Southbourne Allocation Development Plan Document: Regulation 18 Consultation Assessment Framework

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These representations have been prepared by Turley in respect of the current consultation on the emerging Southbourne Allocation DPD (SADPD) Regulation 18 consultation. Wates Developments have land interests in the District, including those to the east of Southbourne within the Broad Location for Development (BLD) that Chichester District Council (CDC) propose to deliver under draft Local Plan Policy A13 and which is the subject of the emerging SADPD. The emerging Local Plan has been the subject of recent Examination hearings, the outcome of which are awaited. It is anticipated that a round of consultation on proposed modifications will be required ahead of receipt of the Inspector’s Report. It will be important therefore that the emerging SADPD has due regard to any changes made to the Local Plan through this process, to ensure the two are in conformity. This includes the potential for a commitment to an early review to ensure additional growth can be planned for at an early stage. Our comments on the SADPD are provided without prejudice to the submissions we have made through the Local Plan Examination process. 1.3 Alongside the draft SADPD itself, the Council have also published an Assessment Framework, Interim Sustainability Appraisal Report and Viability Assessment. These representations consider both the SADPD and the supporting documents. Due regard has also been paid to the evidence base of the emerging Local Plan where relevant to the SADPD. 1.4 Our comments have regard to national planning policy and other material considerations. At the time of consultation, the 2023 National Planning Policy Framework (NPPF) remains the current document. It is noted however that consultation on a revised NPPF was held earlier in 2024 and it is understood that a new NPPF will be formally published by the end of the year. Based on the draft transitional arrangements in the consultation version it is therefore likely that the SADPD will fall to be examined under the new NPPF and therefore once published updates may be required to the SADPD to ensure it is consistent with this. 1.5 Our representations are structured as follows: • Section Two – Representations on the SADPD • Section Three – Representations on the Assessment Framework • Section Four - Representations on the Interim Sustainability Appraisal Report • Section Five – Representations on the Viability Assessment • Section Six – Summary and Conclusion. The representations are supported by the following documents: Appendix One – i-Transport Technical Response • Appendix Two – SLR landscape response • Appendix Three – Vision Document. 1.7 We look forward to continuing to engage with the Council and their consultant team in the development of the SADPD and would be keen to arrange a further meeting to discuss our representations following the close of the consultation. 2. Southbourne Allocation DPD Planning Policy Context 2.1 As set out in the introduction, it is important to recognise the evolving context in respect of the emerging Local Plan which is currently the subject of Examination. It will be necessary to ensure the SADPD is in conformity with the Local Plan when adopted including any modifications which may be made to the current submission version of the Plan. 2.2 Indeed, it is noted that the Council has suggested some modifications to the proposed Southbourne Broad Location for Development (BLD) Policy when submitting the Plan. These include suggested modification CM333 which proposes to alter the requirement to provide ‘up to’ 1,050 dwellings to a requirement to provide ‘approximately’ 1,050 dwellings. Whilst it is understood that the consultation SADPD has been based on the Local Plan as submitted, the outcomes of the Examination process will need to be reflected in future consultation versions of the SADPD. It is important that the SADPD does not prejudice the opportunity to explore additional growth at Southbourne, should this be required as an outcome of the current Local Plan Examination. Furthermore an early review of the Local Plan may be required, in light of the discussions at the recent Examination hearings particularly around the need for updated transport modelling work. Importantly, the Development Plan for this area also includes the Southbourne Modified Neighbourhood Plan 2014-2019 (November 2023). The Neighbourhood Plan provides important local context and further guidance on the community’s aspirations for Southbourne and future development within it. 2.4 As well as the made Neighbourhood Plan itself, it is also important to consider the wider evidence base and consultation processes that have gone into the various iterations of the Neighbourhood Plan. In particular, it is notable that the Neighbourhood Plan process has previously assessed what it considered to be the most appropriate location for growth to be accommodated at the settlement. 2.5 The February 2021 submission version of the Neighbourhood Plan included a proposed allocation (draft Policy SB2) for circa 1,050 homes to the east of Southbourne. The proposed allocation of land to the east of Southbourne was supported by a 51% community preference indicated through the NP consultation process: 2.6 Whilst the Neighbourhood Plan did not ultimately allocate the site to the east of Southbourne as had been proposed in the February 2021 submission version, this was a result of the examining Inspector (Christopher Lockhart- Mummery QC) concluding the Neighbourhood Plan should be seeking conformity with the adopted Development Plan as opposed to an emerging early draft of a Local Plan, one that had potential to alter prior to adoption (Appendix One). Whilst therefore the NP removed the proposed allocation, this was purely on a technical basis rather than any suggestion of any issue with the proposed allocation itself. 2.7 The previous Neighbourhood Plan process therefore provides a clear indication of community preference in relation to the location of growth at Southbourne. Whilst the SADPD has understandably, and correctly, revisited all potential locations for growth it is important that this is also set within the context of the previous work undertaken. Supporting Material 2.8 In addition to the four main consultation documents themselves, the Council’s website advises that: “There are also evidence base documents included within the Local Plan Examination Library which are of relevance in underpinning the Southbourne Allocation DPD, which are available to view via the following link: The Local Plan examination - submission documents and evidence base - Chichester District Council. This includes a Southbourne Level Crossing Study within the Transport and Accessibility section.” 2.9 We note there were considerable discussions at the recent Local Plan Examination in respect of the highways evidence base underpinning the Local Plan in particular. The Inspector’s conclusions in respect of this, and any further work or updates required, will need to be reflected in the SADPD. In any event, it is noted that the work undertaken at the Local Plan level will have necessarily been undertaken at a higher level rather than solely focusing on Southbourne and will be somewhat time dated by the adoption of the SADPD. 2.10 The Stantec Report on Southbourne Level Crossing in particular is dated May 2021. Although there was a Paramics Model Update in March 2023, it is clear that the local context has continued to evolve since this time, including in respect of local commitments. 2.11 Similarly, we note there is no Infrastructure Delivery Plan prepared in support of the SADPD and instead it is assumed reliance is placed on the Infrastructure Delivery Plan (April 2024) prepared in support of the Local Plan. It is considered that a Southbourne specific Infrastructure Delivery Plan should be prepared to inform the SADPD. This would then help to inform the Viability Assessment, our comments on which are provided in Section Five. [See attached document for full submission]

