Southbourne Allocation Development Plan Document: Regulation 18 Consultation Main Document

No

We broadly agree but feel that the preservation and enhancement of the Strategic Wildlife Corridors should be included as being of key importance under 'Environment'. We also feel that the 'setting' of the Chichester Harbour National Landscape and South Downs National Park is key and therefore this word should be added after 'character' under the 'Character' objective.

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No

We do not agree with the following statement under 'Challenges':- 'Landscape buffer required to protect landscape corridor to the west of the scenario' Scenario 1 would fall almost entirely with the landscape gap identified in the Council’s 2019 study which is designed to avoid urban sprawl and maintain the separation of settlements. The site would come very close to the National Landscape boundary, being only just behind a recent small housing development site (‘Parham Place’) and the Tuppeny Barn site, where the Conservancy has recently objected to a planning application for 7 dwellings on the grounds of harm to the setting of the National Landscape and of what remains of the rural landscape gap, as well as harm to the ecological connectivity between the Harbour and the South Downs. We do not believe that a landscape 'buffer' would be sufficient to mitigate for the impact to the landscape gap that this scenario would cause, this landscape gap being identified in the Council's own study in 2019, which states that it is important that this area is retained as open countryside, and that this gap is 'essential in preventing the coalescence of the settlements and maintaining their separate identities'. Scenario 1 (land to the west) would involve building on a large proportion of this identified gap, which extends southwards into the Chichester Harbour National Landscape, which would directly conflict with the observations and statements set out in the Landscape Gap Assessment, as well as adopted Local Plan Policy 20 and emerging Local Plan Policy NE3 criterion a) and b). There are clear views northwards from the open countryside within Chichester Harbour National Landscape to the south of the A259, from where there are 2 public footpaths across the fields which allow views northwards across this landscape gap (see attached photo). Any development within the gap, unless, to the south of the railway line it is limited to land directly north of Parham Place only, would be clearly visible from the National Landscape and would intrude into the open, green gap and harm the rural setting of the National Landscape as well as causing the perceived and actual coalescence of Southbourne and Hermitage/Emsworth. Scenario 1 would conflict with NPPF paragraph 182, which states that development within the setting of AONBs (now National Landscapes) should be 'sensitively located and designed to avoid or minimise adverse impacts on the designated areas'. Scenario 1 would not be sensitively located in relation to the National Landscape. A further issue with scenario 1 is that it includes fields which have been identified as a Brent Goose Secondary Support Area, and development of these fields would result in the loss of this habitat, as acknowledged by its ‘very poor’ scoring under the objective of ‘Protect and / or mitigate existing wildlife and biodiversity’. Any development within the few remaining rural landscape gaps along the A259 corridor would further sever and erode the ecological connectivity between Chichester Harbour and the South Downs.

The location of this scenario within the landscape gap as well as its proximity to Chichester Harbour National Landscape, and the consequent negative landscape impacts and impacts on the setting of Chichester Harbour National Landscape, should be more fully acknowledged under 'challenges'.

We believe that a further 800 houses in Southbourne, in addition to the hundreds of new houses already granted permission or recently built/being built, regardless of the scenario presented, will require a new bridge over the railway line in order to mitigate for the additional traffic congestion that such a large scale development will create. Therefore, if there wasn't a vehicular bridge over the railway line in any of the scenarios, we believe that this would cause significant challenges and issues with regard to traffic congestion at the existing railway crossings.

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No

The benefits and challenges set out in the document misses key points regarding the proximity to (and therefore likely negative impact on) the Ham Brook Strategic Wildlife Corridor, and the fact that this scenario involves land which directly adjoins Chichester Harbour National Landscape, which will therefore inevitably have a negative impact on its setting.

