Chichester Local Plan 2021 - 2039: Proposed Submission

Various areas of transport study require revisiting - see full submission/attachments.

The comments included below from WSCC are Holding Objections. We will continue to work with Chichester District Council and as further work is completed will consider if objections can be withdrawn.

Transport Overview
The County Council has worked with Chichester District Council to develop the Chichester Local Plan and its supporting evidence base and will continue to do so. Although the overall direction of the Local Plan is supported, from a highways and transport perspective, there are three key issues remaining that need to be addressed in order to demonstrate that the Plan is sound:

1. There is insufficient evidence to demonstrate that key infrastructure (i.e. Terminus Road Diversion) will be deliverable;
2. The package of sustainable transport infrastructure and measures is not yet sufficiently well-developed to demonstrate that it is deliverable as part of the monitor and manage process; and
3. There is insufficient evidence to demonstrate that the capacity of the transport network can accommodate the scale of development proposed as part of the Southbourne Broad Location for Development.
The following sections explain; a) the reasons for these issues; b) why they affect the soundness of the Local Plan; and, c) what changes should be made to the Local Plan to remedy the issues.

Deliverability of Key Infrastructure

The recommended transport mitigation strategy, as assessed using the Chichester Area Transport Model for 2039 has been demonstrated to be capable in-principle to prevent the development from resulting in severe residual cumulative impacts on the highways and transport network. However, there are significant risks to deliverability of junction mitigation measures, which have required further work to be undertaken on developing a short to medium term strategy based on phased prioritisation of infrastructure and sustainable transport improvements, to be governed under a monitor and manage approach.

There are three locations where new highway alignments are proposed outside of existing highways boundaries. Two of these may include significant earthworks or structures to be delivered, being Stockbridge Link Road and Terminus Road diversion. The cost of the mitigation strategy exceeds the likely value of developer contributions and additional funding has not yet been secured.

At the Regulation 18 consultation stage in December 2018 to January 2019 the County Council identified delivery risks with the Stockbridge Link Road and Terminus Road Diversion schemes due to the earthworks likely to be required and to confirm the extent of land take required for both schemes. The County Council stated that feasibility work would need to be undertaken for these improvements prior to Plan submission to confirm that the schemes are deliverable. A brief for such a feasibility study was agreed in 2019, but to date, this work has not been commissioned. It is the County Council’s view that Stockbridge Link Road (SLR) should be disregarded as a potential part of a long-term transport mitigation strategy for 2039 and beyond until such time as it can be demonstrated that the scheme is deliverable. Paragraph 8.14 of the Local Plan acknowledges that the SLR is not deliverable as part of the Local Plan mitigation package.

The Terminus Road Diversion is still identified as part of the highest priority in the Local Plan mitigation package (i.e. A27 Fishbourne Junction) which is expected to be delivered once sufficient funding is collected. The County Council considers that in the absence of this feasibility work, the deliverability of the Terminus Road Diversion cannot be confirmed. In particular, given the recent impacts of inflation in the construction industry, this work will need to robustly estimate the costs and confirm delivery arrangements. In the absence of this feasibility work, there is currently insufficient evidence to confirm that the Local Plan complies with Paragraphs 11 and 106 of the NPPF as key infrastructure does not appear to be deliverable.

In order to remedy this issue regarding the Terminus Road Diversion, the County Council requests that feasibility work is undertaken prior to the examination to confirm deliverability of the proposed Terminus Road Diversion.

Sustainable Transport Infrastructure & Measures

The transport study modelling for end of Plan period also includes some proposed highways mitigation schemes within Chichester City. The County Council has previously requested that these be replaced by sustainable transport improvements to comply with the West Sussex Transport Plan 2022-2036. However, only limited modification has been made to these proposed schemes, with a suggestion in text at paragraph 7.3.2 of the main transport study that the costs for these schemes can be reallocated to sustainable transport improvements which are not specified. Although this does help to explain how sustainable transport infrastructure schemes and measures can be at least partially funded, it is rare that schemes will be fully funded using developer contributions. Furthermore, funding is not the only issue that needs to be overcome to secure delivery of these schemes and measures.

The Infrastructure Delivery Plan (IDP) lists the proposed mitigation measures and in some cases provides information on the rationale, phasing, cost, funding and delivery arrangements. However, there are still many gaps in the information, probably because schemes are currently at an early conceptual stage. The County Council’s experience is that it is unlikely that schemes will be fully funded using developer contributions (because doing so would not be compliant with the CIL regulations) so delivery of these schemes will be partially dependent on securing funding from central Government or other sources. The IDP currently fails to identify the scheme-specific requirements for additional funding and the overall scale of additional funding required.

The County Council considers the level of information currently available on the sustainable transport package to be insufficient to demonstrate deliverability of a credible and coordinated sustainable transport package of improved infrastructure and services. Therefore, there is insufficient evidence to confirm that the Local Plan complies with Paragraphs 11 and 106 of the NPPF.

In order to remedy this issue, the County Council requests that further technical work is undertaken to develop the schemes and measures in the sustainable transport package prior to the examination. In particular, this should focus on the following schemes and measures and some cases, this will build on work that has already taken place:
1. St. Paul’s & Parklands cycle routes
2. Improving existing public transport services towards Madgwick Lane
3. Provision of improved bus services for the village serving the development areas of Southbourne Parish
4. Improving cycling connectivity to link the built-out areas of Shopwhyke Lakes with Tangmere and Oving etc

As not all the severely impacted A27 junctions have a reasonable prospect of being physically improved in the Plan period, more investigation into potential public transport enhancements is also required, particularly to strengthen routes that cross the bypass. This may require further amendments to the IDP.

This work should aim to identify options for sustainable transport schemes that can be a priority for investment, provide information to enable safeguarding of routes (e.g. cycle routes) from development and provide a basis for applications for third party funding to support their delivery. The relative priority of such measures would need to be considered under the monitor and manage approach by the proposed Traffic and Infrastructure Management Group for implementation in addition to the proposed improvement at the A27/A259 Fishbourne junction.

To address this issue and support delivery of the sustainable transport package, the County Council also recommends the following minor amendments to Policy T1: Transport Infrastructure:

At bullet point .7 change “other small-scale junction improvements” to read “other sustainable transport and safety focused improvements, including at junctions” and change “These will increase road capacity, reduce traffic congestion, improve safety and air quality, and improve access to Chichester city from surrounding areas” to “These will increase road capacity on strategic roads, and on both strategic and local roads reduce traffic congestion, improve safety and air quality, and improve access to Chichester city from surrounding areas notably by encouraging and prioritising sustainable modes.”

Southbourne Broad Location for Development

The scale of development that can be accommodated at the Southbourne Broad Location will be, at least partially, dependent on the capacity of the transport network to accommodate the associated traffic movements. As the Broad Location spans the railway line, many of these traffic movements would need to cross the railway line. The County Council is concerned that there is currently insufficient capacity of the existing level crossings, notably at Stein Road, to accommodate the additional traffic movements. This could mean that the cumulative impact of development on the traffic network is severe, which is not consistent with Paragraph 111 of the NPPF.

The transport evidence base does not yet provide sufficient assurance that the proposed scale of development can be accommodated. This is because the base level of traffic flow has not been compared to local traffic counts, either in the initial validation of the strategic model or through a new count which the County Council has previously requested, and the assumptions about level crossing downtimes have not been validated against observed data. The County Council is concerned that the assessment of capacity of the local road network to accommodate the quantum of dwellings proposed for the Broad Location may be overoptimistic by underestimating existing flow levels and the duration of level crossing downtime. As a consequence, the proposed quantum may not be deliverable without unacceptable impacts to the conditions on Stein Road and to the level of traffic seeking to use rural lanes to the north of the village to avoid the level crossing.

In order to remedy this issue, the County Council requests that either additional transport evidence is provided prior to the examination to demonstrate that the proposed scale of development is deliverable, or that Policy A13 is changed to remove the proposed scale of development until such evidence is provided.

The following comments from education, minerals and waste, Adults Services and Health, highways & transport and public rights of way, do not affect the soundness of the Plan. However, Chichester District Council should take these into account and, where possible, make minor amendments to the Local Plan and/or evidence base studies before submission of the Local Plan for examination. Officers are happy to meet and discuss any of these comments, and proposed minor amendments to address these comments, ahead of submission:

1) Education

Land West of Chichester

Previous comments have been made requesting that the policy refers to ‘Phase 2 should include expansion of the primary school for the further 1FE of teaching accommodation with nursery and SEND provision’. While it is recognised that reference is made to this in the IDP this is a supporting document to the Local Plan and should not be solely relied on. It is requested that paragraph 10.19 is amended to read: ‘a local centre with retail, community and employment uses (minimum of approximately 2500 sqm E(g)(i) Use Class), two form entry (2FE) primary school and one form entry (1FE) teaching accommodation with nursery and SEND, informal and formal open space (including a country park), allotments,…’

This should also be included in the 3rd bullet point of Policy A6 or the wording of the policy should be drafted to reflect more recent policy requirements i.e. Provide for infrastructure and community facilities in accordance with the most recent Infrastructure Delivery Plan.

There are some inconsistencies with the wording of the strategic policies, not every policy includes the criterion ‘Provide for infrastructure and community facilities in accordance with the most recent Infrastructure Delivery Plan.’ While this may be due to some policies being carried through from the adopted local plan it is inconsistent.

Policy A8 Land East of Chichester

As an education authority WSCC do not request 1FE schools in line with government guidance. As per our earlier comments and discussions we requested a 2 FE primary school for the site.

3rd bullet point of Policy A8 should be amended to read: ‘A neighbourhood centre incorporating local shops, a community centre, flexible space for employment/ small-scale leisure uses and a one-form (expandable to two-form) two form entry primary school with provision for early years/ childcare and special educational needs and disability…’

2) Minerals and Waste

The references to safeguarding minerals is inconsistent and it is suggested that the wording in the email sent to CDC (attached) in relation to Policy AL3 should be used in the policies for the other sites for consistency. Reference to safeguarding minerals and waste infrastructure should also be included in some other policies as previously indicated:

• Policy A2 – needs to include reference to safeguarding minerals and waste infrastructure.
• Policy A7 – needs to include reference to safeguarding waste infrastructure.
• Policy A15 (Loxwood) – needs to include reference to minerals safeguarding as within the clay MSA.
• Policy A21 – needs to include reference to minerals safeguarding.

Also, the reference to the safeguarding guidance needs to be checked to ensure that it is worded correctly as ‘Minerals and Waste Safeguarding Guidance’.

3) Older Person Housing

It is noted that the plan refers to older person housing as specialist housing. WSCC strategy supports the provision of ‘extra care housing’ while this might be similar development it enables younger people to access the accommodation for whatever medical reason i.e. MS, strokes rather than limiting it to a certain age group. Officers are happy to meet and discuss this further.

4) Highways and Transport

Public Transport Priority Infrastructure

The Public Transport section of the main transport study report starting at paragraph 6.2.7 requires revisiting. There is reference to “an expansion of the bus priority lane system within Chichester City Centre” which does not match the existing bus provision in the City which does not provide bus priority lanes on street. It does have restrictions on motor traffic in the adjoining parts of South Street and West Street which provide for bus and cycle only access in both directions of travel plus access for essential goods vehicle loading in the westbound direction only. In addition, the suggestion in the following paragraph for “a time-based system where certain routes are restricted to public transport only during specific times” is not evidenced or developed and as such considered unlikely to be practical and enforceable at most locations used by bus routes in the City. More developed proposals for additional bus priority, improvements to bus passenger facilities or testing of specific locations for bus-only access would be welcomed as part of developing a costed sustainable transport mitigation package.

Park and Ride

The discussion of possible park and ride facilities for the City at paragraphs 6.2.9 to 6.2.16 of the main transport study should also acknowledge. An important part of making park and ride well used by motorists is increasing the price of city centre parking to provide a financial incentive to take up significantly cheaper park and ride charges for parking and travel. However, if park and ride sites are not provided accessible to all major approach routes to the city, such a charging strategy would not be seen to be equitable, whereas only a single site is proposed in the District Council’s emerging parking strategy and the report acknowledges at 6.2.11 that “locations for potential park and ride sites are also deemed to be limited”. The bullet at 6.2.15 “Cost of schemes compared to benefit are likely to be initially lower than highway schemes” may have been incorrectly worded given that this is listed as an issue rather than a benefit. The text may have been intended to say that the ratio of benefit to cost for park and ride schemes may be lower than for conventional highway schemes?