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3.2 Chapter 2 of the Assessment Framework sets out the site context in respect of the Broad Location for Development (BLD). Whilst much of the information presented is factual and therefore on which we have no comment, we would highlight the following. 3.3 To aid clarity it is suggested that Figure 2.2 is updated to also reflect consented development which sits outside the settlement boundary and the BLD. Currently it would appear that growth to the east of the settlement would be disconnected which is not an accurate reflection of the context. 3.4 Figure 2.5 represents the different land ownerships within the BLD. Whilst this is understood to be an accurate reflection of ownership this does not necessarily depict wider agreements that are in place between landowners. Specifically, we can confirm that in addition to the orange parcel which forms the majority of the eastern part of the BDL, Wates also control the pale green and southern blue parcel in the eastern BLDAs such, whilst it is recognised that there are additional parcels outside of the control of Wates Developments, the majority of the land to the east of Southbourne is under their control. 3.5 Whilst the proposed green ring will be primarily a recreation route, it is considered that it should also be referenced in the ‘connectivity network’ section given the opportunity it presents and the community support which it has as well as its status in the Neighbourhood Plan. It is considered that the BLD boundary should be shown as a red line on Figure 3.0 Constraints Map for consistency with the other figures. It is noted that a noise buffer 60dB is annotated on the constraints plan. This is based on assessment work undertaken by Wates and supplied to the authority. It is considered this should be shown as an indicative constraint as clearly this will require further testing (including for the land outside of Wates control) as detailed proposals are developed. At this stage it is unclear whether the LPA are intending to undertake such additional work themselves in developing the next version of the SADPD. Whilst the overhead power line is shown on the constraints map, the route of the gas pipeline is not identified. We would suggest this is updated to include.Whilst the proximity considerations shown on Figure 2.2 Built Form and Heritage are consistent with the Landscape Gap Assessment (May 2019), these are then not replicated on Figure 3.0 which instead shows smaller areas for these. It is considered that the proximity considerations from Figure 2.2 must be accurately reflected on Figure 3.0. If alternative evidence has been prepared to support the revised proximity consideration areas shown on Figure 3.0, these must be published as part of the evidence base to support the current consultation. At the current time it is unclear whether the development scenarios have been informed by inaccurate information in Figure 3.0. [See attached document for full submission]