The part of this site directly adjoining the National Landscape is characterised by a field with a line of trees marking the boundary with the road, which contribute to the rural setting of the National Landscape. This area is not identified as a landscape gap in the Council’s study, however, there is concern about the impact on the setting of the National Landscape given the fact that the site lies directly adjacent to the NL and would take out the last remaining field between the Southbourne and Nutbourne settlement boundaries, effectively joining these settlements (and therefore resulting in actual coalescence, contrary to Local Plan Policy 20 and emerging Local Plan Policy NE3 criterion a) and b). This scenario also comes very close (in places) to the Ham Brook (rare chalk stream) Strategic Wildlife Corridor and is therefore likely to have a greater negative impact on this feature, however, this is not acknowledged within the Assessment Framework, which gives this scenario a score of ‘strong’ under the objective of ‘Preserve wildlife corridors’. It also comes very close to the identified landscape gap to the north of the railway line (the orange shading appears to slightly overlap with the purple shading of the landscape gap). This scenario is also to be avoided on the grounds of both landscape and nature conservation impacts, as well as the loss of Grade 1 and 2 agricultural land, and the reduced ecological connectivity between the Harbour and the South Downs.

We believe that a further 800 houses in Southbourne, regardless of the scenario presented, will require a new bridge over the railway line in order to mitigate for the additional traffic congestion that such a large-scale development will create. Therefore, if there wasn't a vehicular bridge over the railway line in any of the scenarios, we believe that this would cause significant challenges and issues with regard to traffic congestion at the existing railway crossings.

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No

The list of benefits misses out the key point that this scenario would be further removed from, and therefore likely to have less impact on, the rural setting of Chichester Harbour National Landscape. It would also have the least impact in terms of the coalescence of settlements, as it would wrap around the northern part of the existing settlement where it is well spaced apart from neighbouring settlements, and would not contribute to the urbanisation and infilling of the A259 corridor (the boundary of the National Landscape) which has been seen in recent years. It would also be the furthest removed from the Strategic Wildlife Corridors, and would have the least impact on the ecological connectivity between Chichester Harbour and the South Downs, of the 3 scenarios. Therefore, from both a landscape and nature conservation perspective, scenario 3 would be the least bad of the scenarios.

Scenario 3 would clearly have the least impact on the setting of Chichester Harbour National Landscape (NL), given that the housing/built element of the proposal would be limited entirely to land to the north of the railway line, and therefore would be removed a sufficient distance from the National Landscape such that it would be unlikely to affect views into or out of the NL, or the rural setting of the NL. Scenario 3 would also be the furthest removed from the Strategic Wildlife Corridors and is therefore less likely to have a negative impact in this regard (although this is not acknowledged in the Assessment Framework, which scores all 3 as ‘strong’ under the objective of ‘Preserve wildlife corridors’). Scenario 3 would be furthest away from the Harbour's edge and would therefore have the least impact in terms of recreational disturbance to the shoreline, provided a sufficient SANG is provided on site. A further 'benefit' of scenario 3, which is not acknowledged in the document, is that it would have the 'least worst' impact in terms of the loss of Grade 1 agricultural land, since the proposed housing area includes less Grade 1 as a proportion of the land than scenarios 1 and 2.

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Scenario 3: Mixed Scenario, Scenario 2: Land to the East, Scenario 1: Land to the West

Scenario 3 should be selected as the preferred option. Scenarios 1 and 2 are both potentially equally harmful to both landscape and nature conservation objectives, for the reasons given in our answers to earlier questions. All 3 of the scenarios would be located on Grade 1 and 2 Agricultural land and score as ‘poor’ within the Assessment Framework as a result; although scenario 3 would appear to have the ‘least bad’ impact in this regard, as the proposed housing area includes less Grade 1 land than scenarios 1 and 2. All 3 scenarios would increase recreational disturbance to Chichester Harbour SPA, and would therefore require significant mitigation, including the provision of the SANG, as well as contributions to the Bird Aware Solent mitigation package. Again, scenario 3 would have the least impact in this regard, due to being further away from the Harbour. All 3 scenarios would also have the potential to increase pressure on the existing Thornham Waste Water Treatment Works, and under current policy as set out by Natural England, would be required to demonstrate ‘nitrate neutrality’. However, scenario 3 would have the least impact on the setting of Chichester Harbour National Landscape, and therefore selecting this option would help to fulfil the Council’s duty under the Countryside and Rights of Way Act to ‘further the purpose’ of designation of the National Landscape, to conserve and enhance natural beauty. Scenario 3 would be the only option that would not result in actual and perceived coalescence of settlements and the continued urbanisation of the A259 corridor. Scenario 3 would also have the least impact on the Strategic Wildlife corridors and the ecological connectivity between the Harbour and the South Downs.

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