Chichester Local Plan 2021 - 2039: Proposed Submission

Object

Representation ID: 3840

Received: 24/02/2023

Respondent: The Bosham Association

Legally compliant? Yes

Sound? No

Duty to co-operate? No

Building 84% (8717 houses) of the allocated housing along the east-west corridor is not justifiable. There are no guaranteed upgrades to the sewage network or the strategic road network in this area. The areas proposed rely on wastewater treatment facilities which are already over capacity. The road network cannot cope and there are modelled peak time delays of 29 minutes to access the Fishbourne roundabout if this scale of development goes ahead. The Fishbourne roundabout has been over-capacity since 2014 and no measures have been taken to improve the situation. There is nothing guaranteed in the plan to address this.

The housing distribution seeks to reconcile a range of factors in order to achieve the most sustainable approach to the distribution of development. This is set out in the more detail within the Sustainability Appraisal and Housing Distribution Background Paper.

Development of the strategic allocations will be subject to the requirements of the Local Plan natural environment policies, particularly Policy NE2 (Natural Landscape), NE5 (Biodiversity) and NE13 (Chichester Harbour AONB) and the site specific requirements set out in the strategic allocation policies.
The proposed modifications to Policy T1 Transport Infrastructure set out the council’s approach to securing transport mitigation to support the planned growth.

Object

Representation ID: 3841

Received: 24/02/2023

Respondent: The Bosham Association

Legally compliant? No

Sound? No

Duty to co-operate? No

The legislation we believe this refers to includes: the Chichester Harbour Conservancy Act 1971, Wildlife and Countryside Act 1981 and Conservation of Habitats and Species Regulations 2017. 4.27 of the proposed local plan makes it clear that the paragraph above applies to the harbours. Chichester Harbour is currently being impacted adversely by sewage outflows. The outflows at Bosham discharged more than any other site in 2022 (882.38 hours or 36.8 full days. There is no mitigation proposed in the plan for dealing with this.

Objection and proposed change noted. i) Policies NE16 and NE19 (referenced in NE6 and para. 4.27) and their supporting text specifically recognise impacts on water quality (including within Chichester Harbour) from sewage effluent from wastewater treatment works, with required mitigations for development. These references are considered to provide sufficient acknowledgement and mitigation of habitat impacts, as recognised within the HRA.ii) The change proposed (removal of Policy A11) does not relate to this policy (objections have also been recorded against Policy A11).

Object

Representation ID: 3842

Received: 24/02/2023

Respondent: The Bosham Association

Legally compliant? Yes

Sound? No

Duty to co-operate? No

The strategic gap between Fishbourne and Bosham has been placed in the wrong place during the assessment as it is not a clear break between settlements. The land at Highgrove is the first clear break with open fields on either side. If development is allowed on the site proposed at policy A11 there will be no open field space between Bosham and Fishbourne.

Comments noted. The detailed location and boundaries of landscape gaps will be considered and assessed through either the subsequent Site Allocations DPD that will follow on from the Local Plan or be undertaken as part of a relevant neighbourhood plan.

Object

Representation ID: 3843

Received: 24/02/2023

Respondent: The Bosham Association

Legally compliant? No

Sound? No

Duty to co-operate? No

To propose development on the scale suggested in the proposed local plan where there is no timetabled plan clearly defined to upgrade the sewerage network or increase capacity for wastewater treatment could be argued to be a dereliction of the statutory duty, mentioned in paragraph 4.26

Objection and proposed change noted. i) The matter of water management and water quality is addressed by Policy NE16 and its supporting text. Paragraph 4.27 recommends that Policy NE6 should be read in conjunction with Policy NE16 (amongst others) and it is therefore considered unnecessary to duplicate information from NE16 within NE6 and its supporting text (objections have also been recorded against NE16 and supporting text) ii) The changes proposed do not relate to this policy (objections have also been recorded against Policies A11, A12 and A13).

Object

Representation ID: 3844

Received: 24/02/2023

Respondent: The Bosham Association

Legally compliant? Yes

Sound? No

Duty to co-operate? No

There is no capacity within the strategic road network to accommodate the additional traffic the housing proposed in this plan will create and there is no guaranteed upgrade to the strategic road network planned. The proposed local plan seems to predate the Chichester District Council’s Local Plan Transport Assessment (CDCLPTA) which was released in January 2023. The transport assessment confirms what residents have known for the last 10+ years: the strategic road network is at capacity. The CDCLPTA was aware that the 6 major junctions were at capacity in 2014 and nothing has been done since to improve the situation.