3.10 With regards to the opportunities and constraints identified, we would further highlight the following: • The eleventh bullet identifies both the Inlands Road crossing and the western PRoW crossing as being “unsafe and uncontrolled pedestrian rail crossings.” The Inlands Road (all mode) crossing has barriers which drop when a train is approaching, thereby alerting pedestrians not to cross. It is only the crossing of footpath 241 which is completely uncontrolled. The issue at Inlands Road can be addressed much more easily - with double barriers, which development at Scenario 2 could fund. Similar schemes have been implemented elsewhere in West Sussex and there is no reason why the same could not be done here. The constraint should be reworded accordingly. Further information is provided in the i-Transport response at Appendix Two. • The final bullet and constraints notes ‘multiple landowners in the east’ as a constraint but does not acknowledge the land ownership issues that could arise as a result of the multiple third-party land to the west, for example the parties involved in the delivery of a pedestrian link through the college or of the bridge to the south. This should be acknowledged and given equal weighting in the assessment process. Furthermore, our comments in relation to the land control to the east have been discussed above. • Whilst the opportunities are noted in respect of improving north-south mobility within the village, this should also recognise the opportunity to bring forward a development with multiple points of pedestrian and / or cycle access both to the village and across the railway line which is a significant parameter on which the suitability of each scenario should be assessed. Our comments on the accessibility of Scenarios 1 and 2 have been discussed in Section Two and as such are not repeated here. [See attached document for full submission]

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Infrastructure Requirements 3.11 Whilst we do not wish to repeat our earlier comments, we would recommend that a Southbourne specific Infrastructure Delivery Plan is prepared in support of the next consultation on the SADPD. This would provide greater certainty and reflect the current position in order to inform the viability testing. 3.12 A series of infrastructure requirements are noted in Section Three. We would highlight that these are likely to vary depending on the quantum of development to be accommodated in the BLD, which in itself is dependent on the current Local Plan Examination process. These requirements may therefore vary and will need to continue to be reviewed through the evolution of the SADPD. 3.13 It is noted that whilst the majority of the identified infrastructure requirements are consistent with the Local Plan Infrastructure Delivery Plan (LP IDP), there are some discrepancies and ongoing uncertainties. In particular we note: • The LP IDP only noted the need for provision of improved bus services and bus stops in respect of transport infrastructure. It is clear that the SADPD identifies a number of other requirements. It is important that these are justified and have been factored into the viability assessment of the options. Proposals will need to be worked up in further detail through discussions with West Sussex County Council in particular. • There remains uncertainty on the need for an expansion of Bourne Community College for both secondary and sixth form provision. • It is unclear what the need for the potential replacement of the Age Concern building is, how this is directly related to the development and how the relevant tests will be met. Further information is required on this element. • We have commented through the Local Plan Examination on the proposed requirements in respect of custom and self-build housing, and gypsy and traveller pitches and plots for travelling show people. The SADPD will need to respond to the Local Plan Inspector’s comments on these points. • We would note the role that the green ring provision will have in meeting the wider open space requirements and consider these two requirements may be more appropriately addressed as a single requirement to ensure they are considered holistically. 3.14 With regards to the delivery of these infrastructure requirements, we do not repeat our comments provided in Section Two. We comment separately on how the LP IDP has informed the viability appraisal in Section Five. [See attached document for full submission]

