forecast the transport conditions that would occur in the absence of the plan
• Forecast modelling i.e., to forecast the transport conditions that would arise with the plan in place, this will include an assessment at the end of the Plan period; and, if required, at full build out if that occurs after the end of the Plan period
• Outputs and outcomes of modelling, demonstrating, as appropriate, what transport infrastructure is necessary to support the plan o It should be noted that a suite of transport modelling tools may be required. This includes strategic modelling covering an area at least one major junction beyond the district boundary, localised network modelling where several links/junctions are close together and/or individual junction modelling
o A DMRB (Design Manual for Roads and Bridges) compliancy assessment may also be required for certain highway features, such as
Merge/Diverge assessment at Grade separated junctions, link capacity assessments, and others.
• The design of any necessary transport infrastructure, to an extent suitable for establishing deliverability during the plan period at the time that it becomes necessary for the purpose of ensuring that unacceptable road safety impacts or severe operational impacts do not arise as a result of development. This may be to at least General Arrangement design stage or preliminary design stage. Whichever degree of detail is agreed, the products must be in full compliance with the DMRB.
• Industry standard transport intervention costings.
• The delivery/funding mechanisms for necessary transport interventions. It should not be assumed that National Highways will have any responsibility to identify or deliver necessary transport interventions.
• If considered appropriate, a “Monitor & Manage” (M&M) framework, aimed at managing the pace of development in line with the pace of funding and delivery of necessary highway interventions in a manner which responds to the realworld impacts of development may be agreed for inclusion in the plan subject to the adequacy of risk control measures included therein. This can include the move from a ‘predict & provide’ style of delivery to ‘a vision & validate’ style. o Any M&M framework must be based on a “worst case scenario” whereby necessary mitigation is understood, as well as setting out the desired alternative scenario. It must set out details of responsibility, funding and governance of the framework together with the methodology for determining the timing for any mitigation delivery while remaining clear on the fallback position where identified mitigation or desired alternatives are not ultimately achievable. It must be translated into development management plan policy and policy relating to development allocations.
Further detail on the above can be provided by National Highways.
While ideally all the above should be agreed prior to the Submission of the Local Plan for examination, we recognise that this is not always possible. However, all parties should work towards all matters being agreed and reflected in a Statement of Common Ground (SoCG) by the start of the Local Plan Examination at the latest. Ideally the SoCG between the Council and National Highways would be prepared well in advance of plan submission in order to guide resource input and to track progress towards final agreement on all relevant matters starting from the earliest plan iterations until the final version is agreed.
It is acknowledged that Government policy places much emphasis on housing delivery as a means for ensuring economic growth and addressing the current national shortage of housing. The NPPF is very clear that:
“Strategic policy-making authorities should establish a housing requirement figure for their whole area, which shows the extent to which their identified housing need (and any needs that cannot be met within neighbouring areas) can be met over the plan period.”
However, new DfT C1/22 and the NPPF are equally clear that any development, including housing delivery, must be tempered by the requirement to ensure that the associated transport demand can be accommodated without unacceptable impacts on the safety of the SRN or severe impacts on the operation of the SRN including reliability and congestion. Therefore, as necessary and appropriate, any plan and/or development must be accompanied by suitable mitigation in the right places at the right time, that is to the required design standards and is deliverable in terms of land availability, constructability and funding.
We would also draw your attention to the then Highways England document ‘The Strategic Road Network, Planning for the Future: A guide to working with National
Highways on planning matters’ (September 2015). This document sets out how National Highways intends to work with local planning authorities and developers to support the preparation of sound documents which enable the delivery of sustainable development. https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachmen t_data/file/461023/N150227_-_Highways_England_Planning_Document_FINAL-lo.pdf
Responses to Local Plan consultations are also guided by National Planning Policy Framework (NPPF) revised on 20 July 2021 which sets out the government’s planning policies for England and how these are expected to be applied.
Updated Circular (01/2022)
It should be noted that since the start of the Local Plan consultation process, on the 23 December 2022, the Department for Transport released a new circular on the ‘Strategic road network and the delivery of sustainable development’ (Circular 01/2022), which replaces all of the policies in Circular 02/2013 of the same name. These representations take account of the new circular and the requirements in terms of the Local Plan evidence base and process.
We request that the Local Plan is prepared in line with all aspects of the new circular. Particularly, the principles of sustainable development (paragraphs 11 to 17), new connections and capacity enhancements (paragraphs 18 to 25), and engagement with plan-making (paragraphs 26 to 38).
Regulation 18 submission
In our Regulation 18 submission we noted several matters including:
• The need to mitigate the adverse impacts of strategic development traffic to the A27 Chichester Bypass and its junctions at Portfield Roundabout, Bognor Road Roundabout, Whyke Roundabout, Stockbridge Roundabout and Fishbourne Roundabout and Oving junction.
• The need to identify a mechanism to calculate contributions towards the delivery of the previously agreed Local Plan A27 improvements
• The need to confirm the number of dwellings needed within the plan period
• The need to establish National Highways acceptance of the traffic model reference and future case scenarios
• The need to confirm costs, viability, and funding associated with mitigating the safety and congestion impacts of the development included within the plan.
Local Plan context
This Local Plan (Chichester Local Plan 2021 – 2039), prepared by the Local Planning Authority (LPA) Chichester District Council, sets out the vision for future development in the district and will be used to help decide on planning applications and other planning related decisions including shaping infrastructure investments.
The draft sets out how the district should be developed over the next 18-years to 2039 including for the full Plan period (1 April 2021 to 31 March 2039) the total supply of
- 10,359 dwellings
- 114,652 net additional sqm new floorspace
Minus the completions this is equivalent to around 530 dwellings and 6,150 sqm of floorspace a year.
National Highways Representations
To date National Highways have worked collaboratively with Chichester District Council (the Council) and West Sussex County Council (WSCC) and we will continue to work with the Council and other key stakeholders.
We have undertaken a review of the Chichester Local Plan 2021-2039 proposed submission version and accompanying evidence documents, our comments are set out in the tables below (following pages). [see table within attachment]
Summary
We have reviewed the publicly available Local Plan documents and provided comments above in relation to the transport implications of the plan for the safety and operation of the SRN. We understand that other technical information is available, but this was not presented as part of this consultation.
Chichester, and the A27, are already heavily congested, infrastructure in the existing Local Plan remains undelivered and the growth set out in the new Plan will further increase travel demand.
As presented, satisfying the transport needs of the plan is clearly reliant on the delivery of the A27 Chichester bypass improvements project. The A27 Chichester bypass improvements project is one of 32 pipeline schemes being considered for possible inclusion in National Highways third Road Investment Strategy (RIS3) covering 1 April 2025 to 31 March 2030.
On 9 March 2023 the UK Transport Secretary ensured record funding would be invested in the country’s transport network, sustainably driving growth across the country while managing the pressures of inflation. The announcement cited the A27 Arundel Bypass as being deferred from RIS2 to RIS 3 (covering 2025-2030). The transport secretary also identified a number of challenges to the delivery of the road investment strategy and cited the benefit of allowing extra time to ensure schemes are better planned and efficient schemes can be deployed more effectively.
At present, there is no commitment by DfT to carry out the A27 Chichester bypass improvements project. Until the A27 Chichester bypass improvements project is published in the RIS3, consented and a decision to invest is made it cannot be assumed to be a committed project.
We note that the Plan does not address any uncertainty of delivery of the A27 Chichester bypass improvements project and we strongly recommend that there is either no reliance placed on RIS3 to realise capacity for growth in the Plan or that contingency measures are included to cover the eventuality that RIS3 funding is not forthcoming within the plan period. It is not clear that the potential impact of development on transport networks can be addressed in the absence of the A27 Chichester bypass improvements project.
Achieving net zero, reducing emissions reduction, acting on climate, and supporting thousands of new homes and new employment developments will be problematic with existing processes. New, additional, and adapted processes and assessments will likely be required, especially in assessing Transport Assessments, mandating Travel Plans and monitoring traffic associated with new developments. We acknowledge that change is complex, expensive, and time-consuming, especially for smaller district level Councils. But the hard work will deliver benefits for the Council and residents in the longer-term.
National Highways seeks to continue working with the Council and WSCC to progress coordinated and deliverable packages of interim mitigation measures and alternative transport solutions while a long-term strategic solution is considered by government. This must however be in combination with a robust monitor and manage policy that appropriately manages the risk of unacceptable road impacts resulting from new housing
and other development over the Plan period.
We have been in discussion with Chichester District Council regarding their proposed Monitor and Manage Strategy. At present, we do not consider the current strategy to be robust and we seek further information and detail especially on who, when and when monitoring and management will be undertaken. Developments in the right places and served by the right sustainable infrastructure delivered alongside or ahead of occupancy must be a key consideration when planning for growth in all local authority areas. Any M&M framework must be based on a “worst case scenario” whereby necessary transport mitigation is understood, as well as setting out the desired alternative scenario. It must set out details of responsibility, funding and governance of the framework together with the methodology for determining the timing for any mitigation delivery while remaining clear on the fallback position where identified mitigation or desired alternatives are not ultimately achievable. The M&M framework must set out that the alternative to mitigation not being delivered is that development does not proceed where that development would give rise to unacceptable road safety risk or severe cumulative impacts on the road network in the absence of that mitigation. The M&M framework must be translated into development management plan policy and policy relating to development allocations.
As we have reiterated throughout our comments, we welcome the opportunity to work with you to address these outstanding matters and we will continue to liaise over submitted Transport Assessment, Travel Plan policy and Monitor and Manage Policy to help to work towards a viable plan.
We hope our comments assist.
We look forward to continuing to participate in future consultations and discussions. Please do continue to consult us as the Plan progresses so that we can remain aware of, and comment as required on, its contents.
Once you have had the opportunity to digest all the representations received, we would welcome a meeting to run through all the transport related matters and agree how to progress any required evidence gathering or other work.
Attachments:
- Written representation (356.49 KB)
Comments noted. Policy T3 is focused on the provision of active travel, including expectations on new development to deliver well-connected cycling and walking routes, ensuring integration with wider networks. The supporting text for T3 reflects benefits including reduced demand on the road network. It is therefore considered unnecessary to duplicate these points within P4, which is principally concerned with design matters associated with development layout and access.
Object
Chichester Local Plan 2021 - 2039: Proposed Submission
Policy P14 Green Infrastructure
Representation ID: 5302
Received: 16/03/2023
Respondent: National Highways
Legally compliant? Not specified
Sound? Not specified
Duty to co-operate? Not specified
[National Highways letter dated 24/07/23 confirmed representation should be categorised as Comment - Suggest proposals should support non-car trips.] As Policy P4, proposals should maximise opportunities to link with the wider network including the existing A27 pedestrian and cycle footbridges and active travel routes along/intersecting the A27 corridor and how new facilities will be funded, monitored, and maintained.
