Chichester Local Plan 2021 - 2039: Proposed Submission

We strongly support an amendment to be made to Policy H2 to allow for the provision of circa (or a minimum of) 1,250 dwellings at Southbourne

We broadly support the sixteen development requirements included within the allocation wording of emerging policy A13; these are briefly addressed in turn below;

Provide an appropriate mix of housing types, sizes and tenures to meet evidenced local need including affordable housing and specific provision to meet specialised housing needs including 16 serviced self/custom build plots, accommodation for older people and accessible and adaptable homes in accordance with relevant Plan policies; The scheme would present an emerging policy compliant mix of housing types and tenures. We would look to work closely with the local community to identify the appropriate location and phasing for self and/or custom build plots within the Masterplan to ensure the plots come forward in a suitable location that has been considered alongside the wider masterplanning exercise.
Provide 12 gypsy and traveller pitches in accordance with Policy H11; Whilst we recognise the need for the provision of G&T pitches within the District; based on the previous discussions with the Neighbourhood Planning group and local community we feel that the Council would benefit from exploring more appropriate areas for new sites and/or the intensification of nearby sites.
Provide a serviced site(s) for travelling showpeople which should deliver 12 plots, each of sufficient size to allow for the provision of accommodation and equipment plus storage/maintenance, in accordance with Policy H11; As above.
Provide a suitable means of access to the site(s), securing necessary off-site improvements (including highways) in conformity with the Policy T1 (Transport Infrastructure) and T2 (Transport and Development) to promote sustainable transport options; The comprehensive masterplanning approach that has been and will continue to be taken with the scheme will ensure a cohesive layout and access arrangement to best integrate with the existing community. Paragraphs 2.20-4 above outline our recommendation to the Council with regards to infrastructure improvements and we maintain that the most effective way of securing on- and off-site improvements is to place the onus on the developer to ensure their delivery and integration with the local community.
Provide any required mitigation to ensure there is no adverse impact on the safety of existing or planned railway crossings; Any submission will be supported by a robust transport assessment and mitigation strategy.
Ensure adequate provision of supporting infrastructure including education provision, community facilities and transport in accordance with the most up to date Infrastructure Delivery Plan; We support the need for supporting infrastructure, which forms a primary objective of the proposals on last east of Southbourne. We feel that their delivery will be most appropriately secured outside of the limitations of CIL.
Give detailed consideration of the impact of development on the surrounding landscape, including the South Downs National Park and Chichester Harbour AONB and their settings. Development should be designed to protect long-distance views to the South Downs National Park; We support the desire to protect these areas and their settings. Any submission will be supported by a full landscape and visual impact assessment to demonstrate that the scheme east of Southbourne can be a cohesive visual element into the existing built form of the village and avoid any element of incongruousness or harmful impact on the surrounding protected areas.
Ensure that multifunctional green infrastructure provision is well related to the overall layout and character of the development as well as providing opportunities to extend into the wider countryside and surroundings; The proposed scheme to the east of Southbourne would be capable of delivering a significant portion of the Green Ring, originally allocated in the Southbourne Neighbourhood Plan 2015. The Consortium is also supportive of a central feature through the site and the approach to align the Green Ring with the north-south public right of way which connects with the green infrastructure on the eastern edge of the neighbouring Cooks Lane development. This approach would allow the green ring to be cohesive with the neighbouring green infrastructure, whilst also maintaining the public rights of way, in conformity with paragraph 98 of the NPPF. Whilst this central ‘Inner’ Green Ring could include play, gym trail, walking and cycling, benches and a variety of greenspace (amenity and natural), which would create a varied and engaging corridor, we would work wish to with the Neighbourhood Plan Group to identify the best mechanism to position sports and allotments through a masterplanned approach.
Demonstrate that development would not have an adverse impact on the nature conservation interest of identified sites and habitats including the strategic wildlife corridors; We support the desire to protect key habitats and the scheme will be informed by extensive habitat surveys and mitigation strategies.
Provide mitigation to ensure the avoidance of adverse effects on the SPA, SAC and Ramsar site at Chichester Harbour including contributing to any strategic access management issues, loss of functionally linked supporting habitat and water quality issues relating to runoff into a European designated site; We echo the need to avoid adverse effects on the SPA, SAC and Ramsar site at Chichester Harbour and all necessary mitigation will be provided on- and off-site where required.
Protect any other key views; We support the desire to protect the key views of the wider area. Any submission will be supported by a full landscape and visual impact assessment.
Ensure that allocations and policies accord with the sequential approach to flood risk, and that development will be safe for its lifetime, taking account of climate change impacts, as per the requirements set out in national policy and having due regard to the council's latest Strategic Flood Risk Assessment; We support this requirement and discussions with the Environment Agency and the LLFA will inform the most effective flood mitigation and drainage strategy for the site.
Ensure sufficient capacity within the relevant wastewater infrastructure before the delivery of development as required; Addressed in Paragraphs 2.5-10 above, we have concerns regarding the emerging plan’s wording around the future capacity improvements of WwTW in the Apuldram catchment.
Demonstrate that development would not have an adverse impact on the significance of heritage assets or their settings; Any submission will be supported by a full heritage assessment and the layout and scale will be adjusted accordingly to best protect any nearby heritage assets.
Maintain the character and integrity of existing settlements and provide clear separation between new development and neighbouring settlements including through the definition and protection of landscape gaps. The consortiums approach allows for the masterplan to be designed to best protect the existing settlement of Southbourne from any coalescence with surrounding hamlets. The location of development to the east of the village and the inclusion of the Green Ring is the most appropriate and effective way to protect the village’s visual separation and identity.
Consider the Minerals Safeguarding Area and in line with the West Sussex Joint Minerals Local Plan, a minerals resource assessment may be required to assess if the land contained a mineral resource that would require extraction prior to development. Account should also be taken of the West Sussex Waste Local Plan and associated guidance in relation to safeguarding policy W2. We support this inclusion, and any proposal will be accompanied by a minerals resource assessment if needed.

