A27 Chichester Bypass Mitigation Supplementary Planning Document - August 2023

Object

Representation ID: 6407

Received: 01/11/2023

Respondent: Obsidian Strategic AC Limited, DC Heaver and Eurequity IC Ltd

Agent: Quod

With regards to 4.23:

The application of a contribution per bedroom policy is flawed and disproportionate, implying that a 4-bedroom house generates double
the level of vehicular trips as a 2-bedroom house or four times the traffic of a 1-bedroom flat. Whilst the approach seeks to make the contribution proportionate to its impact, it fails to do so.

The suggested approach is not borne out by any provided evidence and fails to recognise that larger housing generally accommodates families, including children who do not drive. This can be demonstrated simplistically using the WSCC Parking Calculator which identifies expected car demand by bedroom size. When applied to the
proposed SPD it demonstrates the disproportionate loading of costs on larger family housing.

In the same manner, the SPD does not recognise the potential benefits that can be achieved by developing in more sustainable locations where traffic impacts can be reduced more readily. Instead, the SPD treats all development in the plan equally, and does not
reflect the reduced impact on the A27 corridor that is achieved by developing sustainable schemes that reduce traffic demands on the A27 corridor. The A8 allocation site is one such example that would be delivered in a sustainable location, well connected to alternative
means of travel, and alongside delivery of an on-site primary school, local centre, and community facilities all of which will materially reduce travel demand and in turn reduce the impact on the A27 corridor.

The contributions would fail to meet the CIL Reg 122 tests – it is not proportional in scale to the impact of development. Any contribution should be based on expected vehicle trips generated by development
instead, taking account of the location and mix of the scheme proposed in an evidenced manner.

Object

Representation ID: 6408

Received: 01/11/2023

Respondent: Obsidian Strategic AC Limited, DC Heaver and Eurequity IC Ltd

Agent: Quod

With regards to para 4.19:

The calculation of planning contributions is focussed on only residential uses within the district which fails to reflect the impact of development in the calculation of the SPD contribution.

This approach is flawed and disproportionately loads the cost of infrastructure improvements on residential developments, without key traffic generators (for example commercial development) required to mitigate for the impact they create, and without requiring cross-boundary development to mitigate its impact in Chichester or reflecting other funding that may be secured in the period of the SPD.

The approach does not account for any funding being sought from:
- Development in neighbouring districts (i.e. Havant BC and Arun DC). It is feasible that both districts will promote development impacting on the A27 corridor in Chichester. The SPD recognises that growth in Chichester district is only one contributor to issues on the A27 which carries significant through traffic and CDC as LPA should seek funding from development that meet the CIL tests
irrespective of their location. By failing to recognise this in the formula of the SPD, the proposed approach is unreasonable and burdens development in Chichester to address an issue it does not create alone.

- Development in the northern part of the District which will still contribute to the need for the A27 improvement as strategic infrastructure. The SPD approach should be amended to include all allocations in the Local Plan.

- Non-residential development, such as commercial / employment, which will generate traffic and impact on the A27 corridor, is not required to fund improvements to mitigate the impact it creates. Whilst employment development can seek to rebalance traffic flows
and commuting patterns, many types of commercial development would result in net traffic impacts on the A27 corridor and should reasonably be required to contribute to its improvement in the same manner as residential development.

Alternative funding sources for example through government grant funding (such as RIS) or through the use of CIL receipts. The draft SPD suggests that CIL will not be used to fund A27 improvements and instead be directed to other infrastructure demands across the
district. This is inappropriate as CIL is intended to deliver the wide range of community infrastructure required in an area. The improvement of the A27 corridor is one of the greatest infrastructure requirements in the district, impacted by development of all types and scales, and CIL funding should contribute to its funding as part of the package of funding sources that need to be considered to
deliver the improvement. This should be rectified in the draft SPD and the CIL Regulation 123 list amended accordingly.

- Additional contributions achieved through speculative and infill development brought forward outside of the Local Plan allocations. The SPD should recognise that this will occur and allow for additional funding to contribute to the A27 contributions pot, thereby reducing the funding burden on the allocations reasonably.

Object

Representation ID: 6409

Received: 01/11/2023

Respondent: Obsidian Strategic AC Limited, DC Heaver and Eurequity IC Ltd

Agent: Quod

With regards to paras 4.9 and 4.10:

The Local Plan Evidence base used to inform the SPD considered assessment of development at 535dpa which forms the draft Local Plan. However, the evidence that is presented also considered a sensitivity test of 700dpa, concluding that the same A27 mitigation package could accommodate this higher level of growth in a similar
manner.

To base the SPD on evidence that has not been properly examined (through EIP) is premature and risks disproportionately loading infrastructure requirements on development that comes ahead of the adoption of the Plan and as such is premature. The A27 contribution
formula is intrinsically linked to the level of growth promoted in the draft Local Plan, and so if this increases, the contribution calculation would need to be amended to reflect this. This approach is contrary to the PPG which states that SPDs should build on advice and guidance
in the Local Plan. Coming ahead of the Local Plan but basing its assessment on the emerging strategy is unsound on this basis.