This is an important measure to reduce demand on the A27.
We have reviewed the publicly available Local Plan documents and provided comments in the attached letter, in relation to the transport implications of the plan for the safety and operation of the SRN.
Our comments include issues to resolve, comments, requests for further information and recommendations. A brief summary of our main comments are:
- the reliance on the delivery of the A27 Chichester bypass improvements project.
- the requirements for new, additional, and adapted processes and assessments, especially in assessing Transport Assessments, mandating Travel Plans and monitoring traffic associated with new developments.
- collaborative working between agencies in combination with a robust monitor and manage policy.
We hope our comments assist.
To date National Highways have worked collaboratively with Chichester District Council (the Council) and West Sussex County Council (WSCC) and we will continue to work with the Council and other key stakeholders. We look forward to continuing to participate in future consultations and discussions.
Once you have had the opportunity to digest all the representations received, we would welcome a meeting to run through all the transport related matters and agree how to progress any required evidence gathering or other work.
Background
National Highways has been appointed by the Secretary of State for Transport as strategic highway company under the provisions of the Infrastructure Act 2015 and is the highway authority, traffic authority and street authority for the strategic road network (SRN).
National Highways is responsible for operating, maintaining, and improving the Strategic Road Network (SRN) i.e., the Trunk Road and Motorway Network in England, as laid down in Department for Transport (DfT) Circular 01/2022 (Strategic Road Network and the delivery of sustainable development).
The SRN is a critical national asset and as such we work to ensure that it operates and is managed in the public interest, both in respect of current activities and needs as well as in providing effective stewardship of its long-term operation and integrity.
Our responses to Local Plan consultations are guided by relevant policy and guidance including the National Planning Policy Framework (2021) (NPPF):
• Transport issues should be considered from the earliest stages of plan-making and development proposals so that the potential impact of development on transport networks can be addressed (para 104).
• The planning system should actively manage patterns of growth such that significant development is focused on locations which are or can be made sustainable, through limiting the need to travel and offering a genuine choice of transport modes. (para 105).
• Planning policies should be prepared with the active involvement of highways authorities and other transport infrastructure providers so that strategies and investments for supporting sustainable transport and development patterns are aligned. (para 106).
• In terms of identifying the necessity of transport infrastructure, NPPF confirms that development should only be prevented or refused on highways grounds if there would be an unacceptable impact on highway safety, or the residual cumulative impacts on the road network would be severe. (para 111).
• Planning policies and decisions should support development that makes efficient use of land, taking into account the availability and capacity of infrastructure and services – both existing and proposed – as well as their potential for further improvement and the scope to promote sustainable travel modes that limit future car use. (para 124).
In relation to the tests of soundness set out at paragraph 35 of the NPPF, in the context of transport, these are interpreted as meaning:
a) Positively prepared - has the transport strategy been prepared with the active involvement of the highway authorities, other transport infrastructure providers and operators and neighbouring councils?
b) Justified – Is the transport strategy based on a robust evidence base prepared with the agreement in partnership, or with the support of the highway authorities?
c) Effective – Does the transport strategy and policy satisfy the transport needs of the plan and is it deliverable at a pace which provides for and accommodates the proposed progress and implementation of the plan?
d) Consistent with national policy – Does the transport strategy support the economic, social, and environmental objectives of the Plan and the NPPF/NPPG?
We will be concerned with proposals that have the potential to impact on the safe and efficient operation of the SRN; in this case, the A27 trunk road (Chichester Bypass and its junctions) which is the main access route in the Chichester area. We have particular interest in any allocation, policy or proposals which could have implications for the A27 and the wider SRN network. We are interested as to whether there would be any adverse road safety or operational implications for the SRN. The latter would include a material increase in queueing or delay or reduction in journey time reliability during the construction or operation of the development set out in the plan.
National Highways is a key delivery partner for sustainable development promoted through the plan-led system, and as a statutory consultee we have a duty to cooperate with local authorities to support the preparation and implementation of development plan documents.
In accordance with national planning and transport policy and our operating licence, we are entirely neutral on the principle of development as it is for the local planning authority to determine whether development should be allocated or permitted; albeit it must comply with national policy on locating development in locations that are or can be made sustainable. Therefore, while always seeking early and fulsome engagement with local plans and/or developers, we will simply be assessing the transport and related implications of plans or proposals and agreeing any necessary transport improvements and relevant development management policy.
In progressing Local Plans, we will seek to agree the following:
• Assessment tools and methodology
• Baseline Assessment i.e., to demonstrate that the assessment tool accurately reflects current transport conditions
• Comparator case assessment i.e., to forecast the transport conditions that would occur in the absence of the plan
• Forecast modelling i.e., to forecast the transport conditions that would arise with the plan in place, this will include an assessment at the end of the Plan period; and, if required, at full build out if that occurs after the end of the Plan period
• Outputs and outcomes of modelling, demonstrating, as appropriate, what transport infrastructure is necessary to support the plan o It should be noted that a suite of transport modelling tools may be required. This includes strategic modelling covering an area at least one major junction beyond the district boundary, localised network modelling where several links/junctions are close together and/or individual junction modelling
o A DMRB (Design Manual for Roads and Bridges) compliancy assessment may also be required for certain highway features, such as
Merge/Diverge assessment at Grade separated junctions, link capacity assessments, and others.
• The design of any necessary transport infrastructure, to an extent suitable for establishing deliverability during the plan period at the time that it becomes necessary for the purpose of ensuring that unacceptable road safety impacts or severe operational impacts do not arise as a result of development. This may be to at least General Arrangement design stage or preliminary design stage. Whichever degree of detail is agreed, the products must be in full compliance with the DMRB.
• Industry standard transport intervention costings.
• The delivery/funding mechanisms for necessary transport interventions. It should not be assumed that National Highways will have any responsibility to identify or deliver necessary transport interventions.
• If considered appropriate, a “Monitor & Manage” (M&M) framework, aimed at managing the pace of development in line with the pace of funding and delivery of necessary highway interventions in a manner which responds to the realworld impacts of development may be agreed for inclusion in the plan subject to the adequacy of risk control measures included therein. This can include the move from a ‘predict & provide’ style of delivery to ‘a vision & validate’ style. o Any M&M framework must be based on a “worst case scenario” whereby necessary mitigation is understood, as well as setting out the desired alternative scenario. It must set out details of responsibility, funding and governance of the framework together with the methodology for determining the timing for any mitigation delivery while remaining clear on the fallback position where identified mitigation or desired alternatives are not ultimately achievable. It must be translated into development management plan policy and policy relating to development allocations.
Further detail on the above can be provided by National Highways.
While ideally all the above should be agreed prior to the Submission of the Local Plan for examination, we recognise that this is not always possible. However, all parties should work towards all matters being agreed and reflected in a Statement of Common Ground (SoCG) by the start of the Local Plan Examination at the latest. Ideally the SoCG between the Council and National Highways would be prepared well in advance of plan submission in order to guide resource input and to track progress towards final agreement on all relevant matters starting from the earliest plan iterations until the final version is agreed.
It is acknowledged that Government policy places much emphasis on housing delivery as a means for ensuring economic growth and addressing the current national shortage of housing. The NPPF is very clear that:
“Strategic policy-making authorities should establish a housing requirement figure for their whole area, which shows the extent to which their identified housing need (and any needs that cannot be met within neighbouring areas) can be met over the plan period.”
However, new DfT C1/22 and the NPPF are equally clear that any development, including housing delivery, must be tempered by the requirement to ensure that the associated transport demand can be accommodated without unacceptable impacts on the safety of the SRN or severe impacts on the operation of the SRN including reliability and congestion. Therefore, as necessary and appropriate, any plan and/or development must be accompanied by suitable mitigation in the right places at the right time, that is to the required design standards and is deliverable in terms of land availability, constructability and funding.
We would also draw your attention to the then Highways England document ‘The Strategic Road Network, Planning for the Future: A guide to working with National
Highways on planning matters’ (September 2015). This document sets out how National Highways intends to work with local planning authorities and developers to support the preparation of sound documents which enable the delivery of sustainable development. https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachmen t_data/file/461023/N150227_-_Highways_England_Planning_Document_FINAL-lo.pdf
Responses to Local Plan consultations are also guided by National Planning Policy Framework (NPPF) revised on 20 July 2021 which sets out the government’s planning policies for England and how these are expected to be applied.
Updated Circular (01/2022)
It should be noted that since the start of the Local Plan consultation process, on the 23 December 2022, the Department for Transport released a new circular on the ‘Strategic road network and the delivery of sustainable development’ (Circular 01/2022), which replaces all of the policies in Circular 02/2013 of the same name. These representations take account of the new circular and the requirements in terms of the Local Plan evidence base and process.
We request that the Local Plan is prepared in line with all aspects of the new circular. Particularly, the principles of sustainable development (paragraphs 11 to 17), new connections and capacity enhancements (paragraphs 18 to 25), and engagement with plan-making (paragraphs 26 to 38).
Regulation 18 submission
In our Regulation 18 submission we noted several matters including:
• The need to mitigate the adverse impacts of strategic development traffic to the A27 Chichester Bypass and its junctions at Portfield Roundabout, Bognor Road Roundabout, Whyke Roundabout, Stockbridge Roundabout and Fishbourne Roundabout and Oving junction.
• The need to identify a mechanism to calculate contributions towards the delivery of the previously agreed Local Plan A27 improvements
• The need to confirm the number of dwellings needed within the plan period
• The need to establish National Highways acceptance of the traffic model reference and future case scenarios
• The need to confirm costs, viability, and funding associated with mitigating the safety and congestion impacts of the development included within the plan.
Local Plan context
This Local Plan (Chichester Local Plan 2021 – 2039), prepared by the Local Planning Authority (LPA) Chichester District Council, sets out the vision for future development in the district and will be used to help decide on planning applications and other planning related decisions including shaping infrastructure investments.
The draft sets out how the district should be developed over the next 18-years to 2039 including for the full Plan period (1 April 2021 to 31 March 2039) the total supply of
- 10,359 dwellings
- 114,652 net additional sqm new floorspace
Minus the completions this is equivalent to around 530 dwellings and 6,150 sqm of floorspace a year.
National Highways Representations
To date National Highways have worked collaboratively with Chichester District Council (the Council) and West Sussex County Council (WSCC) and we will continue to work with the Council and other key stakeholders.
We have undertaken a review of the Chichester Local Plan 2021-2039 proposed submission version and accompanying evidence documents, our comments are set out in the tables below (following pages). [see table within attachment]
Summary
We have reviewed the publicly available Local Plan documents and provided comments above in relation to the transport implications of the plan for the safety and operation of the SRN. We understand that other technical information is available, but this was not presented as part of this consultation.
Chichester, and the A27, are already heavily congested, infrastructure in the existing Local Plan remains undelivered and the growth set out in the new Plan will further increase travel demand.
