Chichester Local Plan 2021 - 2039: Proposed Submission

Include strategies for agriculture use of pesticdes.

Mitigations are a cop out and difficult to monitor over time. As nitrates from agriculture are a large part of the problem where are the strategies to minimise the use of pesticdes and certain kinds of fertilisers?

Two separate policies for water supply and wastewater.
Amend the status of water companies and amend the Water Act.
A more robust policy.

Water supply and wastewater should be dealt with as two separate polices. There is nothing in this policy to prevent applications being approved when connection to WWT is not possible. There should be NO new development in the Thornham Catchment until such time as upgrades to the system have been completed, proposals for which have not been finalised. To do so risks further storm overflows which have been polluting the Harbour for months and completely unsatisfactory solutions such as tankering of waste material from new developments because Southern Water will have issued a letter confirming connection to their network to the developer even though they know that their wastewater treatment plant did not have this capacity. We have requested both the DLUP who have passed on the request to DEFRA that Southern Water and indeed all water utilities are made statutory consultees on all sizeable planning applications. This is essential and needs to be done urgently. Add this bit to the bit on have you told us about this before?

A baseline needs to be established to prevent sites being cleared and evidence lost. This has happened in Chidham where sites have been stripped of vegetation before an application has been submitted. What would constitute evidence that this has happened? What would the penalties be? CDC Ecologists and Enforcement should be present when such works are scheduled. We have examples of where this has happened – planning application for Chaswood. This site was completely stripped before a planning application was sought. Planning application CALA Homes stripped out 80% of an entire hedge to make a temporary entrance which has now been superceded by the main entrance.

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The locations and level of housing will not minimise the need to travel by car. The A27 improvements need to be in place before the housing before it becomes impossible to travel and the climate change targets are breached. Public transport requires increased capacity, infrastructure and frequency which will need considerable investment. Is this going to be provided by Southern Rail and Stagecoach? Where is the collaboration? The West Sussex Bus Plan does not address how this will happen. There is too heavy a reliance on developer contributions for all aspects of travel, including local networks and active travel.

We think that it is essential that infrastructure preceeds development.

Reduced housing numbers away from rural semi-rural locations.

The locations in this area, in the A259 corridor are not sustainable. The number of car journeys for day to day facilities will increase. Most of this traffic will be using the Fishbourne roundabout which will not be improved for a number of years. In the first instance development should be directed at city locations where the need for a car will be less.

Remove policy from the Plan.

This is an entirely inappropriate location for this scale of development. It is in direct conflict with many polices on climate change, the environment, use of agricultural land ,the AONB and its setting, wildlife habitats, protecting long distance views, open countryside and settlement gaps.

Limit the allocation of houses to the number of houses currently permitted to this date i.e 144.