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Assessing the Options 3.15 Chapter 4 sets out how the options have been assessed. We note that initial community engagement is stated to have already taken place. It is assumed that future consultation versions will include a summary of consultation feedback received and how this has fed into the SADPD. 3.16 With regards to establishing the Assessment Framework, it is considered greater clarity is required as to how the comparative tables of shared objectives have been created. We note, by way of example, Figure 1 currently identifies shared objectives between Local Plan objective 1: Climate Change with Neighbourhood Plan objectives 1 and 4, but not with 5 which is “adapted and prepared for climate change and zero carbon living.” As Figure 1 has then fed into Figure 2, this lack of clarity is further compounded. 3.17 Our comments on the DPD objectives have been provided in Section Two and as such are not repeated here. The objectives are however expanded on in the Assessment Framework and we make the following observations: • Whilst it is recognised that the creation of a “Heart for Southbourne” is a local community aspiration and the dispersed nature of facilities has been identified, as discussed in Section Two there are various options for how this could be addressed which do not necessarily require the co-location of uses. The connectivity between the facilities (both new and existing) will be a key consideration. • Our comments on the quantum of housing proposed are addressed elsewhere and as such are not repeated here. The assessment methodology should not only consider the location of the site in relation to existing bus stops. It should also take account of: The assessment methodology should not only consider the location of the site in relation to existing bus stops. It should also take account of: Walking distance to nearest high frequency (as a minimum, hourly) bus services.Quality of walking routes to the bus stops. (iii) Quality of bus stops. Number of vehicular access points into site and likelihood of delivering a new or extended bus service (for example by designing a suitable road network). [See attached document for full submission]

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Assessing the Options 3.15 Chapter 4 sets out how the options have been assessed. We note that initial community engagement is stated to have already taken place. It is assumed that future consultation versions will include a summary of consultation feedback received and how this has fed into the SADPD. 3.16 With regards to establishing the Assessment Framework, it is considered greater clarity is required as to how the comparative tables of shared objectives have been created. We note, by way of example, Figure 1 currently identifies shared objectives between Local Plan objective 1: Climate Change with Neighbourhood Plan objectives 1 and 4, but not with 5 which is “adapted and prepared for climate change and zero carbon living.” As Figure 1 has then fed into Figure 2, this lack of clarity is further compounded. 3.17 Our comments on the DPD objectives have been provided in Section Two and as such are not repeated here. The objectives are however expanded on in the Assessment Framework and we make the following observations: • Whilst it is recognised that the creation of a “Heart for Southbourne” is a local community aspiration and the dispersed nature of facilities has been identified, as discussed in Section Two there are various options for how this could be addressed which do not necessarily require the co-location of uses. The connectivity between the facilities (both new and existing) will be a key consideration. • Our comments on the quantum of housing proposed are addressed elsewhere and as such are not repeated here. The assessment methodology should not only consider the location of the site in relation to existing bus stops. It should also take account of: The assessment methodology should not only consider the location of the site in relation to existing bus stops. It should also take account of: Walking distance to nearest high frequency (as a minimum, hourly) bus services.Quality of walking routes to the bus stops. (iii) Quality of bus stops. Number of vehicular access points into site and likelihood of delivering a new or extended bus service (for example by designing a suitable road network). Assessment Framework 3.18 In light of the above, it is considered the conclusions of the site assessment framework require updating. Whilst this does not relate to all assessment criteria, where changes are recommended, the relevant row of the Assessment Framework table is provided below including the suggested updated text and scoring for the affected Scenario(s). This has been informed by the work of i-Transport at Appendix Two and SLR at Appendix Three. The Vision Document at Appendix Four demonstrates how Scenario 2 could be delivered. [See attached document for full submission]

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