As presented, satisfying the transport needs of the plan is clearly reliant on the delivery of the A27 Chichester bypass improvements project. The A27 Chichester bypass improvements project is one of 32 pipeline schemes being considered for possible inclusion in National Highways third Road Investment Strategy (RIS3) covering 1 April 2025 to 31 March 2030.
On 9 March 2023 the UK Transport Secretary ensured record funding would be invested in the country’s transport network, sustainably driving growth across the country while managing the pressures of inflation. The announcement cited the A27 Arundel Bypass as being deferred from RIS2 to RIS 3 (covering 2025-2030). The transport secretary also identified a number of challenges to the delivery of the road investment strategy and cited the benefit of allowing extra time to ensure schemes are better planned and efficient schemes can be deployed more effectively.
At present, there is no commitment by DfT to carry out the A27 Chichester bypass improvements project. Until the A27 Chichester bypass improvements project is published in the RIS3, consented and a decision to invest is made it cannot be assumed to be a committed project.
We note that the Plan does not address any uncertainty of delivery of the A27 Chichester bypass improvements project and we strongly recommend that there is either no reliance placed on RIS3 to realise capacity for growth in the Plan or that contingency measures are included to cover the eventuality that RIS3 funding is not forthcoming within the plan period. It is not clear that the potential impact of development on transport networks can be addressed in the absence of the A27 Chichester bypass improvements project.
Achieving net zero, reducing emissions reduction, acting on climate, and supporting thousands of new homes and new employment developments will be problematic with existing processes. New, additional, and adapted processes and assessments will likely be required, especially in assessing Transport Assessments, mandating Travel Plans and monitoring traffic associated with new developments. We acknowledge that change is complex, expensive, and time-consuming, especially for smaller district level Councils. But the hard work will deliver benefits for the Council and residents in the longer-term.
National Highways seeks to continue working with the Council and WSCC to progress coordinated and deliverable packages of interim mitigation measures and alternative transport solutions while a long-term strategic solution is considered by government. This must however be in combination with a robust monitor and manage policy that appropriately manages the risk of unacceptable road impacts resulting from new housing
and other development over the Plan period.
We have been in discussion with Chichester District Council regarding their proposed Monitor and Manage Strategy. At present, we do not consider the current strategy to be robust and we seek further information and detail especially on who, when and when monitoring and management will be undertaken. Developments in the right places and served by the right sustainable infrastructure delivered alongside or ahead of occupancy must be a key consideration when planning for growth in all local authority areas. Any M&M framework must be based on a “worst case scenario” whereby necessary transport mitigation is understood, as well as setting out the desired alternative scenario. It must set out details of responsibility, funding and governance of the framework together with the methodology for determining the timing for any mitigation delivery while remaining clear on the fallback position where identified mitigation or desired alternatives are not ultimately achievable. The M&M framework must set out that the alternative to mitigation not being delivered is that development does not proceed where that development would give rise to unacceptable road safety risk or severe cumulative impacts on the road network in the absence of that mitigation. The M&M framework must be translated into development management plan policy and policy relating to development allocations.
As we have reiterated throughout our comments, we welcome the opportunity to work with you to address these outstanding matters and we will continue to liaise over submitted Transport Assessment, Travel Plan policy and Monitor and Manage Policy to help to work towards a viable plan.
We hope our comments assist.
We look forward to continuing to participate in future consultations and discussions. Please do continue to consult us as the Plan progresses so that we can remain aware of, and comment as required on, its contents.
Once you have had the opportunity to digest all the representations received, we would welcome a meeting to run through all the transport related matters and agree how to progress any required evidence gathering or other work.
Attachments:
- Written representation (356.49 KB)
Objection and proposed change noted. i) We will consider modifications to Policy P14 to emphasise that proposals should provide integrated and enhanced active travel routes, and to clarify that strategic priorities (potentially including proposals to reduce demand on the A27) will be determined by the proposed Green Infrastructure Strategy. ii) Point 7. of Policy P14 states that management and maintenance of GI will be secured via planning obligation or legal agreement. Further clarification is therefore not considered necessary.
Support
Chichester Local Plan 2021 - 2039: Proposed Submission
Policy P16 Health and Well-being
Representation ID: 5304
Received: 16/03/2023
Respondent: National Highways
[National Highways letter dated 24/07/23 confirmed representation should be categorised as Comment - Supporting measures to reduce demand.] National Highways support proposals that are safe and connected to existing and future routes that are of the same standard of infrastructure, or better, to enable cycling and walking for local trips to reduce impacts on the A27. This is an important measure to reduce demand on the A27.
We have reviewed the publicly available Local Plan documents and provided comments in the attached letter, in relation to the transport implications of the plan for the safety and operation of the SRN.
Our comments include issues to resolve, comments, requests for further information and recommendations. A brief summary of our main comments are:
- the reliance on the delivery of the A27 Chichester bypass improvements project.
- the requirements for new, additional, and adapted processes and assessments, especially in assessing Transport Assessments, mandating Travel Plans and monitoring traffic associated with new developments.
- collaborative working between agencies in combination with a robust monitor and manage policy.
We hope our comments assist.
To date National Highways have worked collaboratively with Chichester District Council (the Council) and West Sussex County Council (WSCC) and we will continue to work with the Council and other key stakeholders. We look forward to continuing to participate in future consultations and discussions.
Once you have had the opportunity to digest all the representations received, we would welcome a meeting to run through all the transport related matters and agree how to progress any required evidence gathering or other work.
Background
National Highways has been appointed by the Secretary of State for Transport as strategic highway company under the provisions of the Infrastructure Act 2015 and is the highway authority, traffic authority and street authority for the strategic road network (SRN).
National Highways is responsible for operating, maintaining, and improving the Strategic Road Network (SRN) i.e., the Trunk Road and Motorway Network in England, as laid down in Department for Transport (DfT) Circular 01/2022 (Strategic Road Network and the delivery of sustainable development).
The SRN is a critical national asset and as such we work to ensure that it operates and is managed in the public interest, both in respect of current activities and needs as well as in providing effective stewardship of its long-term operation and integrity.
Our responses to Local Plan consultations are guided by relevant policy and guidance including the National Planning Policy Framework (2021) (NPPF):
• Transport issues should be considered from the earliest stages of plan-making and development proposals so that the potential impact of development on transport networks can be addressed (para 104).
• The planning system should actively manage patterns of growth such that significant development is focused on locations which are or can be made sustainable, through limiting the need to travel and offering a genuine choice of transport modes. (para 105).
• Planning policies should be prepared with the active involvement of highways authorities and other transport infrastructure providers so that strategies and investments for supporting sustainable transport and development patterns are aligned. (para 106).
• In terms of identifying the necessity of transport infrastructure, NPPF confirms that development should only be prevented or refused on highways grounds if there would be an unacceptable impact on highway safety, or the residual cumulative impacts on the road network would be severe. (para 111).
• Planning policies and decisions should support development that makes efficient use of land, taking into account the availability and capacity of infrastructure and services – both existing and proposed – as well as their potential for further improvement and the scope to promote sustainable travel modes that limit future car use. (para 124).
In relation to the tests of soundness set out at paragraph 35 of the NPPF, in the context of transport, these are interpreted as meaning:
a) Positively prepared - has the transport strategy been prepared with the active involvement of the highway authorities, other transport infrastructure providers and operators and neighbouring councils?
b) Justified – Is the transport strategy based on a robust evidence base prepared with the agreement in partnership, or with the support of the highway authorities?
c) Effective – Does the transport strategy and policy satisfy the transport needs of the plan and is it deliverable at a pace which provides for and accommodates the proposed progress and implementation of the plan?
d) Consistent with national policy – Does the transport strategy support the economic, social, and environmental objectives of the Plan and the NPPF/NPPG?
We will be concerned with proposals that have the potential to impact on the safe and efficient operation of the SRN; in this case, the A27 trunk road (Chichester Bypass and its junctions) which is the main access route in the Chichester area. We have particular interest in any allocation, policy or proposals which could have implications for the A27 and the wider SRN network. We are interested as to whether there would be any adverse road safety or operational implications for the SRN. The latter would include a material increase in queueing or delay or reduction in journey time reliability during the construction or operation of the development set out in the plan.
National Highways is a key delivery partner for sustainable development promoted through the plan-led system, and as a statutory consultee we have a duty to cooperate with local authorities to support the preparation and implementation of development plan documents.
In accordance with national planning and transport policy and our operating licence, we are entirely neutral on the principle of development as it is for the local planning authority to determine whether development should be allocated or permitted; albeit it must comply with national policy on locating development in locations that are or can be made sustainable. Therefore, while always seeking early and fulsome engagement with local plans and/or developers, we will simply be assessing the transport and related implications of plans or proposals and agreeing any necessary transport improvements and relevant development management policy.
In progressing Local Plans, we will seek to agree the following:
• Assessment tools and methodology
• Baseline Assessment i.e., to demonstrate that the assessment tool accurately reflects current transport conditions
• Comparator case assessment i.e., to forecast the transport conditions that would occur in the absence of the plan
• Forecast modelling i.e., to forecast the transport conditions that would arise with the plan in place, this will include an assessment at the end of the Plan period; and, if required, at full build out if that occurs after the end of the Plan period
• Outputs and outcomes of modelling, demonstrating, as appropriate, what transport infrastructure is necessary to support the plan o It should be noted that a suite of transport modelling tools may be required. This includes strategic modelling covering an area at least one major junction beyond the district boundary, localised network modelling where several links/junctions are close together and/or individual junction modelling
o A DMRB (Design Manual for Roads and Bridges) compliancy assessment may also be required for certain highway features, such as
Merge/Diverge assessment at Grade separated junctions, link capacity assessments, and others.
• The design of any necessary transport infrastructure, to an extent suitable for establishing deliverability during the plan period at the time that it becomes necessary for the purpose of ensuring that unacceptable road safety impacts or severe operational impacts do not arise as a result of development. This may be to at least General Arrangement design stage or preliminary design stage. Whichever degree of detail is agreed, the products must be in full compliance with the DMRB.
• Industry standard transport intervention costings.
• The delivery/funding mechanisms for necessary transport interventions. It should not be assumed that National Highways will have any responsibility to identify or deliver necessary transport interventions.
• If considered appropriate, a “Monitor & Manage” (M&M) framework, aimed at managing the pace of development in line with the pace of funding and delivery of necessary highway interventions in a manner which responds to the realworld impacts of development may be agreed for inclusion in the plan subject to the adequacy of risk control measures included therein. This can include the move from a ‘predict & provide’ style of delivery to ‘a vision & validate’ style. o Any M&M framework must be based on a “worst case scenario” whereby necessary mitigation is understood, as well as setting out the desired alternative scenario. It must set out details of responsibility, funding and governance of the framework together with the methodology for determining the timing for any mitigation delivery while remaining clear on the fallback position where identified mitigation or desired alternatives are not ultimately achievable. It must be translated into development management plan policy and policy relating to development allocations.