Permissions have already been given for 144 homes to be built (2021-2023}. To deliver the Local Plan number of 300 homes, a further 156 homes would be required which is more than Nutbourne and Hambrook could absorb. It should be noted that an additional 248 dwellings are pending Appeal. The Local Plan allocation of 300 homes would increase by 30% the overall number of dwellings in a small, semi-rural location. To put this context the indicative housing number for the Parish in 2014-2019 plan was 25.
There are numerous constraints which would be difficult or impossible to overcome while adhering to policies in the Plan.
Agricultural Land
All the sites identified in the HELAA are green field and the vast majority are viable and productive grade 1 and 2. At a time when food security is so much at risk and our need for self-sufficiency is growing, these need to be preserved. To find sites for a further 156 homes would inevitably mean building on these fields. The HELAA is based on available land, whether or not it is suitable.
Local facilities
These are very limited and more so than adjacent parishes. There is no viable grocery store, medical facilities or sports facilities. Accessing any of these requires a journey, impracticable by public transport and too far for walking. The Primary School is in Chidham,1.2 miles away from the Northern part of Hambrook. There is no public transport north to south. Trains are irregular and infrequent with a service running hourly. The one bus service, along the A259, has recently been reduced to half hourly. Anyone needing to access day to day services will be travelling elsewhere and with the absence of reliable, frequent public transport and the distance required to walk them, these journeys will be made by car. It is therefore not a sustainable location which will reduce the need for car use.
Wildlife and biodiversity
Several sites in the HELAA are within the designated Wildlife Corridors. If Policy NE4 is to be adhered to no development should take place to protect the transit of wildlife and essential connectivity between the SDNP and AONB. Housing with associated noise, lighting and pollution cannot protect and enhance the integrity of any Wildlife Corridor.
Long-distance views
The setting of our villages is characterised by a flat landscape and long-distance views to the SDNP and the Harbour. Locating a further 156 homes on any of our available sites will destroy these views.
AONB and setting
At least half of our parish is in the AONB. Further development will result in increased recreational disturbance and will accelerate the depletion of Chichester Harbour. These impacts cannot be successfully mitigated, particularly when mitigation is allowed off site.
Settlement Boundaries/Gaps
Building 156 further homes will erode our settlement gaps, both between the parish and neighbouring Southbourne, and within the two settlements of Nutbourne and Hambrook. The gaps identified should be respected.
Roads
All new residents will need to access the A259, which is rapidly reaching capacity. Close to 2000 additional homes have been allocated to this corridor. The A27 is already over capacity and the Fishbourne roundabout, which most new residents will use to access the A27, is in need of upgrading. This will not happen before any housing is built resulting in increased peak time delays and a decrease in air quality.
The A259 has inadequate infrastructure for walking or cycling. Cycling lanes are inconsistent, frequently disappearing altogether, and those that are there are too narrow. Cyclists feel increasing unsafe on this busy road.
To reach local facilities would require longer walks than the Government’s suggested 2km to access facilities on foot.
Wastewater
Thornham Wastewater Treatment Plant can currently only connect to 178 new properties (Feb 2023). ‘There is at present no certainty of a deliverable solution for the Thornham catchment and any solution will time to deliver’.(Thornham/CDC Position Statement Nov 201). It is therefore clear that there is not sufficient capacity now or for the foreseeable future.
Southern Water have not yet published their DWMP so there is no guarantee that investment will be available, how much or over what period.
The sewage network is not working now with 256.26 hours of discharges into the Harbour from Thornham since 1 January 2023. This is on top of total releases during the 2022 calendar year of 257.82 hours.(Classified as genuine by the Southern Water Beach Buoy system 14 Mar 2023)
Residents’ consultation
We see it as part of our duty, as a Parish Council representing our residents, to reiterate a very clear message from the detailed consultation we carried out with our residents in the Summer of 2021, where residents indicated consideration concern as substantial increases of houses in the parish.

Include an integrated transport hub in the Plan.

To demolish the bus station and not replace it with a transport hub integrated with the railway station is a profound mistake. ’One of the main aims of this regeneration project is to enhance the use and accessibility of public transport’. That will not be achieved by locating bus stops randomly along Avenue De Chartres, some distance from the train station, with no toilet facilities, rest rooms, seating or refreshments. Those who rely on public transport need to be in a place where they can see their onward travel options, do not have to move far to access them and can use facilities. Bus travel is not pleasant in the city and this will make it less so. This is more likely to decrease the use of public transport. This applies to those both arriving in the city as visitors or residents. The transport hub at Portsmouth Hard has done this with considerable success. This is a profound mistake and a missed opportunity.

More emphasis on housing rather than retail

This is an opportunity to provide much needed sustainable, affordable housing, which would attract younger people to make their homes in the city. There is too much emphasis on retail, café and restaurant use which could be in danger of becoming a white elephant like Chichester Gate. 170 homes on two sites is profoundly unambitious. Creative master planning is needed to take advantage of the space in building a significant number of affordable homes sustainably located without the need for car ownership. Retail uses should be directed to the city and not take the place of housing.