A286 New Park Road / A286 St Pancras Road (Junction 7)
This junction scheme includes pedestrian crossing facilities which are welcomed and also includes a length of advisory cycle lane starting in the middle of the junction for cyclists remaining on St Pancras. However, the approach to the junction on St Pancras from Eastgate Square remains intimidating to cyclists, so further measures would need to be added to make the layout cycle-friendly or the cycle facility is likely to be of limited benefit. This could include decreasing traffic speeds. Until this is done the conclusion at 8.4.4 of the main transport study; “The mitigation scheme includes improvements for pedestrians and cyclists which will lead to increased use of active travel modes and reduce the need for physical mitigation here” is only supported for pedestrians, not for cyclists.

A259 Via Ravenna / A259 Cathedral Way Roundabout (Junction 8)
It is stated at 7.3.8 of the main transport study that “the mitigation may be required to avoid queuing back towards the A27, as well as for capacity issues”. In light of this potential safety issue for the previous junction on Cathedral Way and for the A27 Fishbourne junction, the proposal at 7.3.6 that the scheme delivery should be tied to the monitor and manage regime to see if and when it is required is accepted. This is different to the approach for other junctions in the City because of the potential safety issue. This monitoring approach would be likely to follow after the A259 Cathedral Way / Fishbourne Road East / Terminus Road (as diverted) (Junction 10) improvement, which is to be brought forward as an integral part of the A27 Fishbourne roundabout mitigation scheme, but may allow for increased eastbound flows on Cathedral Way.

A286 Northgate Gyratory
An additional mitigation scheme is proposed at paragraph 7.3.134 of the main transport study for the A286 Northgate Gyratory along its southern arm from Oaklands Way to Orchard Street. The proposal to add traffic signals is welcomed in concept as it can help to control traffic speeds making the junction more friendly for cyclists and pedestrians. However, the layout shown at figure 7-8 does not maximise the opportunity to improve convenience and safety for pedestrians by providing a priority link to reach the central island, which contains employment space and the fire station, nor to assist crossing the exit towards Orchard Street. The scheme would benefit from further development to prioritise active travel movements and should also be fitted with transponders for bus priority.

Fishbourne Road West / Appledram Lane South (Junction 11)
At paragraphs 7.4.1 to 7.4.2 of the main transport study, the junction of Fishbourne Road West / Appledram Lane South (Junction 11) is considered. The proposal to mitigate impacts at this junction through delivery of the Stockbridge Link Road scheme is not considered deliverable, so the approach at this location requires re-thinking. The County Council would not support measures to increase capacity for through traffic on Appledram Lane South, the approach should be to reduce severance and improve safety and comfort for active travel on Appledram Lane by reducing vehicle speeds and as far as possible volume. This should consider the needs of pedestrians and cyclists both for local access and for users of the Salterns Way leisure cycling route.

TEMPro Background Traffic Growth Comparisons
At section 10.2 of the main transport study a comparison is made of the TEMPro 7.2 growth rates used in the study for external traffic with new TEMPro 8.0 growth rates since released by the Department for Transport, which notes that the TEMPro 8.0 rates are significantly lower, if these rates were used then the level of transport impacts could be lower. Unfortunately, a number of highways authorities in the Transport for the South East (TfSE) area including the County Council and Hampshire County Council have concerns that the planning assumptions used in TEMPro v8 core growth scenario underestimate the numbers of additional households forecasted compared to targets in adopted Local Plans for delivering new dwellings. TfSE are currently raising these collective concerns with DfT with a view to obtaining an early update to TEMPro 8 planning assumptions. Although for the purposes of this study TEMPro is not applied to trips produced in Chichester District, from the County Council’s analysis TEMPRo v8 core underestimates the increase in households per year in Arun District by over 50% and in Horsham District by 30% when compared with adopted development plans. On this basis it may be useful to instead compare TEMPro 7.2 with TEMPro 8.0 high growth scenario.

North of District Spatial Scenarios Testing
For the Northern Spatial Scenarios Test provided as an appendix to the main transport study, this had not been updated for the final preferred spatial strategy or in light of the County Council’s previous comments on the March 2022 issue to the District Council. The spatial strategy now is similar but not identical to the Scenario 4: Significant Growth 1 option in the reported tests, totalling 370 dwellings across the four northern parishes, compared to 410 in the test. In both cases the largest allocation is at Loxwood; 220 dwellings were proposed in the Scenario 4 as compared to 200 in this test. Some other tests proposed higher numbers.
The testing in the northern part of the district had used the same trip generation rates per dwelling as in the South of the District, but the County Council considers that in practice private motor vehicle trip generation per dwelling is likely to be higher due to the rural nature of the area, including a lack of local facilities and shops within walking distance of development, a very low level of public transport services and lack of surfaced cycle routes.
The level of development proposed is not at the level capable of delivering transformative transport improvements to match the trip making patterns around Chichester and the A259 corridor to Bosham and Southbourne. This may be offset in part by the lower total amount of development compared to the tested scenario 4. Nonetheless, it would be helpful to adjust the scenario for the spatial strategy now proposed and to provide information on additional traffic movements per peak hour from these parishes using the A272 at junctions at Wisborough Green and reaching the A272/A29 junction at Billingshurst and the A272/A283 junction at the north of Petworth.

Neutral Month and Summer Month Comparison Technical Note
The Neutral Month and Summer Month Comparison Technical Note in the main transport study treats July as a neutral month rather than a summer month. Paragraph 1.3.1 states “The flows were analysed by looking at traffic data for August 2019 this being considered to represent summer traffic. This was compared against traffic data from the neutral months of June, July, September and October also from 2019.” The County Council does not accept this methodology as school summer holidays start part way through July and education traffic is also affected by the formal exam period, whilst there is typically a high level of seasonal leisure traffic including summer outdoor events in this month. It is acceptable to use August alone as the summer comparator month. However, July traffic should be removed from the neutral months analysis and should be substituted with May traffic data from the same year of 2019, provided that sufficient data is available from that month.

5) Public Rights of Way (PRoW)

It is a positive step to see PRoW acknowledged as valued by communities and as part of the area’s green infrastructure. Whilst Policy P14 (Green Infrastructure) states that development proposals should not be detrimental to the network of public rights of way and bridleways (please note bridleways are Public Rights of Way), a more proactively positive approach that seeks enhancements to the network as mitigation, would be welcomed. The improvement, upgrading of existing PRoW and creation of new PRoW where possible, to allow for a greater number of users to access the network would be beneficial. This is somewhat addressed in Policy T1 which refers only to routes identified in the Local Transport Plan, Local Cycling and Walking Infrastructure Plan (LCWIP) and the Infrastructure Delivery Plan. Opportunities to these, should not be limited if they arise elsewhere.
It is surprising to see there is no mention of PRoW within Chapter 8 under Active Travel – Walking and Cycling. The PRoW network provides extensive walking and cycling opportunities, often off-road, and important links between places and non-PRoW routes.

The comments included below from WSCC are Holding Objections. We will continue to work with Chichester District Council and as further work is completed will consider if objections can be withdrawn.

Transport Overview
The County Council has worked with Chichester District Council to develop the Chichester Local Plan and its supporting evidence base and will continue to do so. Although the overall direction of the Local Plan is supported, from a highways and transport perspective, there are three key issues remaining that need to be addressed in order to demonstrate that the Plan is sound:

1. There is insufficient evidence to demonstrate that key infrastructure (i.e. Terminus Road Diversion) will be deliverable;
2. The package of sustainable transport infrastructure and measures is not yet sufficiently well-developed to demonstrate that it is deliverable as part of the monitor and manage process; and
3. There is insufficient evidence to demonstrate that the capacity of the transport network can accommodate the scale of development proposed as part of the Southbourne Broad Location for Development.
The following sections explain; a) the reasons for these issues; b) why they affect the soundness of the Local Plan; and, c) what changes should be made to the Local Plan to remedy the issues.

Deliverability of Key Infrastructure

The recommended transport mitigation strategy, as assessed using the Chichester Area Transport Model for 2039 has been demonstrated to be capable in-principle to prevent the development from resulting in severe residual cumulative impacts on the highways and transport network. However, there are significant risks to deliverability of junction mitigation measures, which have required further work to be undertaken on developing a short to medium term strategy based on phased prioritisation of infrastructure and sustainable transport improvements, to be governed under a monitor and manage approach.

There are three locations where new highway alignments are proposed outside of existing highways boundaries. Two of these may include significant earthworks or structures to be delivered, being Stockbridge Link Road and Terminus Road diversion. The cost of the mitigation strategy exceeds the likely value of developer contributions and additional funding has not yet been secured.

At the Regulation 18 consultation stage in December 2018 to January 2019 the County Council identified delivery risks with the Stockbridge Link Road and Terminus Road Diversion schemes due to the earthworks likely to be required and to confirm the extent of land take required for both schemes. The County Council stated that feasibility work would need to be undertaken for these improvements prior to Plan submission to confirm that the schemes are deliverable. A brief for such a feasibility study was agreed in 2019, but to date, this work has not been commissioned. It is the County Council’s view that Stockbridge Link Road (SLR) should be disregarded as a potential part of a long-term transport mitigation strategy for 2039 and beyond until such time as it can be demonstrated that the scheme is deliverable. Paragraph 8.14 of the Local Plan acknowledges that the SLR is not deliverable as part of the Local Plan mitigation package.

The Terminus Road Diversion is still identified as part of the highest priority in the Local Plan mitigation package (i.e. A27 Fishbourne Junction) which is expected to be delivered once sufficient funding is collected. The County Council considers that in the absence of this feasibility work, the deliverability of the Terminus Road Diversion cannot be confirmed. In particular, given the recent impacts of inflation in the construction industry, this work will need to robustly estimate the costs and confirm delivery arrangements. In the absence of this feasibility work, there is currently insufficient evidence to confirm that the Local Plan complies with Paragraphs 11 and 106 of the NPPF as key infrastructure does not appear to be deliverable.

In order to remedy this issue regarding the Terminus Road Diversion, the County Council requests that feasibility work is undertaken prior to the examination to confirm deliverability of the proposed Terminus Road Diversion.

Sustainable Transport Infrastructure & Measures

The transport study modelling for end of Plan period also includes some proposed highways mitigation schemes within Chichester City. The County Council has previously requested that these be replaced by sustainable transport improvements to comply with the West Sussex Transport Plan 2022-2036. However, only limited modification has been made to these proposed schemes, with a suggestion in text at paragraph 7.3.2 of the main transport study that the costs for these schemes can be reallocated to sustainable transport improvements which are not specified. Although this does help to explain how sustainable transport infrastructure schemes and measures can be at least partially funded, it is rare that schemes will be fully funded using developer contributions. Furthermore, funding is not the only issue that needs to be overcome to secure delivery of these schemes and measures.

The Infrastructure Delivery Plan (IDP) lists the proposed mitigation measures and in some cases provides information on the rationale, phasing, cost, funding and delivery arrangements. However, there are still many gaps in the information, probably because schemes are currently at an early conceptual stage. The County Council’s experience is that it is unlikely that schemes will be fully funded using developer contributions (because doing so would not be compliant with the CIL regulations) so delivery of these schemes will be partially dependent on securing funding from central Government or other sources. The IDP currently fails to identify the scheme-specific requirements for additional funding and the overall scale of additional funding required.

The County Council considers the level of information currently available on the sustainable transport package to be insufficient to demonstrate deliverability of a credible and coordinated sustainable transport package of improved infrastructure and services. Therefore, there is insufficient evidence to confirm that the Local Plan complies with Paragraphs 11 and 106 of the NPPF.

In order to remedy this issue, the County Council requests that further technical work is undertaken to develop the schemes and measures in the sustainable transport package prior to the examination. In particular, this should focus on the following schemes and measures and some cases, this will build on work that has already taken place:
1. St. Paul’s & Parklands cycle routes
2. Improving existing public transport services towards Madgwick Lane
3. Provision of improved bus services for the village serving the development areas of Southbourne Parish
4. Improving cycling connectivity to link the built-out areas of Shopwhyke Lakes with Tangmere and Oving etc

As not all the severely impacted A27 junctions have a reasonable prospect of being physically improved in the Plan period, more investigation into potential public transport enhancements is also required, particularly to strengthen routes that cross the bypass. This may require further amendments to the IDP.

This work should aim to identify options for sustainable transport schemes that can be a priority for investment, provide information to enable safeguarding of routes (e.g. cycle routes) from development and provide a basis for applications for third party funding to support their delivery. The relative priority of such measures would need to be considered under the monitor and manage approach by the proposed Traffic and Infrastructure Management Group for implementation in addition to the proposed improvement at the A27/A259 Fishbourne junction.