Further detail on the above can be provided by National Highways.
While ideally all the above should be agreed prior to the Submission of the Local Plan for examination, we recognise that this is not always possible. However, all parties should work towards all matters being agreed and reflected in a Statement of Common Ground (SoCG) by the start of the Local Plan Examination at the latest. Ideally the SoCG between the Council and National Highways would be prepared well in advance of plan submission in order to guide resource input and to track progress towards final agreement on all relevant matters starting from the earliest plan iterations until the final version is agreed.
It is acknowledged that Government policy places much emphasis on housing delivery as a means for ensuring economic growth and addressing the current national shortage of housing. The NPPF is very clear that:
“Strategic policy-making authorities should establish a housing requirement figure for their whole area, which shows the extent to which their identified housing need (and any needs that cannot be met within neighbouring areas) can be met over the plan period.”
However, new DfT C1/22 and the NPPF are equally clear that any development, including housing delivery, must be tempered by the requirement to ensure that the associated transport demand can be accommodated without unacceptable impacts on the safety of the SRN or severe impacts on the operation of the SRN including reliability and congestion. Therefore, as necessary and appropriate, any plan and/or development must be accompanied by suitable mitigation in the right places at the right time, that is to the required design standards and is deliverable in terms of land availability, constructability and funding.
We would also draw your attention to the then Highways England document ‘The Strategic Road Network, Planning for the Future: A guide to working with National
Highways on planning matters’ (September 2015). This document sets out how National Highways intends to work with local planning authorities and developers to support the preparation of sound documents which enable the delivery of sustainable development. https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachmen t_data/file/461023/N150227_-_Highways_England_Planning_Document_FINAL-lo.pdf
Responses to Local Plan consultations are also guided by National Planning Policy Framework (NPPF) revised on 20 July 2021 which sets out the government’s planning policies for England and how these are expected to be applied.
Updated Circular (01/2022)
It should be noted that since the start of the Local Plan consultation process, on the 23 December 2022, the Department for Transport released a new circular on the ‘Strategic road network and the delivery of sustainable development’ (Circular 01/2022), which replaces all of the policies in Circular 02/2013 of the same name. These representations take account of the new circular and the requirements in terms of the Local Plan evidence base and process.
We request that the Local Plan is prepared in line with all aspects of the new circular. Particularly, the principles of sustainable development (paragraphs 11 to 17), new connections and capacity enhancements (paragraphs 18 to 25), and engagement with plan-making (paragraphs 26 to 38).
Regulation 18 submission
In our Regulation 18 submission we noted several matters including:
• The need to mitigate the adverse impacts of strategic development traffic to the A27 Chichester Bypass and its junctions at Portfield Roundabout, Bognor Road Roundabout, Whyke Roundabout, Stockbridge Roundabout and Fishbourne Roundabout and Oving junction.
• The need to identify a mechanism to calculate contributions towards the delivery of the previously agreed Local Plan A27 improvements
• The need to confirm the number of dwellings needed within the plan period
• The need to establish National Highways acceptance of the traffic model reference and future case scenarios
• The need to confirm costs, viability, and funding associated with mitigating the safety and congestion impacts of the development included within the plan.
Local Plan context
This Local Plan (Chichester Local Plan 2021 – 2039), prepared by the Local Planning Authority (LPA) Chichester District Council, sets out the vision for future development in the district and will be used to help decide on planning applications and other planning related decisions including shaping infrastructure investments.
The draft sets out how the district should be developed over the next 18-years to 2039 including for the full Plan period (1 April 2021 to 31 March 2039) the total supply of
- 10,359 dwellings
- 114,652 net additional sqm new floorspace
Minus the completions this is equivalent to around 530 dwellings and 6,150 sqm of floorspace a year.
National Highways Representations
To date National Highways have worked collaboratively with Chichester District Council (the Council) and West Sussex County Council (WSCC) and we will continue to work with the Council and other key stakeholders.
We have undertaken a review of the Chichester Local Plan 2021-2039 proposed submission version and accompanying evidence documents, our comments are set out in the tables below (following pages). [see table within attachment]
Summary
We have reviewed the publicly available Local Plan documents and provided comments above in relation to the transport implications of the plan for the safety and operation of the SRN. We understand that other technical information is available, but this was not presented as part of this consultation.
Chichester, and the A27, are already heavily congested, infrastructure in the existing Local Plan remains undelivered and the growth set out in the new Plan will further increase travel demand.
As presented, satisfying the transport needs of the plan is clearly reliant on the delivery of the A27 Chichester bypass improvements project. The A27 Chichester bypass improvements project is one of 32 pipeline schemes being considered for possible inclusion in National Highways third Road Investment Strategy (RIS3) covering 1 April 2025 to 31 March 2030.
On 9 March 2023 the UK Transport Secretary ensured record funding would be invested in the country’s transport network, sustainably driving growth across the country while managing the pressures of inflation. The announcement cited the A27 Arundel Bypass as being deferred from RIS2 to RIS 3 (covering 2025-2030). The transport secretary also identified a number of challenges to the delivery of the road investment strategy and cited the benefit of allowing extra time to ensure schemes are better planned and efficient schemes can be deployed more effectively.
At present, there is no commitment by DfT to carry out the A27 Chichester bypass improvements project. Until the A27 Chichester bypass improvements project is published in the RIS3, consented and a decision to invest is made it cannot be assumed to be a committed project.
We note that the Plan does not address any uncertainty of delivery of the A27 Chichester bypass improvements project and we strongly recommend that there is either no reliance placed on RIS3 to realise capacity for growth in the Plan or that contingency measures are included to cover the eventuality that RIS3 funding is not forthcoming within the plan period. It is not clear that the potential impact of development on transport networks can be addressed in the absence of the A27 Chichester bypass improvements project.
Achieving net zero, reducing emissions reduction, acting on climate, and supporting thousands of new homes and new employment developments will be problematic with existing processes. New, additional, and adapted processes and assessments will likely be required, especially in assessing Transport Assessments, mandating Travel Plans and monitoring traffic associated with new developments. We acknowledge that change is complex, expensive, and time-consuming, especially for smaller district level Councils. But the hard work will deliver benefits for the Council and residents in the longer-term.
National Highways seeks to continue working with the Council and WSCC to progress coordinated and deliverable packages of interim mitigation measures and alternative transport solutions while a long-term strategic solution is considered by government. This must however be in combination with a robust monitor and manage policy that appropriately manages the risk of unacceptable road impacts resulting from new housing
and other development over the Plan period.
We have been in discussion with Chichester District Council regarding their proposed Monitor and Manage Strategy. At present, we do not consider the current strategy to be robust and we seek further information and detail especially on who, when and when monitoring and management will be undertaken. Developments in the right places and served by the right sustainable infrastructure delivered alongside or ahead of occupancy must be a key consideration when planning for growth in all local authority areas. Any M&M framework must be based on a “worst case scenario” whereby necessary transport mitigation is understood, as well as setting out the desired alternative scenario. It must set out details of responsibility, funding and governance of the framework together with the methodology for determining the timing for any mitigation delivery while remaining clear on the fallback position where identified mitigation or desired alternatives are not ultimately achievable. The M&M framework must set out that the alternative to mitigation not being delivered is that development does not proceed where that development would give rise to unacceptable road safety risk or severe cumulative impacts on the road network in the absence of that mitigation. The M&M framework must be translated into development management plan policy and policy relating to development allocations.
As we have reiterated throughout our comments, we welcome the opportunity to work with you to address these outstanding matters and we will continue to liaise over submitted Transport Assessment, Travel Plan policy and Monitor and Manage Policy to help to work towards a viable plan.
We hope our comments assist.
We look forward to continuing to participate in future consultations and discussions. Please do continue to consult us as the Plan progresses so that we can remain aware of, and comment as required on, its contents.
Once you have had the opportunity to digest all the representations received, we would welcome a meeting to run through all the transport related matters and agree how to progress any required evidence gathering or other work.
Attachments:
- Written representation (356.49 KB)
Support noted
Object
Chichester Local Plan 2021 - 2039: Proposed Submission
Policy P17 New and Existing Local and Community Facilities including Local Shops
Representation ID: 5305
Received: 16/03/2023
Respondent: National Highways
Legally compliant? Not specified
Sound? Not specified
Duty to co-operate? Not specified
[National Highways letter dated 24/07/23 confirmed representation should be categorised as Issues to resolve.] We can’t assume that only housing and employment sites generate trips. Every trip has an origin and a destination. Furthermore, trip attractors and diversions to key destinations need to be considered.
Community Facilities such as medical centres, social classes in community run facilities, community childcare venues e.g., creche/toddler groups and libraries are busy in the am and pm peak and the offpeak. Realistically people are typically unlikely to walk or cycle to a medical appointment or to a childcare group.
We seek further information on how the Council intends to assess how new or improved community facilities will demonstrate they have no adverse traffic generation effects.
We have reviewed the publicly available Local Plan documents and provided comments in the attached letter, in relation to the transport implications of the plan for the safety and operation of the SRN.
Our comments include issues to resolve, comments, requests for further information and recommendations. A brief summary of our main comments are:
- the reliance on the delivery of the A27 Chichester bypass improvements project.
- the requirements for new, additional, and adapted processes and assessments, especially in assessing Transport Assessments, mandating Travel Plans and monitoring traffic associated with new developments.
- collaborative working between agencies in combination with a robust monitor and manage policy.
We hope our comments assist.
To date National Highways have worked collaboratively with Chichester District Council (the Council) and West Sussex County Council (WSCC) and we will continue to work with the Council and other key stakeholders. We look forward to continuing to participate in future consultations and discussions.
Once you have had the opportunity to digest all the representations received, we would welcome a meeting to run through all the transport related matters and agree how to progress any required evidence gathering or other work.
Background
National Highways has been appointed by the Secretary of State for Transport as strategic highway company under the provisions of the Infrastructure Act 2015 and is the highway authority, traffic authority and street authority for the strategic road network (SRN).
National Highways is responsible for operating, maintaining, and improving the Strategic Road Network (SRN) i.e., the Trunk Road and Motorway Network in England, as laid down in Department for Transport (DfT) Circular 01/2022 (Strategic Road Network and the delivery of sustainable development).
The SRN is a critical national asset and as such we work to ensure that it operates and is managed in the public interest, both in respect of current activities and needs as well as in providing effective stewardship of its long-term operation and integrity.
Our responses to Local Plan consultations are guided by relevant policy and guidance including the National Planning Policy Framework (2021) (NPPF):
• Transport issues should be considered from the earliest stages of plan-making and development proposals so that the potential impact of development on transport networks can be addressed (para 104).
