Southbourne Allocation Development Plan Document: Regulation 18 Consultation Assessment Framework

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It is appropriate to identify the opportunities and constraints as they affect the broad location for development for the three growth scenario options. The assessment framework should also identify the impact and significance of each constraint on each scenario and the degree to which they potentially impact delivering of the allocation. Responses to opportunities and constraints are set out below: Constraints Power Lines - It is appropriate to identify the power lines as a potential constraint and appropriate buffer distances will need to be applied. The impact of the pylons will be confirmed at the Reg 19 Stage of the DPD when a preferred growth scenario is confirmed. Depending on the preferred option and location of development mitigation options will need to be considered including buffer zones or realignment. Gas Pipeline - The pipeline consultation area needs to be shown on the constraints map. Appropriate consultation will need to be undertaken by the Council with statutory consultees regarding the impact of the pipeline consultation area on site access and developable area. Heritage Assets - A heritage statement has been prepared in relation to the Land at Cooks Lane to assess the impact on the setting of Thatchways and Loveders Farmhouse which can be shared with the Council. The statement concludes that the impact of development on Land at Cooks Lane on these heritage assets results in less than substantial harm in accordance with the NPPF and can be mitigated through appropriate masterplanning. Loss of Agricultural Land - This is identified as a constraint for all 3 growth scenarios and is therefore not a deciding factor in determining a preferred option. The Chichester Submission Local Plan SA report states that there is no reasonable alternative strategy to deliver 535dpa including the designation of the BLD at Southbourne through Policy AL13 involving the loss of agricultural land. The DPD should identify that this not an overriding constraint that will affect bringing forward the DPD and determining a preferred growth scenario. Landscape - The impact on views to Chichester Harbour National Landscape and the South Downs National Park is a key consideration. A Landscape and Visual Impact Assessment is being prepared for Land at Cooks Lane which can be shared with the Council. Strategic Wildlife Corridors - These are proposed adjacent to the BLD so not a constraint on the delivery of the allocation for the three scenario options identified at this Regulation 18 stage. Brent Geese Support Area - This is a key constraint to identify in relation to Scenario 1 'Land to the West' which may impact on its deliverability. TPOs & Ancient Woodland - These are key planning considerations but appropriate buffers to Ancient Woodland on the edge of the BLD are easily achieved and the extent of TPOS within developable areas is not a significant constraint to the delivery of the allocation. It is important to set this context in terms of the impact of this constraint on the growth scenarios. Flood Risk - The areas within flood zones 2 and 3 on the eastern boundary to the BLD effect a relatively small area of land and through a sequential approach would not affect the delivery of the c800 within this scenario. There are some limited areas of surface water flooding to the north of the railway on the east and west of Southbourne which need to be considered but do not affect delivery of the allocation overall. Landscape Gap / Coalescence - This is a constraint but primarily affects Scenario 1 'Land to the West' as Scenarios 2 and 3 do not compromise the integrity of the local gap or result in coalescence. This context needs to be set out in the appraisal of the scenarios. Dispersed Location of Amenities - We do not consider this to be a constraint but a consideration for the allocation master planning and provision / location of new amenities and facilities. 'Unsafe and Uncontrolled' Rail Crossings and Western PROW - This is a matter to address with statutory consultees / providers including Network Rail and the highways authority. Limited crossing points and highway capacity restrictions to existing level crossing at Stein Road - The Council will need to undertake consultation with Network Rail and statutory providers / consultees alongside undertaking appropriate transport modelling to determine impact and appropriate mitigation measures. Noise and Air Quality - Air quality is a consideration, but the BLD is not within an air quality management area so unlikely to be a significant constraint. Appropriate noise buffers need to be applied to development near the railway line in accordance with national guidance and noise and vibration assessments. A noise and vibration assessment has been undertaken for Land at Cooks Lane identifying appropriate buffers which can be shared