To address this issue and support delivery of the sustainable transport package, the County Council also recommends the following minor amendments to Policy T1: Transport Infrastructure:

At bullet point .7 change “other small-scale junction improvements” to read “other sustainable transport and safety focused improvements, including at junctions” and change “These will increase road capacity, reduce traffic congestion, improve safety and air quality, and improve access to Chichester city from surrounding areas” to “These will increase road capacity on strategic roads, and on both strategic and local roads reduce traffic congestion, improve safety and air quality, and improve access to Chichester city from surrounding areas notably by encouraging and prioritising sustainable modes.”

Southbourne Broad Location for Development

The scale of development that can be accommodated at the Southbourne Broad Location will be, at least partially, dependent on the capacity of the transport network to accommodate the associated traffic movements. As the Broad Location spans the railway line, many of these traffic movements would need to cross the railway line. The County Council is concerned that there is currently insufficient capacity of the existing level crossings, notably at Stein Road, to accommodate the additional traffic movements. This could mean that the cumulative impact of development on the traffic network is severe, which is not consistent with Paragraph 111 of the NPPF.

The transport evidence base does not yet provide sufficient assurance that the proposed scale of development can be accommodated. This is because the base level of traffic flow has not been compared to local traffic counts, either in the initial validation of the strategic model or through a new count which the County Council has previously requested, and the assumptions about level crossing downtimes have not been validated against observed data. The County Council is concerned that the assessment of capacity of the local road network to accommodate the quantum of dwellings proposed for the Broad Location may be overoptimistic by underestimating existing flow levels and the duration of level crossing downtime. As a consequence, the proposed quantum may not be deliverable without unacceptable impacts to the conditions on Stein Road and to the level of traffic seeking to use rural lanes to the north of the village to avoid the level crossing.

In order to remedy this issue, the County Council requests that either additional transport evidence is provided prior to the examination to demonstrate that the proposed scale of development is deliverable, or that Policy A13 is changed to remove the proposed scale of development until such evidence is provided.

The following comments from education, minerals and waste, Adults Services and Health, highways & transport and public rights of way, do not affect the soundness of the Plan. However, Chichester District Council should take these into account and, where possible, make minor amendments to the Local Plan and/or evidence base studies before submission of the Local Plan for examination. Officers are happy to meet and discuss any of these comments, and proposed minor amendments to address these comments, ahead of submission:

1) Education

Land West of Chichester

Previous comments have been made requesting that the policy refers to ‘Phase 2 should include expansion of the primary school for the further 1FE of teaching accommodation with nursery and SEND provision’. While it is recognised that reference is made to this in the IDP this is a supporting document to the Local Plan and should not be solely relied on. It is requested that paragraph 10.19 is amended to read: ‘a local centre with retail, community and employment uses (minimum of approximately 2500 sqm E(g)(i) Use Class), two form entry (2FE) primary school and one form entry (1FE) teaching accommodation with nursery and SEND, informal and formal open space (including a country park), allotments,…’

This should also be included in the 3rd bullet point of Policy A6 or the wording of the policy should be drafted to reflect more recent policy requirements i.e. Provide for infrastructure and community facilities in accordance with the most recent Infrastructure Delivery Plan.

There are some inconsistencies with the wording of the strategic policies, not every policy includes the criterion ‘Provide for infrastructure and community facilities in accordance with the most recent Infrastructure Delivery Plan.’ While this may be due to some policies being carried through from the adopted local plan it is inconsistent.

Policy A8 Land East of Chichester

As an education authority WSCC do not request 1FE schools in line with government guidance. As per our earlier comments and discussions we requested a 2 FE primary school for the site.

3rd bullet point of Policy A8 should be amended to read: ‘A neighbourhood centre incorporating local shops, a community centre, flexible space for employment/ small-scale leisure uses and a one-form (expandable to two-form) two form entry primary school with provision for early years/ childcare and special educational needs and disability…’

2) Minerals and Waste

The references to safeguarding minerals is inconsistent and it is suggested that the wording in the email sent to CDC (attached) in relation to Policy AL3 should be used in the policies for the other sites for consistency. Reference to safeguarding minerals and waste infrastructure should also be included in some other policies as previously indicated:

• Policy A2 – needs to include reference to safeguarding minerals and waste infrastructure.
• Policy A7 – needs to include reference to safeguarding waste infrastructure.
• Policy A15 (Loxwood) – needs to include reference to minerals safeguarding as within the clay MSA.
• Policy A21 – needs to include reference to minerals safeguarding.

Also, the reference to the safeguarding guidance needs to be checked to ensure that it is worded correctly as ‘Minerals and Waste Safeguarding Guidance’.

3) Older Person Housing

It is noted that the plan refers to older person housing as specialist housing. WSCC strategy supports the provision of ‘extra care housing’ while this might be similar development it enables younger people to access the accommodation for whatever medical reason i.e. MS, strokes rather than limiting it to a certain age group. Officers are happy to meet and discuss this further.

4) Highways and Transport

Public Transport Priority Infrastructure

The Public Transport section of the main transport study report starting at paragraph 6.2.7 requires revisiting. There is reference to “an expansion of the bus priority lane system within Chichester City Centre” which does not match the existing bus provision in the City which does not provide bus priority lanes on street. It does have restrictions on motor traffic in the adjoining parts of South Street and West Street which provide for bus and cycle only access in both directions of travel plus access for essential goods vehicle loading in the westbound direction only. In addition, the suggestion in the following paragraph for “a time-based system where certain routes are restricted to public transport only during specific times” is not evidenced or developed and as such considered unlikely to be practical and enforceable at most locations used by bus routes in the City. More developed proposals for additional bus priority, improvements to bus passenger facilities or testing of specific locations for bus-only access would be welcomed as part of developing a costed sustainable transport mitigation package.

Park and Ride

The discussion of possible park and ride facilities for the City at paragraphs 6.2.9 to 6.2.16 of the main transport study should also acknowledge. An important part of making park and ride well used by motorists is increasing the price of city centre parking to provide a financial incentive to take up significantly cheaper park and ride charges for parking and travel. However, if park and ride sites are not provided accessible to all major approach routes to the city, such a charging strategy would not be seen to be equitable, whereas only a single site is proposed in the District Council’s emerging parking strategy and the report acknowledges at 6.2.11 that “locations for potential park and ride sites are also deemed to be limited”. The bullet at 6.2.15 “Cost of schemes compared to benefit are likely to be initially lower than highway schemes” may have been incorrectly worded given that this is listed as an issue rather than a benefit. The text may have been intended to say that the ratio of benefit to cost for park and ride schemes may be lower than for conventional highway schemes?

A286 New Park Road / A286 St Pancras Road (Junction 7)
This junction scheme includes pedestrian crossing facilities which are welcomed and also includes a length of advisory cycle lane starting in the middle of the junction for cyclists remaining on St Pancras. However, the approach to the junction on St Pancras from Eastgate Square remains intimidating to cyclists, so further measures would need to be added to make the layout cycle-friendly or the cycle facility is likely to be of limited benefit. This could include decreasing traffic speeds. Until this is done the conclusion at 8.4.4 of the main transport study; “The mitigation scheme includes improvements for pedestrians and cyclists which will lead to increased use of active travel modes and reduce the need for physical mitigation here” is only supported for pedestrians, not for cyclists.

A259 Via Ravenna / A259 Cathedral Way Roundabout (Junction 8)
It is stated at 7.3.8 of the main transport study that “the mitigation may be required to avoid queuing back towards the A27, as well as for capacity issues”. In light of this potential safety issue for the previous junction on Cathedral Way and for the A27 Fishbourne junction, the proposal at 7.3.6 that the scheme delivery should be tied to the monitor and manage regime to see if and when it is required is accepted. This is different to the approach for other junctions in the City because of the potential safety issue. This monitoring approach would be likely to follow after the A259 Cathedral Way / Fishbourne Road East / Terminus Road (as diverted) (Junction 10) improvement, which is to be brought forward as an integral part of the A27 Fishbourne roundabout mitigation scheme, but may allow for increased eastbound flows on Cathedral Way.

A286 Northgate Gyratory
An additional mitigation scheme is proposed at paragraph 7.3.134 of the main transport study for the A286 Northgate Gyratory along its southern arm from Oaklands Way to Orchard Street. The proposal to add traffic signals is welcomed in concept as it can help to control traffic speeds making the junction more friendly for cyclists and pedestrians. However, the layout shown at figure 7-8 does not maximise the opportunity to improve convenience and safety for pedestrians by providing a priority link to reach the central island, which contains employment space and the fire station, nor to assist crossing the exit towards Orchard Street. The scheme would benefit from further development to prioritise active travel movements and should also be fitted with transponders for bus priority.

Fishbourne Road West / Appledram Lane South (Junction 11)
At paragraphs 7.4.1 to 7.4.2 of the main transport study, the junction of Fishbourne Road West / Appledram Lane South (Junction 11) is considered. The proposal to mitigate impacts at this junction through delivery of the Stockbridge Link Road scheme is not considered deliverable, so the approach at this location requires re-thinking. The County Council would not support measures to increase capacity for through traffic on Appledram Lane South, the approach should be to reduce severance and improve safety and comfort for active travel on Appledram Lane by reducing vehicle speeds and as far as possible volume. This should consider the needs of pedestrians and cyclists both for local access and for users of the Salterns Way leisure cycling route.

TEMPro Background Traffic Growth Comparisons
At section 10.2 of the main transport study a comparison is made of the TEMPro 7.2 growth rates used in the study for external traffic with new TEMPro 8.0 growth rates since released by the Department for Transport, which notes that the TEMPro 8.0 rates are significantly lower, if these rates were used then the level of transport impacts could be lower. Unfortunately, a number of highways authorities in the Transport for the South East (TfSE) area including the County Council and Hampshire County Council have concerns that the planning assumptions used in TEMPro v8 core growth scenario underestimate the numbers of additional households forecasted compared to targets in adopted Local Plans for delivering new dwellings. TfSE are currently raising these collective concerns with DfT with a view to obtaining an early update to TEMPro 8 planning assumptions. Although for the purposes of this study TEMPro is not applied to trips produced in Chichester District, from the County Council’s analysis TEMPRo v8 core underestimates the increase in households per year in Arun District by over 50% and in Horsham District by 30% when compared with adopted development plans. On this basis it may be useful to instead compare TEMPro 7.2 with TEMPro 8.0 high growth scenario.

North of District Spatial Scenarios Testing
For the Northern Spatial Scenarios Test provided as an appendix to the main transport study, this had not been updated for the final preferred spatial strategy or in light of the County Council’s previous comments on the March 2022 issue to the District Council. The spatial strategy now is similar but not identical to the Scenario 4: Significant Growth 1 option in the reported tests, totalling 370 dwellings across the four northern parishes, compared to 410 in the test. In both cases the largest allocation is at Loxwood; 220 dwellings were proposed in the Scenario 4 as compared to 200 in this test. Some other tests proposed higher numbers.
The testing in the northern part of the district had used the same trip generation rates per dwelling as in the South of the District, but the County Council considers that in practice private motor vehicle trip generation per dwelling is likely to be higher due to the rural nature of the area, including a lack of local facilities and shops within walking distance of development, a very low level of public transport services and lack of surfaced cycle routes.
The level of development proposed is not at the level capable of delivering transformative transport improvements to match the trip making patterns around Chichester and the A259 corridor to Bosham and Southbourne. This may be offset in part by the lower total amount of development compared to the tested scenario 4. Nonetheless, it would be helpful to adjust the scenario for the spatial strategy now proposed and to provide information on additional traffic movements per peak hour from these parishes using the A272 at junctions at Wisborough Green and reaching the A272/A29 junction at Billingshurst and the A272/A283 junction at the north of Petworth.

Neutral Month and Summer Month Comparison Technical Note
The Neutral Month and Summer Month Comparison Technical Note in the main transport study treats July as a neutral month rather than a summer month. Paragraph 1.3.1 states “The flows were analysed by looking at traffic data for August 2019 this being considered to represent summer traffic. This was compared against traffic data from the neutral months of June, July, September and October also from 2019.” The County Council does not accept this methodology as school summer holidays start part way through July and education traffic is also affected by the formal exam period, whilst there is typically a high level of seasonal leisure traffic including summer outdoor events in this month. It is acceptable to use August alone as the summer comparator month. However, July traffic should be removed from the neutral months analysis and should be substituted with May traffic data from the same year of 2019, provided that sufficient data is available from that month.