• The planning system should actively manage patterns of growth such that significant development is focused on locations which are or can be made sustainable, through limiting the need to travel and offering a genuine choice of transport modes. (para 105).
• Planning policies should be prepared with the active involvement of highways authorities and other transport infrastructure providers so that strategies and investments for supporting sustainable transport and development patterns are aligned. (para 106).
• In terms of identifying the necessity of transport infrastructure, NPPF confirms that development should only be prevented or refused on highways grounds if there would be an unacceptable impact on highway safety, or the residual cumulative impacts on the road network would be severe. (para 111).
• Planning policies and decisions should support development that makes efficient use of land, taking into account the availability and capacity of infrastructure and services – both existing and proposed – as well as their potential for further improvement and the scope to promote sustainable travel modes that limit future car use. (para 124).
In relation to the tests of soundness set out at paragraph 35 of the NPPF, in the context of transport, these are interpreted as meaning:
a) Positively prepared - has the transport strategy been prepared with the active involvement of the highway authorities, other transport infrastructure providers and operators and neighbouring councils?
b) Justified – Is the transport strategy based on a robust evidence base prepared with the agreement in partnership, or with the support of the highway authorities?
c) Effective – Does the transport strategy and policy satisfy the transport needs of the plan and is it deliverable at a pace which provides for and accommodates the proposed progress and implementation of the plan?
d) Consistent with national policy – Does the transport strategy support the economic, social, and environmental objectives of the Plan and the NPPF/NPPG?
We will be concerned with proposals that have the potential to impact on the safe and efficient operation of the SRN; in this case, the A27 trunk road (Chichester Bypass and its junctions) which is the main access route in the Chichester area. We have particular interest in any allocation, policy or proposals which could have implications for the A27 and the wider SRN network. We are interested as to whether there would be any adverse road safety or operational implications for the SRN. The latter would include a material increase in queueing or delay or reduction in journey time reliability during the construction or operation of the development set out in the plan.
National Highways is a key delivery partner for sustainable development promoted through the plan-led system, and as a statutory consultee we have a duty to cooperate with local authorities to support the preparation and implementation of development plan documents.
In accordance with national planning and transport policy and our operating licence, we are entirely neutral on the principle of development as it is for the local planning authority to determine whether development should be allocated or permitted; albeit it must comply with national policy on locating development in locations that are or can be made sustainable. Therefore, while always seeking early and fulsome engagement with local plans and/or developers, we will simply be assessing the transport and related implications of plans or proposals and agreeing any necessary transport improvements and relevant development management policy.
In progressing Local Plans, we will seek to agree the following:
• Assessment tools and methodology
• Baseline Assessment i.e., to demonstrate that the assessment tool accurately reflects current transport conditions
• Comparator case assessment i.e., to forecast the transport conditions that would occur in the absence of the plan
• Forecast modelling i.e., to forecast the transport conditions that would arise with the plan in place, this will include an assessment at the end of the Plan period; and, if required, at full build out if that occurs after the end of the Plan period
• Outputs and outcomes of modelling, demonstrating, as appropriate, what transport infrastructure is necessary to support the plan o It should be noted that a suite of transport modelling tools may be required. This includes strategic modelling covering an area at least one major junction beyond the district boundary, localised network modelling where several links/junctions are close together and/or individual junction modelling
o A DMRB (Design Manual for Roads and Bridges) compliancy assessment may also be required for certain highway features, such as
Merge/Diverge assessment at Grade separated junctions, link capacity assessments, and others.
• The design of any necessary transport infrastructure, to an extent suitable for establishing deliverability during the plan period at the time that it becomes necessary for the purpose of ensuring that unacceptable road safety impacts or severe operational impacts do not arise as a result of development. This may be to at least General Arrangement design stage or preliminary design stage. Whichever degree of detail is agreed, the products must be in full compliance with the DMRB.
• Industry standard transport intervention costings.
• The delivery/funding mechanisms for necessary transport interventions. It should not be assumed that National Highways will have any responsibility to identify or deliver necessary transport interventions.
• If considered appropriate, a “Monitor & Manage” (M&M) framework, aimed at managing the pace of development in line with the pace of funding and delivery of necessary highway interventions in a manner which responds to the realworld impacts of development may be agreed for inclusion in the plan subject to the adequacy of risk control measures included therein. This can include the move from a ‘predict & provide’ style of delivery to ‘a vision & validate’ style. o Any M&M framework must be based on a “worst case scenario” whereby necessary mitigation is understood, as well as setting out the desired alternative scenario. It must set out details of responsibility, funding and governance of the framework together with the methodology for determining the timing for any mitigation delivery while remaining clear on the fallback position where identified mitigation or desired alternatives are not ultimately achievable. It must be translated into development management plan policy and policy relating to development allocations.
Further detail on the above can be provided by National Highways.
While ideally all the above should be agreed prior to the Submission of the Local Plan for examination, we recognise that this is not always possible. However, all parties should work towards all matters being agreed and reflected in a Statement of Common Ground (SoCG) by the start of the Local Plan Examination at the latest. Ideally the SoCG between the Council and National Highways would be prepared well in advance of plan submission in order to guide resource input and to track progress towards final agreement on all relevant matters starting from the earliest plan iterations until the final version is agreed.
It is acknowledged that Government policy places much emphasis on housing delivery as a means for ensuring economic growth and addressing the current national shortage of housing. The NPPF is very clear that:
“Strategic policy-making authorities should establish a housing requirement figure for their whole area, which shows the extent to which their identified housing need (and any needs that cannot be met within neighbouring areas) can be met over the plan period.”
However, new DfT C1/22 and the NPPF are equally clear that any development, including housing delivery, must be tempered by the requirement to ensure that the associated transport demand can be accommodated without unacceptable impacts on the safety of the SRN or severe impacts on the operation of the SRN including reliability and congestion. Therefore, as necessary and appropriate, any plan and/or development must be accompanied by suitable mitigation in the right places at the right time, that is to the required design standards and is deliverable in terms of land availability, constructability and funding.
We would also draw your attention to the then Highways England document ‘The Strategic Road Network, Planning for the Future: A guide to working with National
Highways on planning matters’ (September 2015). This document sets out how National Highways intends to work with local planning authorities and developers to support the preparation of sound documents which enable the delivery of sustainable development. https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachmen t_data/file/461023/N150227_-_Highways_England_Planning_Document_FINAL-lo.pdf
Responses to Local Plan consultations are also guided by National Planning Policy Framework (NPPF) revised on 20 July 2021 which sets out the government’s planning policies for England and how these are expected to be applied.
Updated Circular (01/2022)
It should be noted that since the start of the Local Plan consultation process, on the 23 December 2022, the Department for Transport released a new circular on the ‘Strategic road network and the delivery of sustainable development’ (Circular 01/2022), which replaces all of the policies in Circular 02/2013 of the same name. These representations take account of the new circular and the requirements in terms of the Local Plan evidence base and process.
We request that the Local Plan is prepared in line with all aspects of the new circular. Particularly, the principles of sustainable development (paragraphs 11 to 17), new connections and capacity enhancements (paragraphs 18 to 25), and engagement with plan-making (paragraphs 26 to 38).
Regulation 18 submission
In our Regulation 18 submission we noted several matters including:
• The need to mitigate the adverse impacts of strategic development traffic to the A27 Chichester Bypass and its junctions at Portfield Roundabout, Bognor Road Roundabout, Whyke Roundabout, Stockbridge Roundabout and Fishbourne Roundabout and Oving junction.
• The need to identify a mechanism to calculate contributions towards the delivery of the previously agreed Local Plan A27 improvements
• The need to confirm the number of dwellings needed within the plan period
• The need to establish National Highways acceptance of the traffic model reference and future case scenarios
• The need to confirm costs, viability, and funding associated with mitigating the safety and congestion impacts of the development included within the plan.
Local Plan context
This Local Plan (Chichester Local Plan 2021 – 2039), prepared by the Local Planning Authority (LPA) Chichester District Council, sets out the vision for future development in the district and will be used to help decide on planning applications and other planning related decisions including shaping infrastructure investments.
The draft sets out how the district should be developed over the next 18-years to 2039 including for the full Plan period (1 April 2021 to 31 March 2039) the total supply of
- 10,359 dwellings
- 114,652 net additional sqm new floorspace
Minus the completions this is equivalent to around 530 dwellings and 6,150 sqm of floorspace a year.
National Highways Representations
To date National Highways have worked collaboratively with Chichester District Council (the Council) and West Sussex County Council (WSCC) and we will continue to work with the Council and other key stakeholders.
We have undertaken a review of the Chichester Local Plan 2021-2039 proposed submission version and accompanying evidence documents, our comments are set out in the tables below (following pages). [see table within attachment]
Summary
We have reviewed the publicly available Local Plan documents and provided comments above in relation to the transport implications of the plan for the safety and operation of the SRN. We understand that other technical information is available, but this was not presented as part of this consultation.
Chichester, and the A27, are already heavily congested, infrastructure in the existing Local Plan remains undelivered and the growth set out in the new Plan will further increase travel demand.
As presented, satisfying the transport needs of the plan is clearly reliant on the delivery of the A27 Chichester bypass improvements project. The A27 Chichester bypass improvements project is one of 32 pipeline schemes being considered for possible inclusion in National Highways third Road Investment Strategy (RIS3) covering 1 April 2025 to 31 March 2030.
On 9 March 2023 the UK Transport Secretary ensured record funding would be invested in the country’s transport network, sustainably driving growth across the country while managing the pressures of inflation. The announcement cited the A27 Arundel Bypass as being deferred from RIS2 to RIS 3 (covering 2025-2030). The transport secretary also identified a number of challenges to the delivery of the road investment strategy and cited the benefit of allowing extra time to ensure schemes are better planned and efficient schemes can be deployed more effectively.
At present, there is no commitment by DfT to carry out the A27 Chichester bypass improvements project. Until the A27 Chichester bypass improvements project is published in the RIS3, consented and a decision to invest is made it cannot be assumed to be a committed project.
We note that the Plan does not address any uncertainty of delivery of the A27 Chichester bypass improvements project and we strongly recommend that there is either no reliance placed on RIS3 to realise capacity for growth in the Plan or that contingency measures are included to cover the eventuality that RIS3 funding is not forthcoming within the plan period. It is not clear that the potential impact of development on transport networks can be addressed in the absence of the A27 Chichester bypass improvements project.
Achieving net zero, reducing emissions reduction, acting on climate, and supporting thousands of new homes and new employment developments will be problematic with existing processes. New, additional, and adapted processes and assessments will likely be required, especially in assessing Transport Assessments, mandating Travel Plans and monitoring traffic associated with new developments. We acknowledge that change is complex, expensive, and time-consuming, especially for smaller district level Councils. But the hard work will deliver benefits for the Council and residents in the longer-term.
