Chichester Local Plan 2021 - 2039: Proposed Submission

Agreed Statements of Common Ground need to agreed before the Draft plan is examined in public so that all parties can debate the practicality as well as the desirability of the key allocations. There are an absence of transport measures proposed, especially sustainable and active, to address the current levels of congestion, pollution and degradation of the environment.

No Statement of Common Ground has been agreed with neighbouring authorities and key statutory undertakers as required. e.g. National Highways. It is not sufficient to say this will be done in the future as many the large housing proposals require key infrastructure to be agreed in advance of development.

The Plan should take greater account of Climate Change commitments made at Cop 26 for instance. This could have been done and been subject to public consultation.

The last public consultation stage concluded in February 2019, as set out in the latest Statement of Community Involvement published in Nov. 2018. Many matters have changed since then, especially Government policy.

The sites which are uncommitted should only be released conditional on infrastructure being in place commensurate with development.

This policy does not pass the test of soundness as it does not PHASE the release of the uncommitted housing sites. Despite 62% of the overall allocation already being built or committed, equating to 10 years land supply, the remaining 3300 are not constrained. As a consequence such sites could be granted Permission without the necessary infrastructure being in place.

Amend allocation policies to include conditions that a site may only come forward after specific infrastructure requirements have been met.

As an example, site A11, Highgrove farm, subject to a current application should only be released when Transport and Wastewater infrastructure is at least committed.

See Alternative Policy attached which is supported by West Sussex Cycle Forum and local volunteers of Sustrans.

This policy does not safeguard existing and proposed routes for walking and cycling and does not provide a mechanism to fund such improvements.

Basically there is a lack of priority in the plan to sustainable and active travel modes. All funding seems to be based on highway improvements to the A27 to accomodate the anticipated increase in car trips with no mitigation and no certainty of infrastucture improvements occuring in line with land release.

There needs to be clear agreement with the relevant statutory undertakers as to when the deficiencies in infrastructure will be rectified, so that housing land release is phased in line with such provision. This should be set out in an agreed Statement of Common Ground.
In relation to traffic mitigation to relieve congestion and to shift travel to sustainable and active travel modes the draft polices lack teeth to achieve these aims. Again land release for development should follow from such transport investment, not proceed it.

While the objective says all the right things the policies which follow in in draft Plan Policies will not achieve the stated objective..

Point 6 should be replaced by a Policy which specifically identifies the routes etc. needed, safeguards them, and requires funding to allocated to them.

While there is a lot to support in this policy and we would agree with the following analysis in relation to active and sustainable travel;
"Poor road accessibility and problems of traffic congestion result from the limited road connections to the north, the junctions on the A27 Chichester Bypass, and increased traffic during the summer holidays and major events in the district. There are reasonably regular bus services serving Selsey, East Wittering and the other main settlements on the Peninsula, however, these are more limited in terms of evening and weekend services. Direct off-road cycle paths and pedestrian routes are also lacking. These problems of accessibility are further accentuated by the fact that the Peninsula relies strongly on Chichester city for employment, shopping, entertainment and other key facilities, which increases the need to travel."
there are no substantive policies to rectify this situation.

As set in the attached document infrastructure investment in transport to relieve existing congestion, and to enable greater use of sustainable and active travel modes, needs to be given priority over more land release for development.

This policy will be ineffectual because it does not REQUIRE the necessary infrastructure to be phased, committed and provided in advance of the newly proposed land release for housing. There is no agreed Statement of Common Ground, especially with National Highways and Southern Water.

Agreed Statements of Common Ground need to agreed before the Draft plan is examined in public so that all parties can debate the practicality as well as the desirability of the key allocations. There are an absence of transport measures proposed, especially sustainable and active, to address the current levels of congestion, pollution and degradation of the environment.

No Statement of Common Ground has been agreed with neighbouring authorities and key statutory undertakers as required. e.g. National Highways. It is not sufficient to say this will be done in the future as many the large housing proposals require key infrastructure to be agreed in advance of development.