In general, we support the comprehensive masterplanning approach for development in Southbourne. Our proposals are the result of a complete collaboration between landowners and reiterate that the Consortium has always maintained a desire to deliver a comprehensive development that secures substantial benefits to the existing community. It is obviously important that any landowners included within the proposed allocation are required to work collaboratively with others and the local community, sharing the overall infrastructure and policy requirements fairly and proportionately.

We strongly support an amendment to be made to Policy H2 to allow for the provision of circa (or a minimum of) 1,250 dwellings at Southbourne. The accompanying sustainability appraisal, discussed later, supports a larger quantum of development on this site, with benefits realised of accessibility, environmental quality, climate change mitigation, community enhancement, health, historic environment and landscape. A major element of our proposals at Southbourne are in the infrastructure and community improvements to the local residents and increasing the overall housing numbers by less than 20% on this site is key in the wider delivery of package of the infrastructure improvements associated with the scheme.

There is no intention to deliver piecemeal development proposals within the area, which would likely prejudice the delivery including infrastructure delivery. We maintain the most effective way to ensure the infrastructure improvements associated with the scheme would come forward at an effective and appropriate time would be to remove the need for the proposals to contribute to CIL and instead have a direct commitment between the scheme and the improvements to Southbourne.

We broadly support the sixteen development requirements included within the allocation wording of emerging policy A13; these are briefly addressed in turn below;