National Highways seeks to continue working with the Council and WSCC to progress coordinated and deliverable packages of interim mitigation measures and alternative transport solutions while a long-term strategic solution is considered by government. This must however be in combination with a robust monitor and manage policy that appropriately manages the risk of unacceptable road impacts resulting from new housing
and other development over the Plan period.
We have been in discussion with Chichester District Council regarding their proposed Monitor and Manage Strategy. At present, we do not consider the current strategy to be robust and we seek further information and detail especially on who, when and when monitoring and management will be undertaken. Developments in the right places and served by the right sustainable infrastructure delivered alongside or ahead of occupancy must be a key consideration when planning for growth in all local authority areas. Any M&M framework must be based on a “worst case scenario” whereby necessary transport mitigation is understood, as well as setting out the desired alternative scenario. It must set out details of responsibility, funding and governance of the framework together with the methodology for determining the timing for any mitigation delivery while remaining clear on the fallback position where identified mitigation or desired alternatives are not ultimately achievable. The M&M framework must set out that the alternative to mitigation not being delivered is that development does not proceed where that development would give rise to unacceptable road safety risk or severe cumulative impacts on the road network in the absence of that mitigation. The M&M framework must be translated into development management plan policy and policy relating to development allocations.
As we have reiterated throughout our comments, we welcome the opportunity to work with you to address these outstanding matters and we will continue to liaise over submitted Transport Assessment, Travel Plan policy and Monitor and Manage Policy to help to work towards a viable plan.
We hope our comments assist.
We look forward to continuing to participate in future consultations and discussions. Please do continue to consult us as the Plan progresses so that we can remain aware of, and comment as required on, its contents.
Once you have had the opportunity to digest all the representations received, we would welcome a meeting to run through all the transport related matters and agree how to progress any required evidence gathering or other work.
Attachments:
- Written representation (356.49 KB)
This is covered by Policy T2, which refers to all development proposals which are likely to result in significant transport impacts needing to be supported by a transport assessment and travel plan
Support
Chichester Local Plan 2021 - 2039: Proposed Submission
Policy E4 Horticultural Development
Representation ID: 5306
Received: 16/03/2023
Respondent: National Highways
[National Highways letter dated 24/07/23 confirmed representation should be categorised as Comment - Supporting collaborative working.] National Highways welcomes the opportunity to work with you on large, and smaller scale, horticultural developments particularly heavy goods vehicles access onto the A27 and accommodating vehicle movements on the SRN without detriment to highway safety.
The Future of Freight Plan sets out that a joined-up approach between the planning system, local authorities and industry can safeguard and prioritise the land needed for freight and logistics sector uses and their specific requirements.
Impacts arising from such developments and the funding of transport infrastructure modifications should be fully assessed at the planning application stage.
We have reviewed the publicly available Local Plan documents and provided comments in the attached letter, in relation to the transport implications of the plan for the safety and operation of the SRN.
Our comments include issues to resolve, comments, requests for further information and recommendations. A brief summary of our main comments are:
- the reliance on the delivery of the A27 Chichester bypass improvements project.
- the requirements for new, additional, and adapted processes and assessments, especially in assessing Transport Assessments, mandating Travel Plans and monitoring traffic associated with new developments.
- collaborative working between agencies in combination with a robust monitor and manage policy.
We hope our comments assist.
To date National Highways have worked collaboratively with Chichester District Council (the Council) and West Sussex County Council (WSCC) and we will continue to work with the Council and other key stakeholders. We look forward to continuing to participate in future consultations and discussions.
Once you have had the opportunity to digest all the representations received, we would welcome a meeting to run through all the transport related matters and agree how to progress any required evidence gathering or other work.
Background
National Highways has been appointed by the Secretary of State for Transport as strategic highway company under the provisions of the Infrastructure Act 2015 and is the highway authority, traffic authority and street authority for the strategic road network (SRN).
National Highways is responsible for operating, maintaining, and improving the Strategic Road Network (SRN) i.e., the Trunk Road and Motorway Network in England, as laid down in Department for Transport (DfT) Circular 01/2022 (Strategic Road Network and the delivery of sustainable development).
The SRN is a critical national asset and as such we work to ensure that it operates and is managed in the public interest, both in respect of current activities and needs as well as in providing effective stewardship of its long-term operation and integrity.
Our responses to Local Plan consultations are guided by relevant policy and guidance including the National Planning Policy Framework (2021) (NPPF):
• Transport issues should be considered from the earliest stages of plan-making and development proposals so that the potential impact of development on transport networks can be addressed (para 104).
• The planning system should actively manage patterns of growth such that significant development is focused on locations which are or can be made sustainable, through limiting the need to travel and offering a genuine choice of transport modes. (para 105).
• Planning policies should be prepared with the active involvement of highways authorities and other transport infrastructure providers so that strategies and investments for supporting sustainable transport and development patterns are aligned. (para 106).
• In terms of identifying the necessity of transport infrastructure, NPPF confirms that development should only be prevented or refused on highways grounds if there would be an unacceptable impact on highway safety, or the residual cumulative impacts on the road network would be severe. (para 111).
• Planning policies and decisions should support development that makes efficient use of land, taking into account the availability and capacity of infrastructure and services – both existing and proposed – as well as their potential for further improvement and the scope to promote sustainable travel modes that limit future car use. (para 124).
In relation to the tests of soundness set out at paragraph 35 of the NPPF, in the context of transport, these are interpreted as meaning:
a) Positively prepared - has the transport strategy been prepared with the active involvement of the highway authorities, other transport infrastructure providers and operators and neighbouring councils?
b) Justified – Is the transport strategy based on a robust evidence base prepared with the agreement in partnership, or with the support of the highway authorities?
c) Effective – Does the transport strategy and policy satisfy the transport needs of the plan and is it deliverable at a pace which provides for and accommodates the proposed progress and implementation of the plan?
d) Consistent with national policy – Does the transport strategy support the economic, social, and environmental objectives of the Plan and the NPPF/NPPG?
We will be concerned with proposals that have the potential to impact on the safe and efficient operation of the SRN; in this case, the A27 trunk road (Chichester Bypass and its junctions) which is the main access route in the Chichester area. We have particular interest in any allocation, policy or proposals which could have implications for the A27 and the wider SRN network. We are interested as to whether there would be any adverse road safety or operational implications for the SRN. The latter would include a material increase in queueing or delay or reduction in journey time reliability during the construction or operation of the development set out in the plan.
National Highways is a key delivery partner for sustainable development promoted through the plan-led system, and as a statutory consultee we have a duty to cooperate with local authorities to support the preparation and implementation of development plan documents.
In accordance with national planning and transport policy and our operating licence, we are entirely neutral on the principle of development as it is for the local planning authority to determine whether development should be allocated or permitted; albeit it must comply with national policy on locating development in locations that are or can be made sustainable. Therefore, while always seeking early and fulsome engagement with local plans and/or developers, we will simply be assessing the transport and related implications of plans or proposals and agreeing any necessary transport improvements and relevant development management policy.
In progressing Local Plans, we will seek to agree the following:
• Assessment tools and methodology
• Baseline Assessment i.e., to demonstrate that the assessment tool accurately reflects current transport conditions
• Comparator case assessment i.e., to forecast the transport conditions that would occur in the absence of the plan
• Forecast modelling i.e., to forecast the transport conditions that would arise with the plan in place, this will include an assessment at the end of the Plan period; and, if required, at full build out if that occurs after the end of the Plan period
• Outputs and outcomes of modelling, demonstrating, as appropriate, what transport infrastructure is necessary to support the plan o It should be noted that a suite of transport modelling tools may be required. This includes strategic modelling covering an area at least one major junction beyond the district boundary, localised network modelling where several links/junctions are close together and/or individual junction modelling
o A DMRB (Design Manual for Roads and Bridges) compliancy assessment may also be required for certain highway features, such as
Merge/Diverge assessment at Grade separated junctions, link capacity assessments, and others.
• The design of any necessary transport infrastructure, to an extent suitable for establishing deliverability during the plan period at the time that it becomes necessary for the purpose of ensuring that unacceptable road safety impacts or severe operational impacts do not arise as a result of development. This may be to at least General Arrangement design stage or preliminary design stage. Whichever degree of detail is agreed, the products must be in full compliance with the DMRB.
• Industry standard transport intervention costings.
• The delivery/funding mechanisms for necessary transport interventions. It should not be assumed that National Highways will have any responsibility to identify or deliver necessary transport interventions.
• If considered appropriate, a “Monitor & Manage” (M&M) framework, aimed at managing the pace of development in line with the pace of funding and delivery of necessary highway interventions in a manner which responds to the realworld impacts of development may be agreed for inclusion in the plan subject to the adequacy of risk control measures included therein. This can include the move from a ‘predict & provide’ style of delivery to ‘a vision & validate’ style. o Any M&M framework must be based on a “worst case scenario” whereby necessary mitigation is understood, as well as setting out the desired alternative scenario. It must set out details of responsibility, funding and governance of the framework together with the methodology for determining the timing for any mitigation delivery while remaining clear on the fallback position where identified mitigation or desired alternatives are not ultimately achievable. It must be translated into development management plan policy and policy relating to development allocations.
Further detail on the above can be provided by National Highways.
While ideally all the above should be agreed prior to the Submission of the Local Plan for examination, we recognise that this is not always possible. However, all parties should work towards all matters being agreed and reflected in a Statement of Common Ground (SoCG) by the start of the Local Plan Examination at the latest. Ideally the SoCG between the Council and National Highways would be prepared well in advance of plan submission in order to guide resource input and to track progress towards final agreement on all relevant matters starting from the earliest plan iterations until the final version is agreed.
It is acknowledged that Government policy places much emphasis on housing delivery as a means for ensuring economic growth and addressing the current national shortage of housing. The NPPF is very clear that:
“Strategic policy-making authorities should establish a housing requirement figure for their whole area, which shows the extent to which their identified housing need (and any needs that cannot be met within neighbouring areas) can be met over the plan period.”
However, new DfT C1/22 and the NPPF are equally clear that any development, including housing delivery, must be tempered by the requirement to ensure that the associated transport demand can be accommodated without unacceptable impacts on the safety of the SRN or severe impacts on the operation of the SRN including reliability and congestion. Therefore, as necessary and appropriate, any plan and/or development must be accompanied by suitable mitigation in the right places at the right time, that is to the required design standards and is deliverable in terms of land availability, constructability and funding.
We would also draw your attention to the then Highways England document ‘The Strategic Road Network, Planning for the Future: A guide to working with National
Highways on planning matters’ (September 2015). This document sets out how National Highways intends to work with local planning authorities and developers to support the preparation of sound documents which enable the delivery of sustainable development. https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachmen t_data/file/461023/N150227_-_Highways_England_Planning_Document_FINAL-lo.pdf
Responses to Local Plan consultations are also guided by National Planning Policy Framework (NPPF) revised on 20 July 2021 which sets out the government’s planning policies for England and how these are expected to be applied.