with the Council. Walking and Cycling Connections - Consider that this is more of an opportunity for enhancement of existing connections including delivery of the Green Ring. Landownerships - All of the scenarios include multiple land ownerships. There is an opportunity to establish a co-ordinated approach in accordance with an overall masterplan and plan for infrastructure delivery secured through the IDP, proportionate financial contributions and CIL. Opportunities Improved Highways Infrastructure - We agree there is an opportunity to deliver improved highways infrastructure and connectivity through a comprehensive master planned approach with proportionate financial contributions. Pedestrian and Cycle Footbridge - The Land at Cooks Lane provides a key opportunity to deliver a new pedestrian and cycle footbridge to achieve the Southbourne Neighbourhood Plan policy objective. Green Ring - There is an opportunity to deliver the Green Ring and ecological enhancements through all 3 scenarios. Scenario 3 provides the opportunity to deliver the entire Green Ring. Landscape and Ecology Designations - There is an opportunity to provide access to nature but consideration should also be given to impact on sensitive habitats including Ancient Woodland. Provision of new amenities / facilities - There is a significant opportunity for enhancement of existing amenities and facilities through proportionate financial contributions and CIL. [See attached document for full submission]

Constraints Ecology - The SA Report identifies the impact of Scenario 1 'Land to the West' on the Ems Water Body, which should be identified as a constraint. Highways, Access and Rail Crossings - Impact on highways is a key consideration but there is a differing level of impact between the scenarios in relation to access options and safety / capacity considerations with railway crossings which needs to be reflected in the appraisal of the growth scenarios. Opportunities Housing Delivery - Further consideration should be given to the ability to deliver c800 dwellings or above in all three scenarios. Scenarios should consider the ability to deliver more than 800 dwellings to provide sufficient flexibility and certainty that the Local Plan housing requirement will be met. This will take account of potential factors that may affect delivery to ensure that at least 800 dwellings are delivered. Balanced Development & Future Growth - Consideration should be given to the distribution of development and how this enables future growth of Southbourne proportionate to the settlement and its position in the Local Plan settlement hierarchy. Scenario 3 'Mixed' provides the best opportunity for future sustainable growth beyond the level of growth currently identified in the Submission Local Plan Policy A13. Accessibility to Amenities / Facilities - In addition to the provision of new facilities there is the opportunity to enhance accessibility by sustainable modes of transport. Renewable Energy - Further exploration should be undertaken regarding potential opportunities to deliver renewable energy infrastructure to serve the allocation and wider village of Southbourne. [See attached document for full submission]

It is understood that infrastructure requirements have been identified through the Submission Local Plan, Policy A13 and the Infrastructure Delivery Plan 2021 - 2039 (IDP) and Infrastructure Business Plan 2024 - 2029 (IBP). A response to the infrastructure requirements and delivery mechanism is set out below. Transport A27 Mitigation Contributions - It is appropriate that mitigation for the A27 is identified, and contributions should be proportionate to the impact of sites within the wider allocation and in accordance with the adopted SPD. Multi Modal Crossings - The potential requirement for new road level crossings will need to be determined through engagement with statutory providers and transport modelling undertaken by the Council. It is currently not clear what the impact of the allocation is without new multi-modal crossings. Any potential financial contributions must be proportionate and in accordance with the CIL tests. The alternative option of road level crossing improvements should also be assessed through the DPD involving engagement with statutory providers / consultees. Bus Service Improvements - The provision of bus service improvements is a commercial decision by the bus operators and cannot be delivered by developers. Engagement with bus operators should be undertaken by the Council through preparation of the DPD to determine the potential for bus service improvements / bus routes. Pedestrian Rail Crossings - A pedestrian rail crossing is deliverable on safeguarded land located to the east of Southbourne (within scenarios 2 and 3) on Land at Cooks Lane. Elivia Homes has undertaken engagement with Network Rail regarding delivery of the railway footbridge. As a result of these discussions, a railway footbridge is considered deliverable