Provide an appropriate mix of housing types, sizes and tenures to meet evidenced local need including affordable housing and specific provision to meet specialised housing needs including 16 serviced self/custom build plots, accommodation for older people and accessible and adaptable homes in accordance with relevant Plan policies; The scheme would present an emerging policy compliant mix of housing types and tenures. We would look to work closely with the local community to identify the appropriate location and phasing for self and/or custom build plots within the Masterplan to ensure the plots come forward in a suitable location that has been considered alongside the wider masterplanning exercise.
Provide 12 gypsy and traveller pitches in accordance with Policy H11; Whilst we recognise the need for the provision of G&T pitches within the District; based on the previous discussions with the Neighbourhood Planning group and local community we feel that the Council would benefit from exploring more appropriate areas for new sites and/or the intensification of nearby sites.
Provide a serviced site(s) for travelling showpeople which should deliver 12 plots, each of sufficient size to allow for the provision of accommodation and equipment plus storage/maintenance, in accordance with Policy H11; As above.
Provide a suitable means of access to the site(s), securing necessary off-site improvements (including highways) in conformity with the Policy T1 (Transport Infrastructure) and T2 (Transport and Development) to promote sustainable transport options; The comprehensive masterplanning approach that has been and will continue to be taken with the scheme will ensure a cohesive layout and access arrangement to best integrate with the existing community. Paragraphs 2.20-4 above outline our recommendation to the Council with regards to infrastructure improvements and we maintain that the most effective way of securing on- and off-site improvements is to place the onus on the developer to ensure their delivery and integration with the local community.
Provide any required mitigation to ensure there is no adverse impact on the safety of existing or planned railway crossings; Any submission will be supported by a robust transport assessment and mitigation strategy.
Ensure adequate provision of supporting infrastructure including education provision, community facilities and transport in accordance with the most up to date Infrastructure Delivery Plan; We support the need for supporting infrastructure, which forms a primary objective of the proposals on last east of Southbourne. We feel that their delivery will be most appropriately secured outside of the limitations of CIL.
Give detailed consideration of the impact of development on the surrounding landscape, including the South Downs National Park and Chichester Harbour AONB and their settings. Development should be designed to protect long-distance views to the South Downs National Park; We support the desire to protect these areas and their settings. Any submission will be supported by a full landscape and visual impact assessment to demonstrate that the scheme east of Southbourne can be a cohesive visual element into the existing built form of the village and avoid any element of incongruousness or harmful impact on the surrounding protected areas.
Ensure that multifunctional green infrastructure provision is well related to the overall layout and character of the development as well as providing opportunities to extend into the wider countryside and surroundings; The proposed scheme to the east of Southbourne would be capable of delivering a significant portion of the Green Ring, originally allocated in the Southbourne Neighbourhood Plan 2015. The Consortium is also supportive of a central feature through the site and the approach to align the Green Ring with the north-south public right of way which connects with the green infrastructure on the eastern edge of the neighbouring Cooks Lane development. This approach would allow the green ring to be cohesive with the neighbouring green infrastructure, whilst also maintaining the public rights of way, in conformity with paragraph 98 of the NPPF. Whilst this central ‘Inner’ Green Ring could include play, gym trail, walking and cycling, benches and a variety of greenspace (amenity and natural), which would create a varied and engaging corridor, we would work wish to with the Neighbourhood Plan Group to identify the best mechanism to position sports and allotments through a masterplanned approach.
Demonstrate that development would not have an adverse impact on the nature conservation interest of identified sites and habitats including the strategic wildlife corridors; We support the desire to protect key habitats and the scheme will be informed by extensive habitat surveys and mitigation strategies.
Provide mitigation to ensure the avoidance of adverse effects on the SPA, SAC and Ramsar site at Chichester Harbour including contributing to any strategic access management issues, loss of functionally linked supporting habitat and water quality issues relating to runoff into a European designated site; We echo the need to avoid adverse effects on the SPA, SAC and Ramsar site at Chichester Harbour and all necessary mitigation will be provided on- and off-site where required.
Protect any other key views; We support the desire to protect the key views of the wider area. Any submission will be supported by a full landscape and visual impact assessment.
Ensure that allocations and policies accord with the sequential approach to flood risk, and that development will be safe for its lifetime, taking account of climate change impacts, as per the requirements set out in national policy and having due regard to the council's latest Strategic Flood Risk Assessment; We support this requirement and discussions with the Environment Agency and the LLFA will inform the most effective flood mitigation and drainage strategy for the site.
Ensure sufficient capacity within the relevant wastewater infrastructure before the delivery of development as required; Addressed in Paragraphs 2.5-10 above, we have concerns regarding the emerging plan’s wording around the future capacity improvements of WwTW in the Apuldram catchment.
Demonstrate that development would not have an adverse impact on the significance of heritage assets or their settings; Any submission will be supported by a full heritage assessment and the layout and scale will be adjusted accordingly to best protect any nearby heritage assets.
Maintain the character and integrity of existing settlements and provide clear separation between new development and neighbouring settlements including through the definition and protection of landscape gaps. The consortiums approach allows for the masterplan to be designed to best protect the existing settlement of Southbourne from any coalescence with surrounding hamlets. The location of development to the east of the village and the inclusion of the Green Ring is the most appropriate and effective way to protect the village’s visual separation and identity.
Consider the Minerals Safeguarding Area and in line with the West Sussex Joint Minerals Local Plan, a minerals resource assessment may be required to assess if the land contained a mineral resource that would require extraction prior to development. Account should also be taken of the West Sussex Waste Local Plan and associated guidance in relation to safeguarding policy W2. We support this inclusion, and any proposal will be accompanied by a minerals resource assessment if needed.

In general, we support the comprehensive masterplanning approach for development in Southbourne. Our proposals are the result of a complete collaboration between landowners and reiterate that the Consortium has always maintained a desire to deliver a comprehensive development that secures substantial benefits to the existing community. It is obviously important that any landowners included within the proposed allocation are required to work collaboratively with others and the local community, sharing the overall infrastructure and policy requirements fairly and proportionately.