5) Public Rights of Way (PRoW)

It is a positive step to see PRoW acknowledged as valued by communities and as part of the area’s green infrastructure. Whilst Policy P14 (Green Infrastructure) states that development proposals should not be detrimental to the network of public rights of way and bridleways (please note bridleways are Public Rights of Way), a more proactively positive approach that seeks enhancements to the network as mitigation, would be welcomed. The improvement, upgrading of existing PRoW and creation of new PRoW where possible, to allow for a greater number of users to access the network would be beneficial. This is somewhat addressed in Policy T1 which refers only to routes identified in the Local Transport Plan, Local Cycling and Walking Infrastructure Plan (LCWIP) and the Infrastructure Delivery Plan. Opportunities to these, should not be limited if they arise elsewhere.
It is surprising to see there is no mention of PRoW within Chapter 8 under Active Travel – Walking and Cycling. The PRoW network provides extensive walking and cycling opportunities, often off-road, and important links between places and non-PRoW routes.

The comments included below from WSCC are Holding Objections. We will continue to work with Chichester District Council and as further work is completed will consider if objections can be withdrawn.

Transport Overview
The County Council has worked with Chichester District Council to develop the Chichester Local Plan and its supporting evidence base and will continue to do so. Although the overall direction of the Local Plan is supported, from a highways and transport perspective, there are three key issues remaining that need to be addressed in order to demonstrate that the Plan is sound:

1. There is insufficient evidence to demonstrate that key infrastructure (i.e. Terminus Road Diversion) will be deliverable;
2. The package of sustainable transport infrastructure and measures is not yet sufficiently well-developed to demonstrate that it is deliverable as part of the monitor and manage process; and
3. There is insufficient evidence to demonstrate that the capacity of the transport network can accommodate the scale of development proposed as part of the Southbourne Broad Location for Development.
The following sections explain; a) the reasons for these issues; b) why they affect the soundness of the Local Plan; and, c) what changes should be made to the Local Plan to remedy the issues.

Deliverability of Key Infrastructure

The recommended transport mitigation strategy, as assessed using the Chichester Area Transport Model for 2039 has been demonstrated to be capable in-principle to prevent the development from resulting in severe residual cumulative impacts on the highways and transport network. However, there are significant risks to deliverability of junction mitigation measures, which have required further work to be undertaken on developing a short to medium term strategy based on phased prioritisation of infrastructure and sustainable transport improvements, to be governed under a monitor and manage approach.

There are three locations where new highway alignments are proposed outside of existing highways boundaries. Two of these may include significant earthworks or structures to be delivered, being Stockbridge Link Road and Terminus Road diversion. The cost of the mitigation strategy exceeds the likely value of developer contributions and additional funding has not yet been secured.

At the Regulation 18 consultation stage in December 2018 to January 2019 the County Council identified delivery risks with the Stockbridge Link Road and Terminus Road Diversion schemes due to the earthworks likely to be required and to confirm the extent of land take required for both schemes. The County Council stated that feasibility work would need to be undertaken for these improvements prior to Plan submission to confirm that the schemes are deliverable. A brief for such a feasibility study was agreed in 2019, but to date, this work has not been commissioned. It is the County Council’s view that Stockbridge Link Road (SLR) should be disregarded as a potential part of a long-term transport mitigation strategy for 2039 and beyond until such time as it can be demonstrated that the scheme is deliverable. Paragraph 8.14 of the Local Plan acknowledges that the SLR is not deliverable as part of the Local Plan mitigation package.

The Terminus Road Diversion is still identified as part of the highest priority in the Local Plan mitigation package (i.e. A27 Fishbourne Junction) which is expected to be delivered once sufficient funding is collected. The County Council considers that in the absence of this feasibility work, the deliverability of the Terminus Road Diversion cannot be confirmed. In particular, given the recent impacts of inflation in the construction industry, this work will need to robustly estimate the costs and confirm delivery arrangements. In the absence of this feasibility work, there is currently insufficient evidence to confirm that the Local Plan complies with Paragraphs 11 and 106 of the NPPF as key infrastructure does not appear to be deliverable.

In order to remedy this issue regarding the Terminus Road Diversion, the County Council requests that feasibility work is undertaken prior to the examination to confirm deliverability of the proposed Terminus Road Diversion.

Sustainable Transport Infrastructure & Measures

The transport study modelling for end of Plan period also includes some proposed highways mitigation schemes within Chichester City. The County Council has previously requested that these be replaced by sustainable transport improvements to comply with the West Sussex Transport Plan 2022-2036. However, only limited modification has been made to these proposed schemes, with a suggestion in text at paragraph 7.3.2 of the main transport study that the costs for these schemes can be reallocated to sustainable transport improvements which are not specified. Although this does help to explain how sustainable transport infrastructure schemes and measures can be at least partially funded, it is rare that schemes will be fully funded using developer contributions. Furthermore, funding is not the only issue that needs to be overcome to secure delivery of these schemes and measures.

The Infrastructure Delivery Plan (IDP) lists the proposed mitigation measures and in some cases provides information on the rationale, phasing, cost, funding and delivery arrangements. However, there are still many gaps in the information, probably because schemes are currently at an early conceptual stage. The County Council’s experience is that it is unlikely that schemes will be fully funded using developer contributions (because doing so would not be compliant with the CIL regulations) so delivery of these schemes will be partially dependent on securing funding from central Government or other sources. The IDP currently fails to identify the scheme-specific requirements for additional funding and the overall scale of additional funding required.

The County Council considers the level of information currently available on the sustainable transport package to be insufficient to demonstrate deliverability of a credible and coordinated sustainable transport package of improved infrastructure and services. Therefore, there is insufficient evidence to confirm that the Local Plan complies with Paragraphs 11 and 106 of the NPPF.

In order to remedy this issue, the County Council requests that further technical work is undertaken to develop the schemes and measures in the sustainable transport package prior to the examination. In particular, this should focus on the following schemes and measures and some cases, this will build on work that has already taken place:
1. St. Paul’s & Parklands cycle routes
2. Improving existing public transport services towards Madgwick Lane
3. Provision of improved bus services for the village serving the development areas of Southbourne Parish
4. Improving cycling connectivity to link the built-out areas of Shopwhyke Lakes with Tangmere and Oving etc

As not all the severely impacted A27 junctions have a reasonable prospect of being physically improved in the Plan period, more investigation into potential public transport enhancements is also required, particularly to strengthen routes that cross the bypass. This may require further amendments to the IDP.

This work should aim to identify options for sustainable transport schemes that can be a priority for investment, provide information to enable safeguarding of routes (e.g. cycle routes) from development and provide a basis for applications for third party funding to support their delivery. The relative priority of such measures would need to be considered under the monitor and manage approach by the proposed Traffic and Infrastructure Management Group for implementation in addition to the proposed improvement at the A27/A259 Fishbourne junction.

To address this issue and support delivery of the sustainable transport package, the County Council also recommends the following minor amendments to Policy T1: Transport Infrastructure:

At bullet point .7 change “other small-scale junction improvements” to read “other sustainable transport and safety focused improvements, including at junctions” and change “These will increase road capacity, reduce traffic congestion, improve safety and air quality, and improve access to Chichester city from surrounding areas” to “These will increase road capacity on strategic roads, and on both strategic and local roads reduce traffic congestion, improve safety and air quality, and improve access to Chichester city from surrounding areas notably by encouraging and prioritising sustainable modes.”

Southbourne Broad Location for Development

The scale of development that can be accommodated at the Southbourne Broad Location will be, at least partially, dependent on the capacity of the transport network to accommodate the associated traffic movements. As the Broad Location spans the railway line, many of these traffic movements would need to cross the railway line. The County Council is concerned that there is currently insufficient capacity of the existing level crossings, notably at Stein Road, to accommodate the additional traffic movements. This could mean that the cumulative impact of development on the traffic network is severe, which is not consistent with Paragraph 111 of the NPPF.

The transport evidence base does not yet provide sufficient assurance that the proposed scale of development can be accommodated. This is because the base level of traffic flow has not been compared to local traffic counts, either in the initial validation of the strategic model or through a new count which the County Council has previously requested, and the assumptions about level crossing downtimes have not been validated against observed data. The County Council is concerned that the assessment of capacity of the local road network to accommodate the quantum of dwellings proposed for the Broad Location may be overoptimistic by underestimating existing flow levels and the duration of level crossing downtime. As a consequence, the proposed quantum may not be deliverable without unacceptable impacts to the conditions on Stein Road and to the level of traffic seeking to use rural lanes to the north of the village to avoid the level crossing.

In order to remedy this issue, the County Council requests that either additional transport evidence is provided prior to the examination to demonstrate that the proposed scale of development is deliverable, or that Policy A13 is changed to remove the proposed scale of development until such evidence is provided.

The following comments from education, minerals and waste, Adults Services and Health, highways & transport and public rights of way, do not affect the soundness of the Plan. However, Chichester District Council should take these into account and, where possible, make minor amendments to the Local Plan and/or evidence base studies before submission of the Local Plan for examination. Officers are happy to meet and discuss any of these comments, and proposed minor amendments to address these comments, ahead of submission:

1) Education

Land West of Chichester

Previous comments have been made requesting that the policy refers to ‘Phase 2 should include expansion of the primary school for the further 1FE of teaching accommodation with nursery and SEND provision’. While it is recognised that reference is made to this in the IDP this is a supporting document to the Local Plan and should not be solely relied on. It is requested that paragraph 10.19 is amended to read: ‘a local centre with retail, community and employment uses (minimum of approximately 2500 sqm E(g)(i) Use Class), two form entry (2FE) primary school and one form entry (1FE) teaching accommodation with nursery and SEND, informal and formal open space (including a country park), allotments,…’

This should also be included in the 3rd bullet point of Policy A6 or the wording of the policy should be drafted to reflect more recent policy requirements i.e. Provide for infrastructure and community facilities in accordance with the most recent Infrastructure Delivery Plan.

There are some inconsistencies with the wording of the strategic policies, not every policy includes the criterion ‘Provide for infrastructure and community facilities in accordance with the most recent Infrastructure Delivery Plan.’ While this may be due to some policies being carried through from the adopted local plan it is inconsistent.

Policy A8 Land East of Chichester

As an education authority WSCC do not request 1FE schools in line with government guidance. As per our earlier comments and discussions we requested a 2 FE primary school for the site.

3rd bullet point of Policy A8 should be amended to read: ‘A neighbourhood centre incorporating local shops, a community centre, flexible space for employment/ small-scale leisure uses and a one-form (expandable to two-form) two form entry primary school with provision for early years/ childcare and special educational needs and disability…’

2) Minerals and Waste

The references to safeguarding minerals is inconsistent and it is suggested that the wording in the email sent to CDC (attached) in relation to Policy AL3 should be used in the policies for the other sites for consistency. Reference to safeguarding minerals and waste infrastructure should also be included in some other policies as previously indicated:

• Policy A2 – needs to include reference to safeguarding minerals and waste infrastructure.
• Policy A7 – needs to include reference to safeguarding waste infrastructure.
• Policy A15 (Loxwood) – needs to include reference to minerals safeguarding as within the clay MSA.
• Policy A21 – needs to include reference to minerals safeguarding.

Also, the reference to the safeguarding guidance needs to be checked to ensure that it is worded correctly as ‘Minerals and Waste Safeguarding Guidance’.

3) Older Person Housing

It is noted that the plan refers to older person housing as specialist housing. WSCC strategy supports the provision of ‘extra care housing’ while this might be similar development it enables younger people to access the accommodation for whatever medical reason i.e. MS, strokes rather than limiting it to a certain age group. Officers are happy to meet and discuss this further.

4) Highways and Transport

Public Transport Priority Infrastructure

The Public Transport section of the main transport study report starting at paragraph 6.2.7 requires revisiting. There is reference to “an expansion of the bus priority lane system within Chichester City Centre” which does not match the existing bus provision in the City which does not provide bus priority lanes on street. It does have restrictions on motor traffic in the adjoining parts of South Street and West Street which provide for bus and cycle only access in both directions of travel plus access for essential goods vehicle loading in the westbound direction only. In addition, the suggestion in the following paragraph for “a time-based system where certain routes are restricted to public transport only during specific times” is not evidenced or developed and as such considered unlikely to be practical and enforceable at most locations used by bus routes in the City. More developed proposals for additional bus priority, improvements to bus passenger facilities or testing of specific locations for bus-only access would be welcomed as part of developing a costed sustainable transport mitigation package.