The Local Plan Review Transport Studies (2023 & 2024) were commissioned to provide evidence to support the Local Plan. This highlights that in the base year (2014) and baseline scenario without the emerging Local Plan development, a number of junctions already experience capacity issues. Policy T1 has been developed to mitigate the impact of planned development on the Strategic Road Network, improve highway safety and air quality and promote more sustainable travel patterns.
ii) The strategy set out in Policy T1 will support the level of development that is proposed by the Plan. Therefore, there is no justification for the removal of Policies A11 and A12.
iii) as above in relation to limiting Policy A13 to 300 homes.

Object

Representation ID: 3845

Received: 24/02/2023

Respondent: The Bosham Association

Legally compliant? Yes

Sound? No

Duty to co-operate? No

The local plan cannot guarantee any major road improvements to mitigate congestion and building housing on the scale proposed in the local plan is guaranteed to exacerbate the congestion and pollution levels in the Chichester District. Currently every major junction is well over capacity at peak times and has been since the last local plan was produced in 2014. The roads are becoming unusable and adding 10000 houses to the district with no mitigation is against the wishes of the residents who have made Chichester District Council aware of the problem.

i) The strategy set out in Policy T1 will support the level of development that is proposed by the Plan.
ii) Given that the strategy set out in Policy T1 supports the level of development that has been proposed in the Local Plan, there is no justification for the removal of Policies A11 and A12

Object

Representation ID: 3846

Received: 24/02/2023

Respondent: The Bosham Association

Legally compliant? Yes

Sound? No

Duty to co-operate? No

Emphasis in the plan is use of public transport or walking. Sites in policy A11 and A12 have no primary school capacity and have no room for expansion. Schools identified to serve these sites are not within walking distance or reachable by public transport. Among the schools identified as suitable for the A11 and A12 sites are Funtington, Compton and Up-Marden, Westbourne and Thorney Island. These schools do not have transport links and are not within walking distance of A11 and A12 sites.

This representation recommends changes to Policies A11 and A12 and not to Policy T1. See responses to Policies A11 and A12 as well as latest Infrastructure Delivery Plan.

Object

Representation ID: 3852

Received: 28/02/2023

Respondent: The Bosham Association

Legally compliant? Yes

Sound? No

Duty to co-operate? No

Many of the sites chosen in the local plan are outside of settlement boundaries which means the presumption in favour of sustainable development does not apply. This is the case with policy A11 where the whole development lies outside of the settlement boundary.

Allocated sites do not need to be within a settlement boundary. In accordance with the Council’s methodology for reviewing settlement boundaries (as set out in the Settlement Boundaries Background Paper (May 2024)), settlement boundaries will be extended to include allocated sites once they have been built out.

Object

Representation ID: 3853

Received: 28/02/2023

Respondent: The Bosham Association

Legally compliant? Yes

Sound? No

Duty to co-operate? No

Policy A11 has received a large number of objections from people living in Bosham and was the least favoured proposed site when the neighbourhood plan was written. Policy S2 has not been followed to allocate the site proposed in Policy A11 because it is fully outside of the settlement boundary and is therefore countryside and should be protected. The Bosham Association represents the views of its 400 members who are all opposed to Policy A11. There were hundreds of objections to the planning permission application and several people attended the planning committee meeting when permission was being considered.

See response to Policy A11 (rep 3928)

Object

Representation ID: 3854

Received: 28/02/2023

Respondent: The Bosham Association

Legally compliant? Yes

Sound? No

Duty to co-operate? No

The site at Policy A11 does nothing to support the rural economy or allow the local community to thrive. There is a proposed 3rd village hall as part of the development which is neither wanted or needed and allotments which were specifically argued against at the planning consultation stage. The development in the plan proposed for the A259 corridor will exacerbate local traffic congestion and put a strain on the already overwhelmed sewerage system, strategic road network and resources such as the village shop and oversubscribed Dr surgery.

The spatial strategy seeks to locate the majority of development in locations which have access to a range of services and facilities, informed by the settlement hierarchy evidence. This has also been influenced by site availability, suitability, environmental and other constraints.
Assessment of traffic impacts from planned strategic development forms part of the transport evidence base. NE2 Landscape Policy and NE13 Chichester Harbour AONB provide specific protection in relation to the AONB and the SDNP