We strongly support an amendment to be made to Policy H2 to allow for the provision of circa (or a minimum of) 1,250 dwellings at Southbourne. The accompanying sustainability appraisal, discussed later, supports a larger quantum of development on this site, with benefits realised of accessibility, environmental quality, climate change mitigation, community enhancement, health, historic environment and landscape. A major element of our proposals at Southbourne are in the infrastructure and community improvements to the local residents and increasing the overall housing numbers by less than 20% on this site is key in the wider delivery of package of the infrastructure improvements associated with the scheme.

There is no intention to deliver piecemeal development proposals within the area, which would likely prejudice the delivery including infrastructure delivery. We maintain the most effective way to ensure the infrastructure improvements associated with the scheme would come forward at an effective and appropriate time would be to remove the need for the proposals to contribute to CIL and instead have a direct commitment between the scheme and the improvements to Southbourne.

Policy H1 should be amended in line with a reassessment of highway constraints

REPRESENTATION SUMMARY

CDC fails on a number of counts to provide a sound reason for constraining development delivery to 535 dwellings per annum. We find that the Council’s failure to adhere to the OAN on the basis of ineffective evidence results in plan that has not been positively prepared and adopts a strategy that is not justified. We believe the plan is capable promoting a greater level of housing delivery which will, in turn, help bring the estimated infrastructure contribution per dwelling to a more deliverable and realistic level.

This representation provides continued support and draft policy context for the development on land east of Southbourne. We consider it to provide a suitable and sustainable location for large-scale strategic residential growth and substantial associated infrastructure improvements.

The area was due for allocation within the Southbourne Neighbourhood Plan, having been initially allocated 1,250 dwellings on ‘land east of Southbourne’, prior to its removal post Examination (based on concerns of the Examiner over a pre-emption of the emerging local plan). Importantly, the Examiner did not conclude that the proposed allocation was unsustainable for growth or inappropriate in size, but simply that the timing of the Neighbourhood Plan was too early against the emerging Local Plan timetable which had unfortunately been delayed.

We continue to recommend that the land east of Southbourne (Policy A13 in the emerging LP) provides the most appropriate location for development at Southbourne. Indeed, the land to the east of the settlement was chosen as the most appropriate location, as opposed to the land to the west which is more constrained by the A27 and would likely result in amalgamation with the settlement of Emsworth.

We consider that the increase in the quantum of development at Southbourne from 1,050 to c1,250 not only ensures the highest level of community enhancements and infrastructure improvements for Southbourne and the wider area but also helps mitigate certain aspects of the emerging plan that risk being found unsound, including the potential for delays in housing delivery across the largest strategic sites and the potential for Chichester District to accommodate unmet need across neighbouring authorities (and within SDNP).

Considering the above, and in terms of specific policy amendments, we recommend the following policies be reworded to ensure the plan’s overall soundness:
Policy H1 – Meeting Housing Needs – The housing requirement (10,350) for the plan period 2021-2039 must reflect Objectively Assessed Need to avoid the risk of failing to be seen as positively prepared. The evidence base on which the justification for a reduction in housing delivery is flawed and not credible. The plan fails the tests of soundness to this regard and Policy H1 should be amended in line with a reassessment of highway constraints.
Policy H2 – Strategic Locations/Allocations 2021-2039 – The quantum of development at Southbourne (A13) should be 1,250 to reflect the conclusions of the sustainability appraisal, the capacity within the land east of Southbourne and the importance in bringing forward all infrastructure improvements to the village and wider area.
Policy A13 – Southbourne Broad Location for Development - In line with the above, the total number of dwellings allocated to Southbourne should be 1,250. Further, it is recommended that a specific location is selected within Southbourne, to align with all other allocations within Chapter 10 and to avoid a significant risk to the delivery of housing. No rationale is presented as to why development in Southbourne should be delayed until the adoption of a subsequent DPD or Neighbourhood Plan. The long-term assessment and findings of the Neighbourhood Plan group and the plan examiner remain sound and should be respected and reflected in a specific and precise housing allocation for the village. We recommend this policy is rewritten to allocate 1,250 dwellings on land east of Southbourne and to align with the comprehensive masterplanning exercise that has been completed to-date.
These representations bring to light a number of recommended reconsiderations with regards to the emerging local plan, these include a reassessment of the quantum of development in Southbourne, the mechanism for infrastructure funding and delivery, the contingency planning around wastewater treatment capacity and the supporting of Vision & Validate as an approach for encouraging safe, efficient and sustainable transport.
For the reasons outlined throughout, these representations also raise significant concerns that the plan as drafted, in particular the housing delivery strategy, risks being found ‘unsound’ on the grounds of failing to be positively prepared and lacking a fully considered highways evidence base. We believe the changes outlined above with regards to reflecting OAN and adding realistic capacity and specificity to the proposed allocation in Southbourne will help address these concerns.