Park and Ride

The discussion of possible park and ride facilities for the City at paragraphs 6.2.9 to 6.2.16 of the main transport study should also acknowledge. An important part of making park and ride well used by motorists is increasing the price of city centre parking to provide a financial incentive to take up significantly cheaper park and ride charges for parking and travel. However, if park and ride sites are not provided accessible to all major approach routes to the city, such a charging strategy would not be seen to be equitable, whereas only a single site is proposed in the District Council’s emerging parking strategy and the report acknowledges at 6.2.11 that “locations for potential park and ride sites are also deemed to be limited”. The bullet at 6.2.15 “Cost of schemes compared to benefit are likely to be initially lower than highway schemes” may have been incorrectly worded given that this is listed as an issue rather than a benefit. The text may have been intended to say that the ratio of benefit to cost for park and ride schemes may be lower than for conventional highway schemes?

A286 New Park Road / A286 St Pancras Road (Junction 7)
This junction scheme includes pedestrian crossing facilities which are welcomed and also includes a length of advisory cycle lane starting in the middle of the junction for cyclists remaining on St Pancras. However, the approach to the junction on St Pancras from Eastgate Square remains intimidating to cyclists, so further measures would need to be added to make the layout cycle-friendly or the cycle facility is likely to be of limited benefit. This could include decreasing traffic speeds. Until this is done the conclusion at 8.4.4 of the main transport study; “The mitigation scheme includes improvements for pedestrians and cyclists which will lead to increased use of active travel modes and reduce the need for physical mitigation here” is only supported for pedestrians, not for cyclists.

A259 Via Ravenna / A259 Cathedral Way Roundabout (Junction 8)
It is stated at 7.3.8 of the main transport study that “the mitigation may be required to avoid queuing back towards the A27, as well as for capacity issues”. In light of this potential safety issue for the previous junction on Cathedral Way and for the A27 Fishbourne junction, the proposal at 7.3.6 that the scheme delivery should be tied to the monitor and manage regime to see if and when it is required is accepted. This is different to the approach for other junctions in the City because of the potential safety issue. This monitoring approach would be likely to follow after the A259 Cathedral Way / Fishbourne Road East / Terminus Road (as diverted) (Junction 10) improvement, which is to be brought forward as an integral part of the A27 Fishbourne roundabout mitigation scheme, but may allow for increased eastbound flows on Cathedral Way.

A286 Northgate Gyratory
An additional mitigation scheme is proposed at paragraph 7.3.134 of the main transport study for the A286 Northgate Gyratory along its southern arm from Oaklands Way to Orchard Street. The proposal to add traffic signals is welcomed in concept as it can help to control traffic speeds making the junction more friendly for cyclists and pedestrians. However, the layout shown at figure 7-8 does not maximise the opportunity to improve convenience and safety for pedestrians by providing a priority link to reach the central island, which contains employment space and the fire station, nor to assist crossing the exit towards Orchard Street. The scheme would benefit from further development to prioritise active travel movements and should also be fitted with transponders for bus priority.

Fishbourne Road West / Appledram Lane South (Junction 11)
At paragraphs 7.4.1 to 7.4.2 of the main transport study, the junction of Fishbourne Road West / Appledram Lane South (Junction 11) is considered. The proposal to mitigate impacts at this junction through delivery of the Stockbridge Link Road scheme is not considered deliverable, so the approach at this location requires re-thinking. The County Council would not support measures to increase capacity for through traffic on Appledram Lane South, the approach should be to reduce severance and improve safety and comfort for active travel on Appledram Lane by reducing vehicle speeds and as far as possible volume. This should consider the needs of pedestrians and cyclists both for local access and for users of the Salterns Way leisure cycling route.

TEMPro Background Traffic Growth Comparisons
At section 10.2 of the main transport study a comparison is made of the TEMPro 7.2 growth rates used in the study for external traffic with new TEMPro 8.0 growth rates since released by the Department for Transport, which notes that the TEMPro 8.0 rates are significantly lower, if these rates were used then the level of transport impacts could be lower. Unfortunately, a number of highways authorities in the Transport for the South East (TfSE) area including the County Council and Hampshire County Council have concerns that the planning assumptions used in TEMPro v8 core growth scenario underestimate the numbers of additional households forecasted compared to targets in adopted Local Plans for delivering new dwellings. TfSE are currently raising these collective concerns with DfT with a view to obtaining an early update to TEMPro 8 planning assumptions. Although for the purposes of this study TEMPro is not applied to trips produced in Chichester District, from the County Council’s analysis TEMPRo v8 core underestimates the increase in households per year in Arun District by over 50% and in Horsham District by 30% when compared with adopted development plans. On this basis it may be useful to instead compare TEMPro 7.2 with TEMPro 8.0 high growth scenario.

North of District Spatial Scenarios Testing
For the Northern Spatial Scenarios Test provided as an appendix to the main transport study, this had not been updated for the final preferred spatial strategy or in light of the County Council’s previous comments on the March 2022 issue to the District Council. The spatial strategy now is similar but not identical to the Scenario 4: Significant Growth 1 option in the reported tests, totalling 370 dwellings across the four northern parishes, compared to 410 in the test. In both cases the largest allocation is at Loxwood; 220 dwellings were proposed in the Scenario 4 as compared to 200 in this test. Some other tests proposed higher numbers.
The testing in the northern part of the district had used the same trip generation rates per dwelling as in the South of the District, but the County Council considers that in practice private motor vehicle trip generation per dwelling is likely to be higher due to the rural nature of the area, including a lack of local facilities and shops within walking distance of development, a very low level of public transport services and lack of surfaced cycle routes.
The level of development proposed is not at the level capable of delivering transformative transport improvements to match the trip making patterns around Chichester and the A259 corridor to Bosham and Southbourne. This may be offset in part by the lower total amount of development compared to the tested scenario 4. Nonetheless, it would be helpful to adjust the scenario for the spatial strategy now proposed and to provide information on additional traffic movements per peak hour from these parishes using the A272 at junctions at Wisborough Green and reaching the A272/A29 junction at Billingshurst and the A272/A283 junction at the north of Petworth.

Neutral Month and Summer Month Comparison Technical Note
The Neutral Month and Summer Month Comparison Technical Note in the main transport study treats July as a neutral month rather than a summer month. Paragraph 1.3.1 states “The flows were analysed by looking at traffic data for August 2019 this being considered to represent summer traffic. This was compared against traffic data from the neutral months of June, July, September and October also from 2019.” The County Council does not accept this methodology as school summer holidays start part way through July and education traffic is also affected by the formal exam period, whilst there is typically a high level of seasonal leisure traffic including summer outdoor events in this month. It is acceptable to use August alone as the summer comparator month. However, July traffic should be removed from the neutral months analysis and should be substituted with May traffic data from the same year of 2019, provided that sufficient data is available from that month.

5) Public Rights of Way (PRoW)

It is a positive step to see PRoW acknowledged as valued by communities and as part of the area’s green infrastructure. Whilst Policy P14 (Green Infrastructure) states that development proposals should not be detrimental to the network of public rights of way and bridleways (please note bridleways are Public Rights of Way), a more proactively positive approach that seeks enhancements to the network as mitigation, would be welcomed. The improvement, upgrading of existing PRoW and creation of new PRoW where possible, to allow for a greater number of users to access the network would be beneficial. This is somewhat addressed in Policy T1 which refers only to routes identified in the Local Transport Plan, Local Cycling and Walking Infrastructure Plan (LCWIP) and the Infrastructure Delivery Plan. Opportunities to these, should not be limited if they arise elsewhere.
It is surprising to see there is no mention of PRoW within Chapter 8 under Active Travel – Walking and Cycling. The PRoW network provides extensive walking and cycling opportunities, often off-road, and important links between places and non-PRoW routes.

The comments included below from WSCC are Holding Objections. We will continue to work with Chichester District Council and as further work is completed will consider if objections can be withdrawn.

Transport Overview
The County Council has worked with Chichester District Council to develop the Chichester Local Plan and its supporting evidence base and will continue to do so. Although the overall direction of the Local Plan is supported, from a highways and transport perspective, there are three key issues remaining that need to be addressed in order to demonstrate that the Plan is sound:

1. There is insufficient evidence to demonstrate that key infrastructure (i.e. Terminus Road Diversion) will be deliverable;
2. The package of sustainable transport infrastructure and measures is not yet sufficiently well-developed to demonstrate that it is deliverable as part of the monitor and manage process; and
3. There is insufficient evidence to demonstrate that the capacity of the transport network can accommodate the scale of development proposed as part of the Southbourne Broad Location for Development.
The following sections explain; a) the reasons for these issues; b) why they affect the soundness of the Local Plan; and, c) what changes should be made to the Local Plan to remedy the issues.

Deliverability of Key Infrastructure

The recommended transport mitigation strategy, as assessed using the Chichester Area Transport Model for 2039 has been demonstrated to be capable in-principle to prevent the development from resulting in severe residual cumulative impacts on the highways and transport network. However, there are significant risks to deliverability of junction mitigation measures, which have required further work to be undertaken on developing a short to medium term strategy based on phased prioritisation of infrastructure and sustainable transport improvements, to be governed under a monitor and manage approach.

There are three locations where new highway alignments are proposed outside of existing highways boundaries. Two of these may include significant earthworks or structures to be delivered, being Stockbridge Link Road and Terminus Road diversion. The cost of the mitigation strategy exceeds the likely value of developer contributions and additional funding has not yet been secured.

At the Regulation 18 consultation stage in December 2018 to January 2019 the County Council identified delivery risks with the Stockbridge Link Road and Terminus Road Diversion schemes due to the earthworks likely to be required and to confirm the extent of land take required for both schemes. The County Council stated that feasibility work would need to be undertaken for these improvements prior to Plan submission to confirm that the schemes are deliverable. A brief for such a feasibility study was agreed in 2019, but to date, this work has not been commissioned. It is the County Council’s view that Stockbridge Link Road (SLR) should be disregarded as a potential part of a long-term transport mitigation strategy for 2039 and beyond until such time as it can be demonstrated that the scheme is deliverable. Paragraph 8.14 of the Local Plan acknowledges that the SLR is not deliverable as part of the Local Plan mitigation package.

The Terminus Road Diversion is still identified as part of the highest priority in the Local Plan mitigation package (i.e. A27 Fishbourne Junction) which is expected to be delivered once sufficient funding is collected. The County Council considers that in the absence of this feasibility work, the deliverability of the Terminus Road Diversion cannot be confirmed. In particular, given the recent impacts of inflation in the construction industry, this work will need to robustly estimate the costs and confirm delivery arrangements. In the absence of this feasibility work, there is currently insufficient evidence to confirm that the Local Plan complies with Paragraphs 11 and 106 of the NPPF as key infrastructure does not appear to be deliverable.

In order to remedy this issue regarding the Terminus Road Diversion, the County Council requests that feasibility work is undertaken prior to the examination to confirm deliverability of the proposed Terminus Road Diversion.

Sustainable Transport Infrastructure & Measures

The transport study modelling for end of Plan period also includes some proposed highways mitigation schemes within Chichester City. The County Council has previously requested that these be replaced by sustainable transport improvements to comply with the West Sussex Transport Plan 2022-2036. However, only limited modification has been made to these proposed schemes, with a suggestion in text at paragraph 7.3.2 of the main transport study that the costs for these schemes can be reallocated to sustainable transport improvements which are not specified. Although this does help to explain how sustainable transport infrastructure schemes and measures can be at least partially funded, it is rare that schemes will be fully funded using developer contributions. Furthermore, funding is not the only issue that needs to be overcome to secure delivery of these schemes and measures.

The Infrastructure Delivery Plan (IDP) lists the proposed mitigation measures and in some cases provides information on the rationale, phasing, cost, funding and delivery arrangements. However, there are still many gaps in the information, probably because schemes are currently at an early conceptual stage. The County Council’s experience is that it is unlikely that schemes will be fully funded using developer contributions (because doing so would not be compliant with the CIL regulations) so delivery of these schemes will be partially dependent on securing funding from central Government or other sources. The IDP currently fails to identify the scheme-specific requirements for additional funding and the overall scale of additional funding required.

The County Council considers the level of information currently available on the sustainable transport package to be insufficient to demonstrate deliverability of a credible and coordinated sustainable transport package of improved infrastructure and services. Therefore, there is insufficient evidence to confirm that the Local Plan complies with Paragraphs 11 and 106 of the NPPF.

