Draft A27 Chichester Bypass Mitigation Supplementary Planning Document (SPD) Version 2 - May 2024

[RECEIVED LATE]

I write to confirm a continued interest in the A27 SPD process.

Whilst we appreciate the additional opportunity for input, our original concerns remain unresolved. I therefore attach our original representations from November 2023 (attached), which still stand. We do not have new comment on the May 2024 document, but would instead underline the following:

(1) Inappropriateness of an SPD. The original consultation document in 2023 acknowledged (in direct terms) that the approach being taken by CDC was not appropriate or consistent with national Planning Practice Guidance (PPG). The reason for this is that (as PPG states) ‘these would not be subject to examination’. This fundamental issue is still outstanding.

(2) Position of the Local Plan. Reference is made to the SPD providing an interim approach ahead of the Local Plan, which it says ‘will set out a clear policy basis for seeking A27 mitigation contributions in the future’. By implication, the current SPD is far from clear, for reasons outlined in our attached document. Since the last SPD consultation, the Local Plan has formally been submitted for Examination. Accompanying it is a large library of technical evidence documents and position statements which is consistently being added to, including statements of common ground (such as with National Highways which is still outstanding). Many of these hold direct relevance to A27 mitigation and hence we suggest the focus should be on the Local Plan itself which will provide the opportunity for thorough formal examination, rather than introducing an interim SPD which contains various demonstrable weaknesses.

(3) Appropriateness of projects. As stated in our original representations, the proposed upgrades to the A27 are (in physical terms) at odds with the thrust of sustainable transport policy promoted by National Highways, WSCC Highways, and Chichester District Council. At the very least, their merits should be examined independently and alternatives considered before forming the basis of a mitigation strategy.

(4) Calculation of payment under the SPD. There remain numerous problems with the SPD as drafted, which attempts to ‘lock in’ various parameters without Examination. These include:
- the total cost (which will change)
- the amount of contributions collected already (which will increase over time)
- the amount of funding still required (due to the above 2 factors)
- the presupposition that only development around Chichester should contribute – despite being a road of national significance
- limiting contributions to housing (when other uses also generate use of the A27)

Further, as noted in Paragraph 4.2 of the consultation document itself, the overall level of residential development that will be affected by this SPD also cannot be known with certainty. Overall for the reasons set out in our November 2023 response (attached) we believe it would be appropriate to pause this SPD process. We therefore propose the following:

1. Fully review and redesign the proposed A27 works to ensure a sustainable multi-modal approach in line with policies at national, county and local level.

2. Establish a clearer policy footing for the projects under the draft Local Plan (Policy T1)

3. Fully review the mechanism for delivering the projects in line with the Local Plan, and would be subject to due Examination. This review should consider the option of employing CIL towards road improvements, as alluded to in policy T1 of the draft Local Plan.
I look forward to receiving updates on this process in due course.