The quantum of development at Southbourne (A13) should be 1,250 to reflect the conclusions of the sustainability appraisal, the capacity within the land east of Southbourne and the importance in bringing forward all infrastructure improvements to the village and wider area.

REPRESENTATION SUMMARY

CDC fails on a number of counts to provide a sound reason for constraining development delivery to 535 dwellings per annum. We find that the Council’s failure to adhere to the OAN on the basis of ineffective evidence results in plan that has not been positively prepared and adopts a strategy that is not justified. We believe the plan is capable promoting a greater level of housing delivery which will, in turn, help bring the estimated infrastructure contribution per dwelling to a more deliverable and realistic level.

This representation provides continued support and draft policy context for the development on land east of Southbourne. We consider it to provide a suitable and sustainable location for large-scale strategic residential growth and substantial associated infrastructure improvements.

The area was due for allocation within the Southbourne Neighbourhood Plan, having been initially allocated 1,250 dwellings on ‘land east of Southbourne’, prior to its removal post Examination (based on concerns of the Examiner over a pre-emption of the emerging local plan). Importantly, the Examiner did not conclude that the proposed allocation was unsustainable for growth or inappropriate in size, but simply that the timing of the Neighbourhood Plan was too early against the emerging Local Plan timetable which had unfortunately been delayed.

We continue to recommend that the land east of Southbourne (Policy A13 in the emerging LP) provides the most appropriate location for development at Southbourne. Indeed, the land to the east of the settlement was chosen as the most appropriate location, as opposed to the land to the west which is more constrained by the A27 and would likely result in amalgamation with the settlement of Emsworth.

We consider that the increase in the quantum of development at Southbourne from 1,050 to c1,250 not only ensures the highest level of community enhancements and infrastructure improvements for Southbourne and the wider area but also helps mitigate certain aspects of the emerging plan that risk being found unsound, including the potential for delays in housing delivery across the largest strategic sites and the potential for Chichester District to accommodate unmet need across neighbouring authorities (and within SDNP).

Considering the above, and in terms of specific policy amendments, we recommend the following policies be reworded to ensure the plan’s overall soundness:
Policy H1 – Meeting Housing Needs – The housing requirement (10,350) for the plan period 2021-2039 must reflect Objectively Assessed Need to avoid the risk of failing to be seen as positively prepared. The evidence base on which the justification for a reduction in housing delivery is flawed and not credible. The plan fails the tests of soundness to this regard and Policy H1 should be amended in line with a reassessment of highway constraints.
Policy H2 – Strategic Locations/Allocations 2021-2039 – The quantum of development at Southbourne (A13) should be 1,250 to reflect the conclusions of the sustainability appraisal, the capacity within the land east of Southbourne and the importance in bringing forward all infrastructure improvements to the village and wider area.
Policy A13 – Southbourne Broad Location for Development - In line with the above, the total number of dwellings allocated to Southbourne should be 1,250. Further, it is recommended that a specific location is selected within Southbourne, to align with all other allocations within Chapter 10 and to avoid a significant risk to the delivery of housing. No rationale is presented as to why development in Southbourne should be delayed until the adoption of a subsequent DPD or Neighbourhood Plan. The long-term assessment and findings of the Neighbourhood Plan group and the plan examiner remain sound and should be respected and reflected in a specific and precise housing allocation for the village. We recommend this policy is rewritten to allocate 1,250 dwellings on land east of Southbourne and to align with the comprehensive masterplanning exercise that has been completed to-date.
These representations bring to light a number of recommended reconsiderations with regards to the emerging local plan, these include a reassessment of the quantum of development in Southbourne, the mechanism for infrastructure funding and delivery, the contingency planning around wastewater treatment capacity and the supporting of Vision & Validate as an approach for encouraging safe, efficient and sustainable transport.
For the reasons outlined throughout, these representations also raise significant concerns that the plan as drafted, in particular the housing delivery strategy, risks being found ‘unsound’ on the grounds of failing to be positively prepared and lacking a fully considered highways evidence base. We believe the changes outlined above with regards to reflecting OAN and adding realistic capacity and specificity to the proposed allocation in Southbourne will help address these concerns.