on land at Cooks Lane within the next 4 years. Furthermore, the costs of delivering the footbridge have been broadly agreed with Network Rail which will refine the costs provisionally identified in the emerging Southbourne Allocation DPD. Education - Education infrastructure requirements have been identified through the Local Plan IDP in relation to wider population growth and the impact of growth associated through the Local Plan including the Southbourne Local Plan allocation Policy A13. The delivery of education infrastructure through the Southbourne DPD could identify proportionate financial contributions related to the impact of individual sites / land parcels within the wider allocation in accordance with the CIL tests. Health - Health infrastructure requirements have been identified through the Local Plan IDP in relation to wider population growth and the impact of growth associated through the Local Plan including the Southbourne Local Plan allocation Policy A13. The delivery of health infrastructure through the Southbourne DPD will need to identify proportionate financial contributions related to the impact of individual sites / land parcels within the wider allocation in accordance with the CIL tests. Sports Facilities - More details required on sports facilities requirements and playing pitch provision. Social / Community - The identified requirements for a new community hall and library expansion will relate to the needs of Southbourne as a whole. The IDP will need to determine the impact of the allocation and to determine proportionate contributions related to the impact of individual sites / land parcels within the wider allocation in accordance with the CIL tests. Thornham WWTW Capacity - Further clarity needed in the IDP regarding delivering sufficient capacity over the plan period to accommodate the allocation. Natural Environment - In relation to nutrient neutrality a strategic approach should be identified through the Southbourne DPD whereby a mitigation strategy is identified which specifies a suitable scheme capable of delivering appropriate mitigation as part of a co- ordinated approach. Green Infrastructure - In consultation with Southbourne Parish Council and in accordance with the Southbourne Neighbourhood Plan further work needs to be undertaken to clarify the detailed form of the Green Ring SO this can be incorporated into master planning work. Gypsy and Traveller Pitches - Submission Local Plan Policy A13 Southbourne Broad Location for Development' identifies that the Southbourne BLD will provide 12 gypsy and traveller pitches in accordance with Policy H11 and a serviced site(s) to deliver 12 plots for travelling showpeople. The Southbourne DPD needs to establish a preferred location(s) for the provision of gypsy and traveller pitches and travelling showpeople plots that meets the needs of these groups in accordance with the local plan criteria policy and as part of a co-ordinated engagement exercise involving landowners within the BLD. Infrastructure Delivery Informed by ongoing refinement of the IDP, the Southbourne Allocation DPD needs to establish a planning obligations framework which enables proportionate contributions to be made from individual sites / land parcels within the wider allocation. The role of CIL to contribute to infrastructure priorities in the BLD also needs to be clarified which also reflects how the Southbourne Parish CIL proportion is spent. The role of statutory providers in delivering key infrastructure also needs to be identified including the role of Network Rail, Southern Water and the Highways Authority / National Highways. In terms of the impact of overall growth in the area statutory providers will need to be planning for the delivery of key infrastructure related to the impact of cumulative growth in the wider area. [See attached document for full submission]

An assessment framework has been prepared to appraise the 3 growth scenario options currently proposed at this Regulation 18 stage and comments are provided in relation to the proposed methodology below. A Sustainability Appraisal has been undertaken for the proposed growth scenarios in accordance with the SA Framework established for the Submission Local Plan. The Southbourne DPD assessment methodology should be amended to clearly state that the assessment framework also includes the SA. A response in relation to the proposed detailed DPD assessment criteria is set out below: 1. Integrated, Well-Serviced Community It is appropriate for this criteria to identify the opportunity within the BLD to deliver new educational and community infrastructure including a community hub in accordance with the Local Plan IDP. It is important to identify opportunities to deliver potential multi modal / pedestrian rail crossings. Land South of Cooks Lane provides the key opportunity to deliver a pedestrian footbridge to connect to the school, railway station, wider village. It is appropriate to identify criteria related to achieving improved connectivity within the village for walking, cycling and vehicles. Access to nature and open space including provision of the Green Ring is a key criteria. Land at Cooks Lane is able to deliver a key element of the eastern Green Ring including connectivity through provision of a pedestrian railway bridge. 