In order to remedy this issue, the County Council requests that further technical work is undertaken to develop the schemes and measures in the sustainable transport package prior to the examination. In particular, this should focus on the following schemes and measures and some cases, this will build on work that has already taken place:
1. St. Paul’s & Parklands cycle routes
2. Improving existing public transport services towards Madgwick Lane
3. Provision of improved bus services for the village serving the development areas of Southbourne Parish
4. Improving cycling connectivity to link the built-out areas of Shopwhyke Lakes with Tangmere and Oving etc

As not all the severely impacted A27 junctions have a reasonable prospect of being physically improved in the Plan period, more investigation into potential public transport enhancements is also required, particularly to strengthen routes that cross the bypass. This may require further amendments to the IDP.

This work should aim to identify options for sustainable transport schemes that can be a priority for investment, provide information to enable safeguarding of routes (e.g. cycle routes) from development and provide a basis for applications for third party funding to support their delivery. The relative priority of such measures would need to be considered under the monitor and manage approach by the proposed Traffic and Infrastructure Management Group for implementation in addition to the proposed improvement at the A27/A259 Fishbourne junction.

To address this issue and support delivery of the sustainable transport package, the County Council also recommends the following minor amendments to Policy T1: Transport Infrastructure:

At bullet point .7 change “other small-scale junction improvements” to read “other sustainable transport and safety focused improvements, including at junctions” and change “These will increase road capacity, reduce traffic congestion, improve safety and air quality, and improve access to Chichester city from surrounding areas” to “These will increase road capacity on strategic roads, and on both strategic and local roads reduce traffic congestion, improve safety and air quality, and improve access to Chichester city from surrounding areas notably by encouraging and prioritising sustainable modes.”

Southbourne Broad Location for Development

The scale of development that can be accommodated at the Southbourne Broad Location will be, at least partially, dependent on the capacity of the transport network to accommodate the associated traffic movements. As the Broad Location spans the railway line, many of these traffic movements would need to cross the railway line. The County Council is concerned that there is currently insufficient capacity of the existing level crossings, notably at Stein Road, to accommodate the additional traffic movements. This could mean that the cumulative impact of development on the traffic network is severe, which is not consistent with Paragraph 111 of the NPPF.

The transport evidence base does not yet provide sufficient assurance that the proposed scale of development can be accommodated. This is because the base level of traffic flow has not been compared to local traffic counts, either in the initial validation of the strategic model or through a new count which the County Council has previously requested, and the assumptions about level crossing downtimes have not been validated against observed data. The County Council is concerned that the assessment of capacity of the local road network to accommodate the quantum of dwellings proposed for the Broad Location may be overoptimistic by underestimating existing flow levels and the duration of level crossing downtime. As a consequence, the proposed quantum may not be deliverable without unacceptable impacts to the conditions on Stein Road and to the level of traffic seeking to use rural lanes to the north of the village to avoid the level crossing.

In order to remedy this issue, the County Council requests that either additional transport evidence is provided prior to the examination to demonstrate that the proposed scale of development is deliverable, or that Policy A13 is changed to remove the proposed scale of development until such evidence is provided.

The following comments from education, minerals and waste, Adults Services and Health, highways & transport and public rights of way, do not affect the soundness of the Plan. However, Chichester District Council should take these into account and, where possible, make minor amendments to the Local Plan and/or evidence base studies before submission of the Local Plan for examination. Officers are happy to meet and discuss any of these comments, and proposed minor amendments to address these comments, ahead of submission:

1) Education

Land West of Chichester

Previous comments have been made requesting that the policy refers to ‘Phase 2 should include expansion of the primary school for the further 1FE of teaching accommodation with nursery and SEND provision’. While it is recognised that reference is made to this in the IDP this is a supporting document to the Local Plan and should not be solely relied on. It is requested that paragraph 10.19 is amended to read: ‘a local centre with retail, community and employment uses (minimum of approximately 2500 sqm E(g)(i) Use Class), two form entry (2FE) primary school and one form entry (1FE) teaching accommodation with nursery and SEND, informal and formal open space (including a country park), allotments,…’

This should also be included in the 3rd bullet point of Policy A6 or the wording of the policy should be drafted to reflect more recent policy requirements i.e. Provide for infrastructure and community facilities in accordance with the most recent Infrastructure Delivery Plan.

There are some inconsistencies with the wording of the strategic policies, not every policy includes the criterion ‘Provide for infrastructure and community facilities in accordance with the most recent Infrastructure Delivery Plan.’ While this may be due to some policies being carried through from the adopted local plan it is inconsistent.

Policy A8 Land East of Chichester

As an education authority WSCC do not request 1FE schools in line with government guidance. As per our earlier comments and discussions we requested a 2 FE primary school for the site.

3rd bullet point of Policy A8 should be amended to read: ‘A neighbourhood centre incorporating local shops, a community centre, flexible space for employment/ small-scale leisure uses and a one-form (expandable to two-form) two form entry primary school with provision for early years/ childcare and special educational needs and disability…’

2) Minerals and Waste

The references to safeguarding minerals is inconsistent and it is suggested that the wording in the email sent to CDC (attached) in relation to Policy AL3 should be used in the policies for the other sites for consistency. Reference to safeguarding minerals and waste infrastructure should also be included in some other policies as previously indicated:

• Policy A2 – needs to include reference to safeguarding minerals and waste infrastructure.
• Policy A7 – needs to include reference to safeguarding waste infrastructure.
• Policy A15 (Loxwood) – needs to include reference to minerals safeguarding as within the clay MSA.
• Policy A21 – needs to include reference to minerals safeguarding.

Also, the reference to the safeguarding guidance needs to be checked to ensure that it is worded correctly as ‘Minerals and Waste Safeguarding Guidance’.

3) Older Person Housing

It is noted that the plan refers to older person housing as specialist housing. WSCC strategy supports the provision of ‘extra care housing’ while this might be similar development it enables younger people to access the accommodation for whatever medical reason i.e. MS, strokes rather than limiting it to a certain age group. Officers are happy to meet and discuss this further.

4) Highways and Transport

Public Transport Priority Infrastructure

The Public Transport section of the main transport study report starting at paragraph 6.2.7 requires revisiting. There is reference to “an expansion of the bus priority lane system within Chichester City Centre” which does not match the existing bus provision in the City which does not provide bus priority lanes on street. It does have restrictions on motor traffic in the adjoining parts of South Street and West Street which provide for bus and cycle only access in both directions of travel plus access for essential goods vehicle loading in the westbound direction only. In addition, the suggestion in the following paragraph for “a time-based system where certain routes are restricted to public transport only during specific times” is not evidenced or developed and as such considered unlikely to be practical and enforceable at most locations used by bus routes in the City. More developed proposals for additional bus priority, improvements to bus passenger facilities or testing of specific locations for bus-only access would be welcomed as part of developing a costed sustainable transport mitigation package.

Park and Ride

The discussion of possible park and ride facilities for the City at paragraphs 6.2.9 to 6.2.16 of the main transport study should also acknowledge. An important part of making park and ride well used by motorists is increasing the price of city centre parking to provide a financial incentive to take up significantly cheaper park and ride charges for parking and travel. However, if park and ride sites are not provided accessible to all major approach routes to the city, such a charging strategy would not be seen to be equitable, whereas only a single site is proposed in the District Council’s emerging parking strategy and the report acknowledges at 6.2.11 that “locations for potential park and ride sites are also deemed to be limited”. The bullet at 6.2.15 “Cost of schemes compared to benefit are likely to be initially lower than highway schemes” may have been incorrectly worded given that this is listed as an issue rather than a benefit. The text may have been intended to say that the ratio of benefit to cost for park and ride schemes may be lower than for conventional highway schemes?

A286 New Park Road / A286 St Pancras Road (Junction 7)
This junction scheme includes pedestrian crossing facilities which are welcomed and also includes a length of advisory cycle lane starting in the middle of the junction for cyclists remaining on St Pancras. However, the approach to the junction on St Pancras from Eastgate Square remains intimidating to cyclists, so further measures would need to be added to make the layout cycle-friendly or the cycle facility is likely to be of limited benefit. This could include decreasing traffic speeds. Until this is done the conclusion at 8.4.4 of the main transport study; “The mitigation scheme includes improvements for pedestrians and cyclists which will lead to increased use of active travel modes and reduce the need for physical mitigation here” is only supported for pedestrians, not for cyclists.

A259 Via Ravenna / A259 Cathedral Way Roundabout (Junction 8)
It is stated at 7.3.8 of the main transport study that “the mitigation may be required to avoid queuing back towards the A27, as well as for capacity issues”. In light of this potential safety issue for the previous junction on Cathedral Way and for the A27 Fishbourne junction, the proposal at 7.3.6 that the scheme delivery should be tied to the monitor and manage regime to see if and when it is required is accepted. This is different to the approach for other junctions in the City because of the potential safety issue. This monitoring approach would be likely to follow after the A259 Cathedral Way / Fishbourne Road East / Terminus Road (as diverted) (Junction 10) improvement, which is to be brought forward as an integral part of the A27 Fishbourne roundabout mitigation scheme, but may allow for increased eastbound flows on Cathedral Way.

A286 Northgate Gyratory
An additional mitigation scheme is proposed at paragraph 7.3.134 of the main transport study for the A286 Northgate Gyratory along its southern arm from Oaklands Way to Orchard Street. The proposal to add traffic signals is welcomed in concept as it can help to control traffic speeds making the junction more friendly for cyclists and pedestrians. However, the layout shown at figure 7-8 does not maximise the opportunity to improve convenience and safety for pedestrians by providing a priority link to reach the central island, which contains employment space and the fire station, nor to assist crossing the exit towards Orchard Street. The scheme would benefit from further development to prioritise active travel movements and should also be fitted with transponders for bus priority.

Fishbourne Road West / Appledram Lane South (Junction 11)
At paragraphs 7.4.1 to 7.4.2 of the main transport study, the junction of Fishbourne Road West / Appledram Lane South (Junction 11) is considered. The proposal to mitigate impacts at this junction through delivery of the Stockbridge Link Road scheme is not considered deliverable, so the approach at this location requires re-thinking. The County Council would not support measures to increase capacity for through traffic on Appledram Lane South, the approach should be to reduce severance and improve safety and comfort for active travel on Appledram Lane by reducing vehicle speeds and as far as possible volume. This should consider the needs of pedestrians and cyclists both for local access and for users of the Salterns Way leisure cycling route.

TEMPro Background Traffic Growth Comparisons
At section 10.2 of the main transport study a comparison is made of the TEMPro 7.2 growth rates used in the study for external traffic with new TEMPro 8.0 growth rates since released by the Department for Transport, which notes that the TEMPro 8.0 rates are significantly lower, if these rates were used then the level of transport impacts could be lower. Unfortunately, a number of highways authorities in the Transport for the South East (TfSE) area including the County Council and Hampshire County Council have concerns that the planning assumptions used in TEMPro v8 core growth scenario underestimate the numbers of additional households forecasted compared to targets in adopted Local Plans for delivering new dwellings. TfSE are currently raising these collective concerns with DfT with a view to obtaining an early update to TEMPro 8 planning assumptions. Although for the purposes of this study TEMPro is not applied to trips produced in Chichester District, from the County Council’s analysis TEMPRo v8 core underestimates the increase in households per year in Arun District by over 50% and in Horsham District by 30% when compared with adopted development plans. On this basis it may be useful to instead compare TEMPro 7.2 with TEMPro 8.0 high growth scenario.

North of District Spatial Scenarios Testing
For the Northern Spatial Scenarios Test provided as an appendix to the main transport study, this had not been updated for the final preferred spatial strategy or in light of the County Council’s previous comments on the March 2022 issue to the District Council. The spatial strategy now is similar but not identical to the Scenario 4: Significant Growth 1 option in the reported tests, totalling 370 dwellings across the four northern parishes, compared to 410 in the test. In both cases the largest allocation is at Loxwood; 220 dwellings were proposed in the Scenario 4 as compared to 200 in this test. Some other tests proposed higher numbers.
The testing in the northern part of the district had used the same trip generation rates per dwelling as in the South of the District, but the County Council considers that in practice private motor vehicle trip generation per dwelling is likely to be higher due to the rural nature of the area, including a lack of local facilities and shops within walking distance of development, a very low level of public transport services and lack of surfaced cycle routes.
The level of development proposed is not at the level capable of delivering transformative transport improvements to match the trip making patterns around Chichester and the A259 corridor to Bosham and Southbourne. This may be offset in part by the lower total amount of development compared to the tested scenario 4. Nonetheless, it would be helpful to adjust the scenario for the spatial strategy now proposed and to provide information on additional traffic movements per peak hour from these parishes using the A272 at junctions at Wisborough Green and reaching the A272/A29 junction at Billingshurst and the A272/A283 junction at the north of Petworth.