We recommend this policy is rewritten to allocate 1,250 dwellings on land east of Southbourne and to align with the comprehensive masterplanning exercise that has been completed to-date.

REPRESENTATION SUMMARY

CDC fails on a number of counts to provide a sound reason for constraining development delivery to 535 dwellings per annum. We find that the Council’s failure to adhere to the OAN on the basis of ineffective evidence results in plan that has not been positively prepared and adopts a strategy that is not justified. We believe the plan is capable promoting a greater level of housing delivery which will, in turn, help bring the estimated infrastructure contribution per dwelling to a more deliverable and realistic level.

This representation provides continued support and draft policy context for the development on land east of Southbourne. We consider it to provide a suitable and sustainable location for large-scale strategic residential growth and substantial associated infrastructure improvements.

The area was due for allocation within the Southbourne Neighbourhood Plan, having been initially allocated 1,250 dwellings on ‘land east of Southbourne’, prior to its removal post Examination (based on concerns of the Examiner over a pre-emption of the emerging local plan). Importantly, the Examiner did not conclude that the proposed allocation was unsustainable for growth or inappropriate in size, but simply that the timing of the Neighbourhood Plan was too early against the emerging Local Plan timetable which had unfortunately been delayed.

We continue to recommend that the land east of Southbourne (Policy A13 in the emerging LP) provides the most appropriate location for development at Southbourne. Indeed, the land to the east of the settlement was chosen as the most appropriate location, as opposed to the land to the west which is more constrained by the A27 and would likely result in amalgamation with the settlement of Emsworth.

We consider that the increase in the quantum of development at Southbourne from 1,050 to c1,250 not only ensures the highest level of community enhancements and infrastructure improvements for Southbourne and the wider area but also helps mitigate certain aspects of the emerging plan that risk being found unsound, including the potential for delays in housing delivery across the largest strategic sites and the potential for Chichester District to accommodate unmet need across neighbouring authorities (and within SDNP).

Considering the above, and in terms of specific policy amendments, we recommend the following policies be reworded to ensure the plan’s overall soundness:
Policy H1 – Meeting Housing Needs – The housing requirement (10,350) for the plan period 2021-2039 must reflect Objectively Assessed Need to avoid the risk of failing to be seen as positively prepared. The evidence base on which the justification for a reduction in housing delivery is flawed and not credible. The plan fails the tests of soundness to this regard and Policy H1 should be amended in line with a reassessment of highway constraints.
Policy H2 – Strategic Locations/Allocations 2021-2039 – The quantum of development at Southbourne (A13) should be 1,250 to reflect the conclusions of the sustainability appraisal, the capacity within the land east of Southbourne and the importance in bringing forward all infrastructure improvements to the village and wider area.
Policy A13 – Southbourne Broad Location for Development - In line with the above, the total number of dwellings allocated to Southbourne should be 1,250. Further, it is recommended that a specific location is selected within Southbourne, to align with all other allocations within Chapter 10 and to avoid a significant risk to the delivery of housing. No rationale is presented as to why development in Southbourne should be delayed until the adoption of a subsequent DPD or Neighbourhood Plan. The long-term assessment and findings of the Neighbourhood Plan group and the plan examiner remain sound and should be respected and reflected in a specific and precise housing allocation for the village. We recommend this policy is rewritten to allocate 1,250 dwellings on land east of Southbourne and to align with the comprehensive masterplanning exercise that has been completed to-date.
These representations bring to light a number of recommended reconsiderations with regards to the emerging local plan, these include a reassessment of the quantum of development in Southbourne, the mechanism for infrastructure funding and delivery, the contingency planning around wastewater treatment capacity and the supporting of Vision & Validate as an approach for encouraging safe, efficient and sustainable transport.
For the reasons outlined throughout, these representations also raise significant concerns that the plan as drafted, in particular the housing delivery strategy, risks being found ‘unsound’ on the grounds of failing to be positively prepared and lacking a fully considered highways evidence base. We believe the changes outlined above with regards to reflecting OAN and adding realistic capacity and specificity to the proposed allocation in Southbourne will help address these concerns.

We support the requirement of Policy NE5 to provide a minimum of 10% biodiversity net gain against a pre-development baseline. Further, we agree that the Bird Aware Solent strategy is an effective mechanism for avoiding adverse effects on the Chichester and Langstone Harbours (SAC, SPA and Ramsar).