2. Housing for All To ensure that the Local Plan housing requirement is met the assessment criteria should assess the ability for growth scenarios to deliver in excess of c800 dwellings. This will provide sufficient flexibility to ensure at least 800 dwellings are delivered during the plan period taking account of any potential factors that may affect delivery within the allocation area. The assessment should also consider the best distribution of development that supports longer term growth. For example, Scenario 3 'Mixed' approach provides a balanced approach to development that does not compromise the ability to sustainably accommodate further growth in the future above that identified in the Submission Local Plan. The Southbourne DPD needs to establish a preferred location(s) for the provision of gypsy and traveller pitches and travelling showpeople plots that meets the needs of these groups in accordance with the local plan criteria policy and as part of a co-ordinated engagement exercise involving landowners within the BLD. In terms of housing mix, all scenarios are capable of delivering a policy compliant mix and therefore this criteria does not assist in informing the identification of a preferred strategic option at this stage. The allocation policy will have reference to housing mix but this does not need to be included in the assessment criteria. In relation to transport impact and ability to accommodate c800 homes, a full transport assessment will need to be undertaken by the Council in the preparation of the DPD. 3. Transport and Sustainable Travel The assessment criteria and objectives are similar to '1 Integrated, Well Serviced Community' and the framework could be updated to avoid duplication between the criteria. We support the identification of opportunities for active travel routes. The opportunity to provide land to deliver pedestrian and cycle bridges across the railway in safe and convenient locations is a key criteria. Scenario 2 and 3 both include Land at Cooks Lane which provides land to enable the delivery of the railway footbridge as part of the Green Ring and enabling connectivity to the school and railway station. The assessment criteria includes the ability to deliver multi modal rail crossings but the requirement for such crossings needs to be clarified through the Council's transport evidence and in consultation with statutory providers. The weight attached to this criteria is dependent on the need for the multi modal crossings in relation to the transport evidence. Proximity to bus stops and frequent bus services is an important consideration of achieving sustainable development. However, the main issue will be for the Council to engage with the bus operators regarding bus routes and any potential for improvement in services. Proximity and connectivity to the railway station and local facilities is a key criteria and scenarios 2 and 3 perform well in against this criteria. 4. Climate Change, Towards Net Zero Carbon Living The ability of each scenario to achieve the Future Homes Standard does not need to be within the assessment criteria to determine a preferred option at this stage. All scenarios are capable of being policy compliant and any further detail that expands upon the Submission Local Plan policy can be included in the Southbourne Allocation DPD policy at Regulation 19. The criteria related to promoting short journeys, collocating uses and providing an appropriate mix of uses will be a key allocation policy requirement but is not needed at this stage to determine a preferred scenario option as all scenarios are capable of delivering the land use requirements. 5. Environment It is appropriate to include a criteria that relates to the delivery of the Green Ring but further detail is required in relation to the form that the Green Ring will take to deliver the objectives of the Southbourne Neighbourhood Plan (in addition to the 20m corridor criteria). The criteria includes reference to preserving and enhancing the wildlife corridors identified in the Neighbourhood Plan. The wildlife corridors are an important consideration but the criteria is not needed as the location of built development in all scenarios is located outside the wildlife corridors where there is no significant impact. Significant weight should be given to the opportunity to retain existing habitats, such as the Brent Geese Support area which is significantly affected by Scenario 1 Land to the West. The assessment of flood risk impact needs to consider the ability to deliver c800 homes in flood zone 1 and within areas of low risk for surface water flooding. In scenarios 2 and 3 areas within future flood zones 2 and 3 are not required for residential development. The DPD will need to consider appropriate drainage strategies for the delivery of infrastructure in areas affected by surface water flooding. The criteria related to the loss of BMV agricultural land should be removed as all 3 scenarios involve loss of BMV land and this criteria does not assist in differentiating the appraisal performance of each scenario. Furthermore, the Submission Local Plan has identified the priority to meet local housing need through the Southbourne Allocation and the loss of agricultural land has been accepted. 