Neutral Month and Summer Month Comparison Technical Note
The Neutral Month and Summer Month Comparison Technical Note in the main transport study treats July as a neutral month rather than a summer month. Paragraph 1.3.1 states “The flows were analysed by looking at traffic data for August 2019 this being considered to represent summer traffic. This was compared against traffic data from the neutral months of June, July, September and October also from 2019.” The County Council does not accept this methodology as school summer holidays start part way through July and education traffic is also affected by the formal exam period, whilst there is typically a high level of seasonal leisure traffic including summer outdoor events in this month. It is acceptable to use August alone as the summer comparator month. However, July traffic should be removed from the neutral months analysis and should be substituted with May traffic data from the same year of 2019, provided that sufficient data is available from that month.

5) Public Rights of Way (PRoW)

It is a positive step to see PRoW acknowledged as valued by communities and as part of the area’s green infrastructure. Whilst Policy P14 (Green Infrastructure) states that development proposals should not be detrimental to the network of public rights of way and bridleways (please note bridleways are Public Rights of Way), a more proactively positive approach that seeks enhancements to the network as mitigation, would be welcomed. The improvement, upgrading of existing PRoW and creation of new PRoW where possible, to allow for a greater number of users to access the network would be beneficial. This is somewhat addressed in Policy T1 which refers only to routes identified in the Local Transport Plan, Local Cycling and Walking Infrastructure Plan (LCWIP) and the Infrastructure Delivery Plan. Opportunities to these, should not be limited if they arise elsewhere.
It is surprising to see there is no mention of PRoW within Chapter 8 under Active Travel – Walking and Cycling. The PRoW network provides extensive walking and cycling opportunities, often off-road, and important links between places and non-PRoW routes.

More flexibility to be written into policy:
Provide up to 5 no. plots, with need to be determined at time of submission of planning application and dependent on land required to satisfy biodiversity net gain and/or drainage requirements associated with commercial development;
More flexibility for amount of storage area associated with travelling showpeople plots. Flexibility and requirement for an assessment in accordance with Policy H13 should be included in policy wording;
A timescale for marketing of travelling showpeople plots following which it should revert to part of the commercial site.
Request more precise wording is included in criteria 10 and 11 so that expectations are clear.

See attachments.

Consider allocating Land at Tangmere Apron for housing should housing requirement for Tangmere increase.

This representation is made on behalf of our client, West Sussex County Council who wish to raise objection to the continued allocation of land within their ownership for horticultural development under Policy E3 of the draft Local Plan. The site is edged in red on the attached plan (dated 06-02-2014).
Site
The site is situated to the South of the main settlement of Tangmere and relates to an open area of brownfield land previously used as the apron for RAF Tangmere airfield. As a result of this previous use, the site comprises a large flat area of concrete. Most recently, the site has been rented out by our client to the NHS, who used it as a COVID testing centre.
The site borders residential development along its Northern boundary, which also provide a number of opportunities for access. Extensive areas of greenhouses are located to the East of the site, and the fields to the South of the site are in agricultural in use. The site has no planning constraints, other than being outside of the Settlement Policy Boundary and partly covered by the Horticultural Development Area (HDA).
Policy E3 Assessment
Policy E3 of the draft Local Plan sets out that there is a need to support the growth of horticultural industry within the plan area, which requires 204ha of additional land over the plan period. It sets out that large scale horticultural development will be focussed within the HDAs at Tangmere and Runcton.
We are of the view that the site is wholly unsuitable for horticultural use, as a result of it being hardstanding, but principally due to its proximity to residential properties and the only likely suitable use being for additional greenhouses. The significant light spill from such a use would harmful to neighbouring amenity and would not therefore be a suitable use of the land. When viewed within the Agricultural Land Classification maps, the site can be seen to be classified as ‘Other land primarily in a non-agricultural use’.
The site was submitted within the most recent HELAA, and has been considered developable for employment uses, and potentially developable for residential uses. Should the housing requirement for Tangmere increase, we ask Chichester District Council to consider allocating Land at Tangmere Apron for housing, as in accordance with the NPPF, brownfield sites should be considered ahead of greenfield. At present, it represents an area of under-utilised brownfield land, which will not find functional purpose in agricultural / horticultural use due to its concrete top and proximity to residential properties. The site represents a greater opportunity for allocation in alternate uses. Part of the site is already outside of the HDA. The site adjoins the adopted settlement policy boundary to its North, and therefore it is clear it relates well to the existing settlement.
In visual terms, the site is unsightly, and untidy, which is incongruous in comparison to the residential uses directly adjacent to the Northern boundary of the site, and the open, undeveloped nature of the land to the South of the site. Potential development of the site provides opportunity to provide a softer transition between the hard settlement edge and open countryside, through a landscape led development at the site. This could significantly soften the edge of the settlement, where currently it is abrupt and stark when viewed from the south.
We therefore ask that Chichester District Council consider removing the Horticultural Development Area (HDA) designation currently affecting part of the site for the reasons set out above. The site adjoins the settlement policy boundary to the majority of its Northern boundary, and can be considered as an area of brownfield land. Therefore, in line with the NPPF, its development should be considered ahead of greenfield land. Further, the site is currently of a poor visual quality, and any development would provide the opportunity to enhance and soften the edge of the settlement.

More flexibility to be written into policy: Provide up to 5 no. plots, with need to be determined at time of submission of planning application and dependent on land required to satisfy biodiversity net gain and/or drainage requirements associated with commercial development; More flexibility for amount of storage area associated with travelling showpeople plots. Flexibility and requirement for an assessment in accordance with Policy H13 should be included in policy wording; A timescale for marketing of travelling showpeople plots following which it should revert to part of the commercial site. Request more precise wording is included in criteria 10 and 11 so that expectations are clear.

See attachments.

The comments included below from WSCC are Holding Objections. We will continue to work with Chichester District Council and as further work is completed will consider if objections can be withdrawn.

Transport Overview
The County Council has worked with Chichester District Council to develop the Chichester Local Plan and its supporting evidence base and will continue to do so. Although the overall direction of the Local Plan is supported, from a highways and transport perspective, there are three key issues remaining that need to be addressed in order to demonstrate that the Plan is sound:

1. There is insufficient evidence to demonstrate that key infrastructure (i.e. Terminus Road Diversion) will be deliverable;
2. The package of sustainable transport infrastructure and measures is not yet sufficiently well-developed to demonstrate that it is deliverable as part of the monitor and manage process; and
3. There is insufficient evidence to demonstrate that the capacity of the transport network can accommodate the scale of development proposed as part of the Southbourne Broad Location for Development.
The following sections explain; a) the reasons for these issues; b) why they affect the soundness of the Local Plan; and, c) what changes should be made to the Local Plan to remedy the issues.

Deliverability of Key Infrastructure

The recommended transport mitigation strategy, as assessed using the Chichester Area Transport Model for 2039 has been demonstrated to be capable in-principle to prevent the development from resulting in severe residual cumulative impacts on the highways and transport network. However, there are significant risks to deliverability of junction mitigation measures, which have required further work to be undertaken on developing a short to medium term strategy based on phased prioritisation of infrastructure and sustainable transport improvements, to be governed under a monitor and manage approach.

There are three locations where new highway alignments are proposed outside of existing highways boundaries. Two of these may include significant earthworks or structures to be delivered, being Stockbridge Link Road and Terminus Road diversion. The cost of the mitigation strategy exceeds the likely value of developer contributions and additional funding has not yet been secured.

At the Regulation 18 consultation stage in December 2018 to January 2019 the County Council identified delivery risks with the Stockbridge Link Road and Terminus Road Diversion schemes due to the earthworks likely to be required and to confirm the extent of land take required for both schemes. The County Council stated that feasibility work would need to be undertaken for these improvements prior to Plan submission to confirm that the schemes are deliverable. A brief for such a feasibility study was agreed in 2019, but to date, this work has not been commissioned. It is the County Council’s view that Stockbridge Link Road (SLR) should be disregarded as a potential part of a long-term transport mitigation strategy for 2039 and beyond until such time as it can be demonstrated that the scheme is deliverable. Paragraph 8.14 of the Local Plan acknowledges that the SLR is not deliverable as part of the Local Plan mitigation package.

The Terminus Road Diversion is still identified as part of the highest priority in the Local Plan mitigation package (i.e. A27 Fishbourne Junction) which is expected to be delivered once sufficient funding is collected. The County Council considers that in the absence of this feasibility work, the deliverability of the Terminus Road Diversion cannot be confirmed. In particular, given the recent impacts of inflation in the construction industry, this work will need to robustly estimate the costs and confirm delivery arrangements. In the absence of this feasibility work, there is currently insufficient evidence to confirm that the Local Plan complies with Paragraphs 11 and 106 of the NPPF as key infrastructure does not appear to be deliverable.

In order to remedy this issue regarding the Terminus Road Diversion, the County Council requests that feasibility work is undertaken prior to the examination to confirm deliverability of the proposed Terminus Road Diversion.

Sustainable Transport Infrastructure & Measures

The transport study modelling for end of Plan period also includes some proposed highways mitigation schemes within Chichester City. The County Council has previously requested that these be replaced by sustainable transport improvements to comply with the West Sussex Transport Plan 2022-2036. However, only limited modification has been made to these proposed schemes, with a suggestion in text at paragraph 7.3.2 of the main transport study that the costs for these schemes can be reallocated to sustainable transport improvements which are not specified. Although this does help to explain how sustainable transport infrastructure schemes and measures can be at least partially funded, it is rare that schemes will be fully funded using developer contributions. Furthermore, funding is not the only issue that needs to be overcome to secure delivery of these schemes and measures.

The Infrastructure Delivery Plan (IDP) lists the proposed mitigation measures and in some cases provides information on the rationale, phasing, cost, funding and delivery arrangements. However, there are still many gaps in the information, probably because schemes are currently at an early conceptual stage. The County Council’s experience is that it is unlikely that schemes will be fully funded using developer contributions (because doing so would not be compliant with the CIL regulations) so delivery of these schemes will be partially dependent on securing funding from central Government or other sources. The IDP currently fails to identify the scheme-specific requirements for additional funding and the overall scale of additional funding required.

The County Council considers the level of information currently available on the sustainable transport package to be insufficient to demonstrate deliverability of a credible and coordinated sustainable transport package of improved infrastructure and services. Therefore, there is insufficient evidence to confirm that the Local Plan complies with Paragraphs 11 and 106 of the NPPF.

In order to remedy this issue, the County Council requests that further technical work is undertaken to develop the schemes and measures in the sustainable transport package prior to the examination. In particular, this should focus on the following schemes and measures and some cases, this will build on work that has already taken place:
1. St. Paul’s & Parklands cycle routes
2. Improving existing public transport services towards Madgwick Lane
3. Provision of improved bus services for the village serving the development areas of Southbourne Parish
4. Improving cycling connectivity to link the built-out areas of Shopwhyke Lakes with Tangmere and Oving etc

As not all the severely impacted A27 junctions have a reasonable prospect of being physically improved in the Plan period, more investigation into potential public transport enhancements is also required, particularly to strengthen routes that cross the bypass. This may require further amendments to the IDP.

This work should aim to identify options for sustainable transport schemes that can be a priority for investment, provide information to enable safeguarding of routes (e.g. cycle routes) from development and provide a basis for applications for third party funding to support their delivery. The relative priority of such measures would need to be considered under the monitor and manage approach by the proposed Traffic and Infrastructure Management Group for implementation in addition to the proposed improvement at the A27/A259 Fishbourne junction.

To address this issue and support delivery of the sustainable transport package, the County Council also recommends the following minor amendments to Policy T1: Transport Infrastructure:

At bullet point .7 change “other small-scale junction improvements” to read “other sustainable transport and safety focused improvements, including at junctions” and change “These will increase road capacity, reduce traffic congestion, improve safety and air quality, and improve access to Chichester city from surrounding areas” to “These will increase road capacity on strategic roads, and on both strategic and local roads reduce traffic congestion, improve safety and air quality, and improve access to Chichester city from surrounding areas notably by encouraging and prioritising sustainable modes.”

Southbourne Broad Location for Development

The scale of development that can be accommodated at the Southbourne Broad Location will be, at least partially, dependent on the capacity of the transport network to accommodate the associated traffic movements. As the Broad Location spans the railway line, many of these traffic movements would need to cross the railway line. The County Council is concerned that there is currently insufficient capacity of the existing level crossings, notably at Stein Road, to accommodate the additional traffic movements. This could mean that the cumulative impact of development on the traffic network is severe, which is not consistent with Paragraph 111 of the NPPF.

