Chichester Local Plan 2021 - 2039: Proposed Submission

This site allocation has areas of Flood Zones 2 and 3 within its boundary. Therefore, we are supportive of the site-specific requirements that the site design should minimise the risk of flooding from all sources and where possible, reduce flood risk overall (requirement 12).

As for all site allocations, we are supportive of the policy requirement for suitable phasing to ensure adequate wastewater treatment capacity is available (requirement 9).

We are supportive of policy requirement 12 given that part of the site fall within areas of high fluvial flood risk. Flood storage capacity must be retained, or compensated for on a level-by-level basis with hydrological connection to the existing floodplain. Residential development must be directed to areas of the site at lower flood risk.

As for all site allocations, we are supportive of the policy requirement for suitable phasing to ensure adequate wastewater treatment capacity is available (requirement 13).

Additional wording to requirement 12 b:

“Any new additional culverts must be kept to an absolute minimum with alternative approaches explored first, such as natural flood management measures. Any new culvert must be designed in such a way so as to limit their impact on the watercourse, such as by allowing for a suitable depth of substrate to reflect the natural watercourse bed and including mammal ledges as appropriate.”

We note that Phase 1 of the site is connecting to Tangmere Wastewater Treatment Works (WwTW) due to the constraints on the Apuldram WwTW. Subsequent phases of the site are reliant on additional capacity at Tangmere WwTW. The Local Authority must be satisfied at the time of any planning application for future phases that such wastewater capacity exists, and appropriate phasing must be secured via conditions to ensure that occupants are not reliant on package treatment plants or removal of wastewater by tanks. Requirements 14 and 15 deal with this to a certain extent.

We are concerned about requirement 12 b which says “Provide mitigation for any loss of watercourse habitat resulting from culverting for highway provision in the development.” We would strongly discourage adding more culverts to watercourses as they are likely to have adverse impacts on flood risk, ecology, human health and safety and amenity whilst increasing maintenance costs and hindering future options to restore the watercourse. The latest Planning Practice Guidance for Flood risk and coastal change says that proposals to introduce new culverting are likely to run contrary to natural flood management objectives and the objectives of River Basin Management Plans (paragraph 067). Therefore, We would recommend the following addition to that requirement:

“Any new additional culverts must be kept to an absolute minimum with alternative approaches explored first, such as natural flood management measures. Any new culvert must be designed in such a way so as to limit their impact on the watercourse, such as by allowing for a suitable depth of substrate to reflect the natural watercourse bed and including mammal ledges as appropriate.”

As for all site allocations, we are supportive of the policy requirement for suitable phasing to ensure adequate wastewater treatment capacity is available (requirement 11).

We would wish to see built development located solely within Flood Zone 1.

As for all site allocations, we are supportive of the policy requirement for suitable phasing to ensure adequate wastewater treatment capacity is available (requirement 15).

We would wish to see built development located solely within Flood Zone 1.

There is a small section of Flood Zone 3 on this site. We are supportive of policy requirement 1, that built development must be directed away from the floodplain of the River Lavant. We are also supportive of requirement 7, that flood risk management must be part of the masterplanning for the site.

As for all site allocations, we are supportive of the policy requirement for suitable phasing to ensure adequate wastewater treatment capacity is available (requirement 11).

This policy lacks reference to appropriate phasing for wastewater infrastructure. This should be added as per other site allocation policies.

This policy lacks reference to appropriate phasing for wastewater infrastructure. This should be added as per other site allocation policies.

We are supportive of policy requirement 11 regarding appropriate investigation and remediation of the former landfill site. Remediation measures must have regard to any risks to groundwater quality.

As for all site allocations, we are supportive of the policy requirement for suitable phasing to ensure adequate wastewater treatment capacity is available (requirement 12).

As the specific site is not allocated, we are supportive of policy requirement 10 that allocations take a sequential approach to flood risk.

As for all site allocations, we are supportive of the policy requirement for suitable phasing to ensure adequate wastewater treatment capacity is available (requirement 11).

As the specific site is not allocated, we are supportive of policy requirement 12 that allocations take a sequential approach to flood risk.

As for all site allocations, we are supportive of the policy requirement for suitable phasing to ensure adequate wastewater treatment capacity is available (requirement 13).