6. Character Landscape impact and views of the Chichester Harbour National Landscape and South Downs National Park as are key consideration. The draft DPD needs to clarify the approach to co- ordinating an allocation master plan and landscape strategy confirming technical work to be undertaken by the Council in the preparation of this DPD. Landscape Gap is a key criteria for appraisal of the scenarios and is recognised that Scenario 2 'Land to the East' and Scenario 3 Mixed' perform best in this respect. The criteria identifies the importance of development respecting Southbourne's settlement form, by maintaining the traditional village structure, ensuring that new development complement the scale and style of the existing properties. This is an important consideration for the allocation policy and determining the preferred high level scenario option. [See attached document for full submission]

Reduce the barrier effect of rail tracks Scenarios 1 and 2 include the provision of a multi modal bridge but transport evidence has not yet been prepared to confirm whether it is required to the west or east. We consider that Scenario 3 should score 'strongly' by providing pedestrian / cycle rail crossings rather than making a 'reasonable / neutral contribution'. Support delivery of improved connectivity within the village as a whole with good integration between new and existing community Scoring needs to be adjusted to take account of scenario 2 delivering a multi modal rail crossing and pedestrian footbridges which will improve connectivity. We consider scenario 2 scores higher in this respect. Utilities pipeline impact onsite capacity From the appraisal it is considered that Scenario 1 'Land to the West' performs least well in terms of pushing development to the west into the landscape gap affecting the ability to sustainably deliver c800 dwellings and this should be reflected in the scoring i.e. makes a negative contribution. Scenario 2 performs better and should make a 'reasonable 'contribution and Scenario 3 also a 'reasonable' contribution. Site capacity to meet 800 homes delivery requirement It is considered that scenario 1 'Land to the west' performs least well and may not have capacity to sustainably deliver c800 homes. This is primarily in relation to impact on landscape gap, site access, connectivity, and ecological impacts. The rating for scenario 1 should be amended to 'poor'. Scenario 2 Land to the East is currently assessed as 'poor' in relation to potential access constraints at South Lane and pressure on Inlands Road but this is uncertain and has not been demonstrated through the Council's transport evidence. This option also includes the provision of a multi modal bridge and pedestrian railway bridge so appraisal scoring should be changed to 'reasonable'. Consider that scenario 3 performs best in terms of the ability to accommodate c800 dwellings and this should be reflected in the scoring which should be a 'strong' contribution This balanced distribution also provides better opportunity for further sustainable growth in the future over and above the Local Plan allocation. Potential to deliver mix of housing types and tenures, including G&T provision We consider this criteria is not required as all options are capable of providing an appropriate mix including G&T provision. This is a policy requirement from Local Plan Policy A13, which can be reflected in the Southbourne allocation policy. Potential to meet local housing need We consider this criteria is not required as all options are capable of providing an appropriate mix, including G&T provision. This is a policy requirement from the Submission Local Plan which can be reflected in the allocation policy and master planning. Potential for a bridge crossing the railway for vehicles Scenario 2 land to the east should score 'strongly' as it includes the provision for a multi modal bridge. There are considerations for landowner collaboration, but this does not mean that this scenario scores 'poorly'. Scenario 3 does not include a multi modal bridge but the significance of this will depend on the outputs of the Councils transport evidence as the DPD progresses. Influence of vehicular bridge on traffic congestion Scenario 3 does not provide a new vehicular bridge but the impact of this is currently uncertain without transport evidence