A27 Chichester Bypass Mitigation Supplementary Planning Document - August 2023

Object

Representation ID: 6403

Received: 01/11/2023

Respondent: Rydon Homes Ltd

Agent: DMH Stallard

The Draft SPD evidence base does not relate to the measures being proposed but to the overall improvements being sought for the A27 Chichester Bypass. The omission of transport modelling for the proposed limited A27 mitigation scenario undermines the Draft
SPD.

The evidence in the Local Plan Review Transport Assessment clearly demonstrates that wider traffic growth on the A27 Chichester Bypass is causing the effect of the loss of junction capacity. Therefore, the primary cause of the capacity constraint is strategic traffic and the responsibility of National Highways to address, rather than Chichester District Council.

We recognise there is no certainty that the A27 Chichester Bypass improvements will secure funding as part of RIS3 and the scheme could slip back to subsequent RIS
programmes. However, the proposed Chichester Local Plan period runs until 2039 and therefore in our view, it would seem reasonably likely that the National Highways
improvements to the A27 Chichester Bypass will be secured within the emerging plan period.

The Draft SPD should be supported by transport modelling work that reflects the mitigation proposals at the A27 Fishbourne and Bognor junctions in isolation. The other A27 junctions would need to be left as capacity constraints with no improvement.

The draft SPD should only be seeking contributions for developments in Chichester that impact on the A27 Chichester bypass. National Highways as the strategic highway authority should address the wider strategic impacts on the A27 corridor.

Object

Representation ID: 6404

Received: 01/11/2023

Respondent: Rydon Homes Ltd

Agent: DMH Stallard

It is noted that CDC indicates it acknowledges and has considered carefully the advice within Planning Practice Guidance that it is not appropriate for plan-makers to set out new formulaic approaches to Planning Obligations in supplementary planning documents or supporting evidence base documents as these would not be subject to examination. Notwithstanding this advice, the Council has nevertheless pushed ahead with the new means of seeking contributions as set out in the draft SPD.

The justification given for setting aside the guidance within Planning Policy Guidance is not considered to be sufficiently robust and reasoned to go against the national guidance on these matters.

The amended SPD should be delayed until the Local Plan Examination has taken place so that the evidence base can be tested through examination.

Object

Representation ID: 6405

Received: 01/11/2023

Respondent: Rydon Homes Ltd

Agent: DMH Stallard

The proposal to establish a fixed contribution for all residential development in the area to the south of the National Park boundary, irrespective of the impact of the development on the A27 is effectively a tax on development and wholly unacceptable.

The basis for seeking contributions must be amended to reflect the structure of cost and impact of development akin to the existing Planning Obligations and Affordable Housing SPD produced in 2016 whereby the contribution sought should be based on the proportionate traffic generation and impact on the A27 Chichester bypass for each development site. This would then be used to determine an equitable development contribution.

Object

Representation ID: 6406

Received: 01/11/2023

Respondent: Rydon Homes Ltd

Agent: DMH Stallard

The proposed amendments to the A27 mitigation strategy will result in a wholly disproportionate A27 contribution based on the scale and impact of the development. The
use of a fixed contribution based on the number of bedrooms in a new dwelling is not proportionate and does not consider the actual impact of development on the A27
corridor.

As is set out in the accompanying RPS Transport Note (paragraphs 1.31 to 1.36), the proposed development at Halnaker will not materially impact on the A27 Chichester
Bypass.

To seek a standard charge for mitigation is in clear breach of the CIL test for sourcing Section 106 financial contributions as set out in Regulation 122 of the Community Infrastructure Levy 2010 (as amended) as they would not be necessary to make the development acceptable in planning terms, be directly related to the development or be fairly or reasonably related in scale and kind to the development.

Contributions towards the A27 Mitigation Scheme should instead be based on the proportionate traffic generation and impact on the A27 Chichester bypass for each
development site. This should then be used to determine an equitable development contribution.