The transport evidence base does not yet provide sufficient assurance that the proposed scale of development can be accommodated. This is because the base level of traffic flow has not been compared to local traffic counts, either in the initial validation of the strategic model or through a new count which the County Council has previously requested, and the assumptions about level crossing downtimes have not been validated against observed data. The County Council is concerned that the assessment of capacity of the local road network to accommodate the quantum of dwellings proposed for the Broad Location may be overoptimistic by underestimating existing flow levels and the duration of level crossing downtime. As a consequence, the proposed quantum may not be deliverable without unacceptable impacts to the conditions on Stein Road and to the level of traffic seeking to use rural lanes to the north of the village to avoid the level crossing.

In order to remedy this issue, the County Council requests that either additional transport evidence is provided prior to the examination to demonstrate that the proposed scale of development is deliverable, or that Policy A13 is changed to remove the proposed scale of development until such evidence is provided.

The following comments from education, minerals and waste, Adults Services and Health, highways & transport and public rights of way, do not affect the soundness of the Plan. However, Chichester District Council should take these into account and, where possible, make minor amendments to the Local Plan and/or evidence base studies before submission of the Local Plan for examination. Officers are happy to meet and discuss any of these comments, and proposed minor amendments to address these comments, ahead of submission:

1) Education

Land West of Chichester

Previous comments have been made requesting that the policy refers to ‘Phase 2 should include expansion of the primary school for the further 1FE of teaching accommodation with nursery and SEND provision’. While it is recognised that reference is made to this in the IDP this is a supporting document to the Local Plan and should not be solely relied on. It is requested that paragraph 10.19 is amended to read: ‘a local centre with retail, community and employment uses (minimum of approximately 2500 sqm E(g)(i) Use Class), two form entry (2FE) primary school and one form entry (1FE) teaching accommodation with nursery and SEND, informal and formal open space (including a country park), allotments,…’

This should also be included in the 3rd bullet point of Policy A6 or the wording of the policy should be drafted to reflect more recent policy requirements i.e. Provide for infrastructure and community facilities in accordance with the most recent Infrastructure Delivery Plan.

There are some inconsistencies with the wording of the strategic policies, not every policy includes the criterion ‘Provide for infrastructure and community facilities in accordance with the most recent Infrastructure Delivery Plan.’ While this may be due to some policies being carried through from the adopted local plan it is inconsistent.

Policy A8 Land East of Chichester

As an education authority WSCC do not request 1FE schools in line with government guidance. As per our earlier comments and discussions we requested a 2 FE primary school for the site.

3rd bullet point of Policy A8 should be amended to read: ‘A neighbourhood centre incorporating local shops, a community centre, flexible space for employment/ small-scale leisure uses and a one-form (expandable to two-form) two form entry primary school with provision for early years/ childcare and special educational needs and disability…’

2) Minerals and Waste

The references to safeguarding minerals is inconsistent and it is suggested that the wording in the email sent to CDC (attached) in relation to Policy AL3 should be used in the policies for the other sites for consistency. Reference to safeguarding minerals and waste infrastructure should also be included in some other policies as previously indicated:

• Policy A2 – needs to include reference to safeguarding minerals and waste infrastructure.
• Policy A7 – needs to include reference to safeguarding waste infrastructure.
• Policy A15 (Loxwood) – needs to include reference to minerals safeguarding as within the clay MSA.
• Policy A21 – needs to include reference to minerals safeguarding.

Also, the reference to the safeguarding guidance needs to be checked to ensure that it is worded correctly as ‘Minerals and Waste Safeguarding Guidance’.

3) Older Person Housing

It is noted that the plan refers to older person housing as specialist housing. WSCC strategy supports the provision of ‘extra care housing’ while this might be similar development it enables younger people to access the accommodation for whatever medical reason i.e. MS, strokes rather than limiting it to a certain age group. Officers are happy to meet and discuss this further.

4) Highways and Transport

Public Transport Priority Infrastructure

The Public Transport section of the main transport study report starting at paragraph 6.2.7 requires revisiting. There is reference to “an expansion of the bus priority lane system within Chichester City Centre” which does not match the existing bus provision in the City which does not provide bus priority lanes on street. It does have restrictions on motor traffic in the adjoining parts of South Street and West Street which provide for bus and cycle only access in both directions of travel plus access for essential goods vehicle loading in the westbound direction only. In addition, the suggestion in the following paragraph for “a time-based system where certain routes are restricted to public transport only during specific times” is not evidenced or developed and as such considered unlikely to be practical and enforceable at most locations used by bus routes in the City. More developed proposals for additional bus priority, improvements to bus passenger facilities or testing of specific locations for bus-only access would be welcomed as part of developing a costed sustainable transport mitigation package.

Park and Ride

The discussion of possible park and ride facilities for the City at paragraphs 6.2.9 to 6.2.16 of the main transport study should also acknowledge. An important part of making park and ride well used by motorists is increasing the price of city centre parking to provide a financial incentive to take up significantly cheaper park and ride charges for parking and travel. However, if park and ride sites are not provided accessible to all major approach routes to the city, such a charging strategy would not be seen to be equitable, whereas only a single site is proposed in the District Council’s emerging parking strategy and the report acknowledges at 6.2.11 that “locations for potential park and ride sites are also deemed to be limited”. The bullet at 6.2.15 “Cost of schemes compared to benefit are likely to be initially lower than highway schemes” may have been incorrectly worded given that this is listed as an issue rather than a benefit. The text may have been intended to say that the ratio of benefit to cost for park and ride schemes may be lower than for conventional highway schemes?

A286 New Park Road / A286 St Pancras Road (Junction 7)
This junction scheme includes pedestrian crossing facilities which are welcomed and also includes a length of advisory cycle lane starting in the middle of the junction for cyclists remaining on St Pancras. However, the approach to the junction on St Pancras from Eastgate Square remains intimidating to cyclists, so further measures would need to be added to make the layout cycle-friendly or the cycle facility is likely to be of limited benefit. This could include decreasing traffic speeds. Until this is done the conclusion at 8.4.4 of the main transport study; “The mitigation scheme includes improvements for pedestrians and cyclists which will lead to increased use of active travel modes and reduce the need for physical mitigation here” is only supported for pedestrians, not for cyclists.

A259 Via Ravenna / A259 Cathedral Way Roundabout (Junction 8)
It is stated at 7.3.8 of the main transport study that “the mitigation may be required to avoid queuing back towards the A27, as well as for capacity issues”. In light of this potential safety issue for the previous junction on Cathedral Way and for the A27 Fishbourne junction, the proposal at 7.3.6 that the scheme delivery should be tied to the monitor and manage regime to see if and when it is required is accepted. This is different to the approach for other junctions in the City because of the potential safety issue. This monitoring approach would be likely to follow after the A259 Cathedral Way / Fishbourne Road East / Terminus Road (as diverted) (Junction 10) improvement, which is to be brought forward as an integral part of the A27 Fishbourne roundabout mitigation scheme, but may allow for increased eastbound flows on Cathedral Way.

A286 Northgate Gyratory
An additional mitigation scheme is proposed at paragraph 7.3.134 of the main transport study for the A286 Northgate Gyratory along its southern arm from Oaklands Way to Orchard Street. The proposal to add traffic signals is welcomed in concept as it can help to control traffic speeds making the junction more friendly for cyclists and pedestrians. However, the layout shown at figure 7-8 does not maximise the opportunity to improve convenience and safety for pedestrians by providing a priority link to reach the central island, which contains employment space and the fire station, nor to assist crossing the exit towards Orchard Street. The scheme would benefit from further development to prioritise active travel movements and should also be fitted with transponders for bus priority.

Fishbourne Road West / Appledram Lane South (Junction 11)
At paragraphs 7.4.1 to 7.4.2 of the main transport study, the junction of Fishbourne Road West / Appledram Lane South (Junction 11) is considered. The proposal to mitigate impacts at this junction through delivery of the Stockbridge Link Road scheme is not considered deliverable, so the approach at this location requires re-thinking. The County Council would not support measures to increase capacity for through traffic on Appledram Lane South, the approach should be to reduce severance and improve safety and comfort for active travel on Appledram Lane by reducing vehicle speeds and as far as possible volume. This should consider the needs of pedestrians and cyclists both for local access and for users of the Salterns Way leisure cycling route.

TEMPro Background Traffic Growth Comparisons
At section 10.2 of the main transport study a comparison is made of the TEMPro 7.2 growth rates used in the study for external traffic with new TEMPro 8.0 growth rates since released by the Department for Transport, which notes that the TEMPro 8.0 rates are significantly lower, if these rates were used then the level of transport impacts could be lower. Unfortunately, a number of highways authorities in the Transport for the South East (TfSE) area including the County Council and Hampshire County Council have concerns that the planning assumptions used in TEMPro v8 core growth scenario underestimate the numbers of additional households forecasted compared to targets in adopted Local Plans for delivering new dwellings. TfSE are currently raising these collective concerns with DfT with a view to obtaining an early update to TEMPro 8 planning assumptions. Although for the purposes of this study TEMPro is not applied to trips produced in Chichester District, from the County Council’s analysis TEMPRo v8 core underestimates the increase in households per year in Arun District by over 50% and in Horsham District by 30% when compared with adopted development plans. On this basis it may be useful to instead compare TEMPro 7.2 with TEMPro 8.0 high growth scenario.

North of District Spatial Scenarios Testing
For the Northern Spatial Scenarios Test provided as an appendix to the main transport study, this had not been updated for the final preferred spatial strategy or in light of the County Council’s previous comments on the March 2022 issue to the District Council. The spatial strategy now is similar but not identical to the Scenario 4: Significant Growth 1 option in the reported tests, totalling 370 dwellings across the four northern parishes, compared to 410 in the test. In both cases the largest allocation is at Loxwood; 220 dwellings were proposed in the Scenario 4 as compared to 200 in this test. Some other tests proposed higher numbers.
The testing in the northern part of the district had used the same trip generation rates per dwelling as in the South of the District, but the County Council considers that in practice private motor vehicle trip generation per dwelling is likely to be higher due to the rural nature of the area, including a lack of local facilities and shops within walking distance of development, a very low level of public transport services and lack of surfaced cycle routes.
The level of development proposed is not at the level capable of delivering transformative transport improvements to match the trip making patterns around Chichester and the A259 corridor to Bosham and Southbourne. This may be offset in part by the lower total amount of development compared to the tested scenario 4. Nonetheless, it would be helpful to adjust the scenario for the spatial strategy now proposed and to provide information on additional traffic movements per peak hour from these parishes using the A272 at junctions at Wisborough Green and reaching the A272/A29 junction at Billingshurst and the A272/A283 junction at the north of Petworth.

Neutral Month and Summer Month Comparison Technical Note
The Neutral Month and Summer Month Comparison Technical Note in the main transport study treats July as a neutral month rather than a summer month. Paragraph 1.3.1 states “The flows were analysed by looking at traffic data for August 2019 this being considered to represent summer traffic. This was compared against traffic data from the neutral months of June, July, September and October also from 2019.” The County Council does not accept this methodology as school summer holidays start part way through July and education traffic is also affected by the formal exam period, whilst there is typically a high level of seasonal leisure traffic including summer outdoor events in this month. It is acceptable to use August alone as the summer comparator month. However, July traffic should be removed from the neutral months analysis and should be substituted with May traffic data from the same year of 2019, provided that sufficient data is available from that month.

5) Public Rights of Way (PRoW)

It is a positive step to see PRoW acknowledged as valued by communities and as part of the area’s green infrastructure. Whilst Policy P14 (Green Infrastructure) states that development proposals should not be detrimental to the network of public rights of way and bridleways (please note bridleways are Public Rights of Way), a more proactively positive approach that seeks enhancements to the network as mitigation, would be welcomed. The improvement, upgrading of existing PRoW and creation of new PRoW where possible, to allow for a greater number of users to access the network would be beneficial. This is somewhat addressed in Policy T1 which refers only to routes identified in the Local Transport Plan, Local Cycling and Walking Infrastructure Plan (LCWIP) and the Infrastructure Delivery Plan. Opportunities to these, should not be limited if they arise elsewhere.
It is surprising to see there is no mention of PRoW within Chapter 8 under Active Travel – Walking and Cycling. The PRoW network provides extensive walking and cycling opportunities, often off-road, and important links between places and non-PRoW routes.