prepared by the Council. Potential to create buildings to high environmental performance and meet Future Homes Standard This criteria is not required to differentiate performance of scenario options as all options capable of meeting this policy requirement of the Submission Local Plan, which can be reflected in the Southbourne Allocation DPD policy. Preserve wildlife corridors This criteria not required to differentiate performance of scenarios as all options located outside of wildlife corridors with no impact. Protect and / or mitigate existing wildlife and biodiversity We consider that scenario 3 performs 'reasonably' rather than 'poorly' with limited impact on the Brent Geese Support Area which can be mitigated. Impacts to agricultural land The criteria related to the loss of BMV agricultural land should be removed as all 3 scenarios involve loss of BMV land and this criteria does not assist in differentiating the appraisal performance of each scenario. The Submission Local Plan has identified the priority to meet local housing need through the Southbourne Allocation BLD and the loss of agricultural land has been accepted. Development location within Flood Zones Scenario 2 'Land to the East 'should score 'reasonably' rather than 'poor' as the majority of the site is within flood zone 1 and the location for development is identified outside of the flood zone. Also, as part of a sequential approach it should be possible to locate development in areas of low risk of surface water flooding. Also, there is potential for a drainage strategy solution for delivery critical infrastructure (multi modal rail bridge). Delivery of the railway footbridge on Land South of Cooks Lane is not constrained by surface water flooding. Retention of landscape gaps between villages/settlements Scenarios 2 and 3 should score 'reasonably' rather than 'poorly' as they do not affect the integrity of the landscape gaps or result in coalescence. Scenario 1 has the greatest impact on the hermitage landscape gap and should score 'very poorly'. Sympathetically to existing heritage features Scenarios 2 and 3 should have a 'reasonable' impact and not 'poor' as the existence of heritage assets within the broader allocation does not mean there will be harm to these heritage assets. Effective master planning provides the opportunity for new development to consider the setting of these heritage assets. Deliverability Assessment Deliverability (land) Considerations Scenarios 2 and 3 include multiple landowners however, the Southbourne DPD can establish an appropriate framework to ensure a co-ordinated approach to masterplanning and the delivery of key infrastructure. An overall master plan framework can be prepared which enables separate land parcels to come forward without compromising the overall objectives of the DPD. An approach can be established which enables proportionate financial contributions to ensure the delivery of key infrastructure. Therefore, consider that scenarios 2 and 3 should score 'reasonably' for this criteria. The appraisal for scenario 1 does not reflect that there is a significant parcel of land in a key position which is owned by a different landowner. Deliverability (viability) Considerations The conclusions on viability at this stage have been drawn from high level assumptions contained in the Southbourne Allocation Development Plan Document Viability Assessment Stage 1 (2024), prepared on behalf of the Council by Dixon Searle. The viability performance of Scenario 2 'Land to the East' is identified as poor, primarily in relation to the potential cost of a multi modal railway crossing. The viability report identifies that estimates regarding the cost of this crossing vary significantly and the actual cost will need to be confirmed through further work. Therefore, at this stage viability implications for scenario 2 should be identified as 'reasonable'. Furthermore, subject to transport evidence and engagement with statutory providers there is potential for this scenario to be delivered without a multi modal rail crossing which will significantly impact the viability assessment. The Dixon Searle viability report also identifies significant improvements to viability with the delivery of c1,050 dwellings as opposed to c800 dwellings. Subject to other considerations and constraints consideration should be given to delivering over 800 dwellings in relation to viability and ensuring that policy requirements can be met, and key infrastructure required to support the allocation can be delivered. Overall, we support the preparation of the Southbourne Allocation DPD and the broad approach to identifying a preferred growth scenario to progress to the Regulation 19 stage. We welcome the opportunity to continue to work closely with the Council and other landowners in the preparation of the DPD as it progresses to Regulation 19 stage including involvement in preparation of the evidence base. [See attached document for full submission]