Updated Circular (01/2022)
It should be noted that since the start of the Local Plan consultation process, on the 23 December 2022, the Department for Transport released a new circular on the ‘Strategic road network and the delivery of sustainable development’ (Circular 01/2022), which replaces all of the policies in Circular 02/2013 of the same name. These representations take account of the new circular and the requirements in terms of the Local Plan evidence base and process.
We request that the Local Plan is prepared in line with all aspects of the new circular. Particularly, the principles of sustainable development (paragraphs 11 to 17), new connections and capacity enhancements (paragraphs 18 to 25), and engagement with plan-making (paragraphs 26 to 38).
Regulation 18 submission
In our Regulation 18 submission we noted several matters including:
• The need to mitigate the adverse impacts of strategic development traffic to the A27 Chichester Bypass and its junctions at Portfield Roundabout, Bognor Road Roundabout, Whyke Roundabout, Stockbridge Roundabout and Fishbourne Roundabout and Oving junction.
• The need to identify a mechanism to calculate contributions towards the delivery of the previously agreed Local Plan A27 improvements
• The need to confirm the number of dwellings needed within the plan period
• The need to establish National Highways acceptance of the traffic model reference and future case scenarios
• The need to confirm costs, viability, and funding associated with mitigating the safety and congestion impacts of the development included within the plan.
Local Plan context
This Local Plan (Chichester Local Plan 2021 – 2039), prepared by the Local Planning Authority (LPA) Chichester District Council, sets out the vision for future development in the district and will be used to help decide on planning applications and other planning related decisions including shaping infrastructure investments.
The draft sets out how the district should be developed over the next 18-years to 2039 including for the full Plan period (1 April 2021 to 31 March 2039) the total supply of
- 10,359 dwellings
- 114,652 net additional sqm new floorspace
Minus the completions this is equivalent to around 530 dwellings and 6,150 sqm of floorspace a year.
National Highways Representations
To date National Highways have worked collaboratively with Chichester District Council (the Council) and West Sussex County Council (WSCC) and we will continue to work with the Council and other key stakeholders.
We have undertaken a review of the Chichester Local Plan 2021-2039 proposed submission version and accompanying evidence documents, our comments are set out in the tables below (following pages). [see table within attachment]
Summary
We have reviewed the publicly available Local Plan documents and provided comments above in relation to the transport implications of the plan for the safety and operation of the SRN. We understand that other technical information is available, but this was not presented as part of this consultation.
Chichester, and the A27, are already heavily congested, infrastructure in the existing Local Plan remains undelivered and the growth set out in the new Plan will further increase travel demand.
As presented, satisfying the transport needs of the plan is clearly reliant on the delivery of the A27 Chichester bypass improvements project. The A27 Chichester bypass improvements project is one of 32 pipeline schemes being considered for possible inclusion in National Highways third Road Investment Strategy (RIS3) covering 1 April 2025 to 31 March 2030.
On 9 March 2023 the UK Transport Secretary ensured record funding would be invested in the country’s transport network, sustainably driving growth across the country while managing the pressures of inflation. The announcement cited the A27 Arundel Bypass as being deferred from RIS2 to RIS 3 (covering 2025-2030). The transport secretary also identified a number of challenges to the delivery of the road investment strategy and cited the benefit of allowing extra time to ensure schemes are better planned and efficient schemes can be deployed more effectively.
At present, there is no commitment by DfT to carry out the A27 Chichester bypass improvements project. Until the A27 Chichester bypass improvements project is published in the RIS3, consented and a decision to invest is made it cannot be assumed to be a committed project.
We note that the Plan does not address any uncertainty of delivery of the A27 Chichester bypass improvements project and we strongly recommend that there is either no reliance placed on RIS3 to realise capacity for growth in the Plan or that contingency measures are included to cover the eventuality that RIS3 funding is not forthcoming within the plan period. It is not clear that the potential impact of development on transport networks can be addressed in the absence of the A27 Chichester bypass improvements project.
Achieving net zero, reducing emissions reduction, acting on climate, and supporting thousands of new homes and new employment developments will be problematic with existing processes. New, additional, and adapted processes and assessments will likely be required, especially in assessing Transport Assessments, mandating Travel Plans and monitoring traffic associated with new developments. We acknowledge that change is complex, expensive, and time-consuming, especially for smaller district level Councils. But the hard work will deliver benefits for the Council and residents in the longer-term.
National Highways seeks to continue working with the Council and WSCC to progress coordinated and deliverable packages of interim mitigation measures and alternative transport solutions while a long-term strategic solution is considered by government. This must however be in combination with a robust monitor and manage policy that appropriately manages the risk of unacceptable road impacts resulting from new housing
and other development over the Plan period.
We have been in discussion with Chichester District Council regarding their proposed Monitor and Manage Strategy. At present, we do not consider the current strategy to be robust and we seek further information and detail especially on who, when and when monitoring and management will be undertaken. Developments in the right places and served by the right sustainable infrastructure delivered alongside or ahead of occupancy must be a key consideration when planning for growth in all local authority areas. Any M&M framework must be based on a “worst case scenario” whereby necessary transport mitigation is understood, as well as setting out the desired alternative scenario. It must set out details of responsibility, funding and governance of the framework together with the methodology for determining the timing for any mitigation delivery while remaining clear on the fallback position where identified mitigation or desired alternatives are not ultimately achievable. The M&M framework must set out that the alternative to mitigation not being delivered is that development does not proceed where that development would give rise to unacceptable road safety risk or severe cumulative impacts on the road network in the absence of that mitigation. The M&M framework must be translated into development management plan policy and policy relating to development allocations.
As we have reiterated throughout our comments, we welcome the opportunity to work with you to address these outstanding matters and we will continue to liaise over submitted Transport Assessment, Travel Plan policy and Monitor and Manage Policy to help to work towards a viable plan.
We hope our comments assist.
We look forward to continuing to participate in future consultations and discussions. Please do continue to consult us as the Plan progresses so that we can remain aware of, and comment as required on, its contents.
Once you have had the opportunity to digest all the representations received, we would welcome a meeting to run through all the transport related matters and agree how to progress any required evidence gathering or other work.
Attachments:
- Written representation (356.49 KB)
Support and comment noted
Object
Chichester Local Plan 2021 - 2039: Proposed Submission
Policy E5 Retail Strategy and New Development
Representation ID: 5307
Received: 16/03/2023
Respondent: National Highways
Legally compliant? Not specified
Sound? Not specified
Duty to co-operate? Not specified
[National Highways letter dated 24/07/23 confirmed representation should be categorised as Comment - Seeking further information on approach and monitoring.] National Highways support retail development and expansion within the existing areas and re-occupation of vacant floorspace. This support NPPF (para 86) stating that planning policies and decisions should support the role that town centres play at the heart of local communities, by taking a positive approach to their growth, management, and adaptation.
We seek further information on how servicing and customer traffic will be safely and conveniently accommodated by the surrounding road network will be monitored and if not safely and conveniently accommodated how the impacts will be managed and mitigated especially traffic generated in peak periods, for example weekends and Christmas.
We have reviewed the publicly available Local Plan documents and provided comments in the attached letter, in relation to the transport implications of the plan for the safety and operation of the SRN.
Our comments include issues to resolve, comments, requests for further information and recommendations. A brief summary of our main comments are:
- the reliance on the delivery of the A27 Chichester bypass improvements project.
- the requirements for new, additional, and adapted processes and assessments, especially in assessing Transport Assessments, mandating Travel Plans and monitoring traffic associated with new developments.
- collaborative working between agencies in combination with a robust monitor and manage policy.
We hope our comments assist.
To date National Highways have worked collaboratively with Chichester District Council (the Council) and West Sussex County Council (WSCC) and we will continue to work with the Council and other key stakeholders. We look forward to continuing to participate in future consultations and discussions.
Once you have had the opportunity to digest all the representations received, we would welcome a meeting to run through all the transport related matters and agree how to progress any required evidence gathering or other work.
Background
National Highways has been appointed by the Secretary of State for Transport as strategic highway company under the provisions of the Infrastructure Act 2015 and is the highway authority, traffic authority and street authority for the strategic road network (SRN).
National Highways is responsible for operating, maintaining, and improving the Strategic Road Network (SRN) i.e., the Trunk Road and Motorway Network in England, as laid down in Department for Transport (DfT) Circular 01/2022 (Strategic Road Network and the delivery of sustainable development).
The SRN is a critical national asset and as such we work to ensure that it operates and is managed in the public interest, both in respect of current activities and needs as well as in providing effective stewardship of its long-term operation and integrity.
Our responses to Local Plan consultations are guided by relevant policy and guidance including the National Planning Policy Framework (2021) (NPPF):
• Transport issues should be considered from the earliest stages of plan-making and development proposals so that the potential impact of development on transport networks can be addressed (para 104).
• The planning system should actively manage patterns of growth such that significant development is focused on locations which are or can be made sustainable, through limiting the need to travel and offering a genuine choice of transport modes. (para 105).
• Planning policies should be prepared with the active involvement of highways authorities and other transport infrastructure providers so that strategies and investments for supporting sustainable transport and development patterns are aligned. (para 106).
• In terms of identifying the necessity of transport infrastructure, NPPF confirms that development should only be prevented or refused on highways grounds if there would be an unacceptable impact on highway safety, or the residual cumulative impacts on the road network would be severe. (para 111).
• Planning policies and decisions should support development that makes efficient use of land, taking into account the availability and capacity of infrastructure and services – both existing and proposed – as well as their potential for further improvement and the scope to promote sustainable travel modes that limit future car use. (para 124).
In relation to the tests of soundness set out at paragraph 35 of the NPPF, in the context of transport, these are interpreted as meaning:
a) Positively prepared - has the transport strategy been prepared with the active involvement of the highway authorities, other transport infrastructure providers and operators and neighbouring councils?
b) Justified – Is the transport strategy based on a robust evidence base prepared with the agreement in partnership, or with the support of the highway authorities?
c) Effective – Does the transport strategy and policy satisfy the transport needs of the plan and is it deliverable at a pace which provides for and accommodates the proposed progress and implementation of the plan?
d) Consistent with national policy – Does the transport strategy support the economic, social, and environmental objectives of the Plan and the NPPF/NPPG?
We will be concerned with proposals that have the potential to impact on the safe and efficient operation of the SRN; in this case, the A27 trunk road (Chichester Bypass and its junctions) which is the main access route in the Chichester area. We have particular interest in any allocation, policy or proposals which could have implications for the A27 and the wider SRN network. We are interested as to whether there would be any adverse road safety or operational implications for the SRN. The latter would include a material increase in queueing or delay or reduction in journey time reliability during the construction or operation of the development set out in the plan.
National Highways is a key delivery partner for sustainable development promoted through the plan-led system, and as a statutory consultee we have a duty to cooperate with local authorities to support the preparation and implementation of development plan documents.
In accordance with national planning and transport policy and our operating licence, we are entirely neutral on the principle of development as it is for the local planning authority to determine whether development should be allocated or permitted; albeit it must comply with national policy on locating development in locations that are or can be made sustainable. Therefore, while always seeking early and fulsome engagement with local plans and/or developers, we will simply be assessing the transport and related implications of plans or proposals and agreeing any necessary transport improvements and relevant development management policy.
In progressing Local Plans, we will seek to agree the following:
• Assessment tools and methodology
• Baseline Assessment i.e., to demonstrate that the assessment tool accurately reflects current transport conditions
• Comparator case assessment i.e., to forecast the transport conditions that would occur in the absence of the plan
• Forecast modelling i.e., to forecast the transport conditions that would arise with the plan in place, this will include an assessment at the end of the Plan period; and, if required, at full build out if that occurs after the end of the Plan period
• Outputs and outcomes of modelling, demonstrating, as appropriate, what transport infrastructure is necessary to support the plan o It should be noted that a suite of transport modelling tools may be required. This includes strategic modelling covering an area at least one major junction beyond the district boundary, localised network modelling where several links/junctions are close together and/or individual junction modelling
o A DMRB (Design Manual for Roads and Bridges) compliancy assessment may also be required for certain highway features, such as
Merge/Diverge assessment at Grade separated junctions, link capacity assessments, and others.
• The design of any necessary transport infrastructure, to an extent suitable for establishing deliverability during the plan period at the time that it becomes necessary for the purpose of ensuring that unacceptable road safety impacts or severe operational impacts do not arise as a result of development. This may be to at least General Arrangement design stage or preliminary design stage. Whichever degree of detail is agreed, the products must be in full compliance with the DMRB.
• Industry standard transport intervention costings.
• The delivery/funding mechanisms for necessary transport interventions. It should not be assumed that National Highways will have any responsibility to identify or deliver necessary transport interventions.
• If considered appropriate, a “Monitor & Manage” (M&M) framework, aimed at managing the pace of development in line with the pace of funding and delivery of necessary highway interventions in a manner which responds to the realworld impacts of development may be agreed for inclusion in the plan subject to the adequacy of risk control measures included therein. This can include the move from a ‘predict & provide’ style of delivery to ‘a vision & validate’ style. o Any M&M framework must be based on a “worst case scenario” whereby necessary mitigation is understood, as well as setting out the desired alternative scenario. It must set out details of responsibility, funding and governance of the framework together with the methodology for determining the timing for any mitigation delivery while remaining clear on the fallback position where identified mitigation or desired alternatives are not ultimately achievable. It must be translated into development management plan policy and policy relating to development allocations.
Further detail on the above can be provided by National Highways.
While ideally all the above should be agreed prior to the Submission of the Local Plan for examination, we recognise that this is not always possible. However, all parties should work towards all matters being agreed and reflected in a Statement of Common Ground (SoCG) by the start of the Local Plan Examination at the latest. Ideally the SoCG between the Council and National Highways would be prepared well in advance of plan submission in order to guide resource input and to track progress towards final agreement on all relevant matters starting from the earliest plan iterations until the final version is agreed.
It is acknowledged that Government policy places much emphasis on housing delivery as a means for ensuring economic growth and addressing the current national shortage of housing. The NPPF is very clear that:
“Strategic policy-making authorities should establish a housing requirement figure for their whole area, which shows the extent to which their identified housing need (and any needs that cannot be met within neighbouring areas) can be met over the plan period.”
However, new DfT C1/22 and the NPPF are equally clear that any development, including housing delivery, must be tempered by the requirement to ensure that the associated transport demand can be accommodated without unacceptable impacts on the safety of the SRN or severe impacts on the operation of the SRN including reliability and congestion. Therefore, as necessary and appropriate, any plan and/or development must be accompanied by suitable mitigation in the right places at the right time, that is to the required design standards and is deliverable in terms of land availability, constructability and funding.
We would also draw your attention to the then Highways England document ‘The Strategic Road Network, Planning for the Future: A guide to working with National
Highways on planning matters’ (September 2015). This document sets out how National Highways intends to work with local planning authorities and developers to support the preparation of sound documents which enable the delivery of sustainable development. https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachmen t_data/file/461023/N150227_-_Highways_England_Planning_Document_FINAL-lo.pdf
Responses to Local Plan consultations are also guided by National Planning Policy Framework (NPPF) revised on 20 July 2021 which sets out the government’s planning policies for England and how these are expected to be applied.
Updated Circular (01/2022)
It should be noted that since the start of the Local Plan consultation process, on the 23 December 2022, the Department for Transport released a new circular on the ‘Strategic road network and the delivery of sustainable development’ (Circular 01/2022), which replaces all of the policies in Circular 02/2013 of the same name. These representations take account of the new circular and the requirements in terms of the Local Plan evidence base and process.
We request that the Local Plan is prepared in line with all aspects of the new circular. Particularly, the principles of sustainable development (paragraphs 11 to 17), new connections and capacity enhancements (paragraphs 18 to 25), and engagement with plan-making (paragraphs 26 to 38).
Regulation 18 submission
In our Regulation 18 submission we noted several matters including:
• The need to mitigate the adverse impacts of strategic development traffic to the A27 Chichester Bypass and its junctions at Portfield Roundabout, Bognor Road Roundabout, Whyke Roundabout, Stockbridge Roundabout and Fishbourne Roundabout and Oving junction.
• The need to identify a mechanism to calculate contributions towards the delivery of the previously agreed Local Plan A27 improvements
• The need to confirm the number of dwellings needed within the plan period
• The need to establish National Highways acceptance of the traffic model reference and future case scenarios
• The need to confirm costs, viability, and funding associated with mitigating the safety and congestion impacts of the development included within the plan.
Local Plan context
This Local Plan (Chichester Local Plan 2021 – 2039), prepared by the Local Planning Authority (LPA) Chichester District Council, sets out the vision for future development in the district and will be used to help decide on planning applications and other planning related decisions including shaping infrastructure investments.
The draft sets out how the district should be developed over the next 18-years to 2039 including for the full Plan period (1 April 2021 to 31 March 2039) the total supply of
- 10,359 dwellings
- 114,652 net additional sqm new floorspace
Minus the completions this is equivalent to around 530 dwellings and 6,150 sqm of floorspace a year.
National Highways Representations
To date National Highways have worked collaboratively with Chichester District Council (the Council) and West Sussex County Council (WSCC) and we will continue to work with the Council and other key stakeholders.
We have undertaken a review of the Chichester Local Plan 2021-2039 proposed submission version and accompanying evidence documents, our comments are set out in the tables below (following pages). [see table within attachment]
Summary
We have reviewed the publicly available Local Plan documents and provided comments above in relation to the transport implications of the plan for the safety and operation of the SRN. We understand that other technical information is available, but this was not presented as part of this consultation.
Chichester, and the A27, are already heavily congested, infrastructure in the existing Local Plan remains undelivered and the growth set out in the new Plan will further increase travel demand.
As presented, satisfying the transport needs of the plan is clearly reliant on the delivery of the A27 Chichester bypass improvements project. The A27 Chichester bypass improvements project is one of 32 pipeline schemes being considered for possible inclusion in National Highways third Road Investment Strategy (RIS3) covering 1 April 2025 to 31 March 2030.
On 9 March 2023 the UK Transport Secretary ensured record funding would be invested in the country’s transport network, sustainably driving growth across the country while managing the pressures of inflation. The announcement cited the A27 Arundel Bypass as being deferred from RIS2 to RIS 3 (covering 2025-2030). The transport secretary also identified a number of challenges to the delivery of the road investment strategy and cited the benefit of allowing extra time to ensure schemes are better planned and efficient schemes can be deployed more effectively.
At present, there is no commitment by DfT to carry out the A27 Chichester bypass improvements project. Until the A27 Chichester bypass improvements project is published in the RIS3, consented and a decision to invest is made it cannot be assumed to be a committed project.
We note that the Plan does not address any uncertainty of delivery of the A27 Chichester bypass improvements project and we strongly recommend that there is either no reliance placed on RIS3 to realise capacity for growth in the Plan or that contingency measures are included to cover the eventuality that RIS3 funding is not forthcoming within the plan period. It is not clear that the potential impact of development on transport networks can be addressed in the absence of the A27 Chichester bypass improvements project.
Achieving net zero, reducing emissions reduction, acting on climate, and supporting thousands of new homes and new employment developments will be problematic with existing processes. New, additional, and adapted processes and assessments will likely be required, especially in assessing Transport Assessments, mandating Travel Plans and monitoring traffic associated with new developments. We acknowledge that change is complex, expensive, and time-consuming, especially for smaller district level Councils. But the hard work will deliver benefits for the Council and residents in the longer-term.
National Highways seeks to continue working with the Council and WSCC to progress coordinated and deliverable packages of interim mitigation measures and alternative transport solutions while a long-term strategic solution is considered by government. This must however be in combination with a robust monitor and manage policy that appropriately manages the risk of unacceptable road impacts resulting from new housing
and other development over the Plan period.
We have been in discussion with Chichester District Council regarding their proposed Monitor and Manage Strategy. At present, we do not consider the current strategy to be robust and we seek further information and detail especially on who, when and when monitoring and management will be undertaken. Developments in the right places and served by the right sustainable infrastructure delivered alongside or ahead of occupancy must be a key consideration when planning for growth in all local authority areas. Any M&M framework must be based on a “worst case scenario” whereby necessary transport mitigation is understood, as well as setting out the desired alternative scenario. It must set out details of responsibility, funding and governance of the framework together with the methodology for determining the timing for any mitigation delivery while remaining clear on the fallback position where identified mitigation or desired alternatives are not ultimately achievable. The M&M framework must set out that the alternative to mitigation not being delivered is that development does not proceed where that development would give rise to unacceptable road safety risk or severe cumulative impacts on the road network in the absence of that mitigation. The M&M framework must be translated into development management plan policy and policy relating to development allocations.
As we have reiterated throughout our comments, we welcome the opportunity to work with you to address these outstanding matters and we will continue to liaise over submitted Transport Assessment, Travel Plan policy and Monitor and Manage Policy to help to work towards a viable plan.
We hope our comments assist.
We look forward to continuing to participate in future consultations and discussions. Please do continue to consult us as the Plan progresses so that we can remain aware of, and comment as required on, its contents.
Once you have had the opportunity to digest all the representations received, we would welcome a meeting to run through all the transport related matters and agree how to progress any required evidence gathering or other work.
Attachments:
- Written representation (356.49 KB)
Support noted.
Any planning application will consider the transport implications arising from any proposed development or redevelopment.
