Southbourne Allocation Development Plan Document: Regulation 18 Consultation Main Document
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New searchWe support the proposed inclusion of a vision and objectives within the SADPD which have been informed by the Neighbourhood Plan and the emerging Local Plan. As with our above comments, any changes to the emerging Local Plan should be reflected in the SADPD. Whilst we broadly support the SADPD Vision, we note that the Neighbourhood Plan also recognises the wider role played by Southbourne as a focal point for the Bournes area. This should be reflected in the SADPD Vision. We note the objective in respect of “housing for all” highlights a number of different forms of housing. Notably no mention is made of the need for market housing both to meet housing needs (including for the wider area) and the role of market housing in supporting the delivery of affordable housing and other forms of infrastructure provision. The objective should therefore be updated to also refer to the provision of market housing. As set out in the accompanying i-Transport response (Appendix Two), the “transport and sustainable travel” objective is overly focused on connections to the railway station. Reference should also be made to bus stops and other key amenities. Reference should be made to providing direct walking and cycling routes to multiple points of access into the site, so as to minimise walking distances and thus increase the likelihood of making trips by walking or cycling. Doing so would accord with the first two bullets of paragraph 114 of the NPPF. [See attached document for full submission]
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2.19 Whilst our clients do not have land interests in this scenario, we do wish to highlight the following matters. 2.20 The SADPD highlights that a key benefit of this scenario is that that the northern side of the site allocation could be largely facilitated by a single landowner and land is safeguarded to the south of the railway line for a potential bridge (via existing S106 agreements). The potential bridge is also listed as a benefit of the proposals. 2.23 In the absence of a bridge, any intensification of the existing use of this crossing is likely to face objection by Network Rail. Network Rail are likely to expect a safe (grade separated) alternative, given likely increases in walking demands. Any order to extinguish the footpath, in the absence of a bridge, is likely to fail because the order making authority (Chichester District Council) will need to consider the detriment to existing users of the crossing when they come to their decision. The footpath cannot simply be taken away from existing users. The significance of this risk needs to be given appropriate weight in the SADPD decision making process. The matter is considered further in the technical note by i-Transport at Appendix Two, which include a case study from a development site that was similarly close to a pedestrian level crossing of a railway line. 2.24 Whilst the SADPD suggests there would be multiple opportunities to create walking and cycle connections into the existing village, as demonstrated by the i-Transport Technical Note at Appendix Two, there are in fact only three pedestrian routes into the site other than vehicular access points. Of these the St John’s Road access would require third party land (thereby running contrary to the suggestion that the land control position is less complex); the footpath 243_1 route would need improvement from the current grassed route through a recreation ground and would again require third party land. If the St John’s Road access could not be secured then the new residents would be subject to lengthy diversions for pedestrian and cycle access to many local facilities to the south and east. 2.25 With regards to the existing gas pipeline, it is noted that if development cannot be accommodated within this zone then it will push development further south and west. Whilst it is suggested that this “could potentially push development closer to the landscape gap addressed in the Landscape Gap assessment completed for Chichester District Council in 2019” this is considered to be incorrect. We comment on the Assessment Framework in Section Three but note that the proximity considerations identified by the Landscape Gap assessment have been incorrectly transposed onto the composite constraints map. These are correctly shown on Figure 2.2 of the Assessment Framework which clearly shows the “area for development 800 dwellings” under Scenario 1 would already encroach into the proximity considerations area. Clearly this would be further worsened if the area for development were to be pushed further south and west as a result of the pipeline constraint. Further information is also required on the relationship between the pipeline and the proposed access arrangement. 2.26 Whilst the SADPD notes that “a landscape corridor at the western edge of this scenario will mitigate and provide a spatial and visual gap to the north of the railway line,” at this stage it is unclear how successful such a solution would be and it is understood that no further assessment work has been undertaken to inform such an assumption. Indeed it is noted that the 2019 Landscape Gap Assessment concluded in respect of this gap that: “It is important that the area between Hermitage and Southbourne is retained as open countryside. The gap is essential in preventing the coalescence of the settlements and maintaining their separate identities.” 2.27 Furthermore, as set out in the SLR response at Appendix Three, any development to the west of Southbourne would be breaking out into open, agricultural land which would fundamentally change the form of the settlement. Whilst no Landscape and Visual Assessment has seemingly been prepared for Scenario 1, as noted in Appendix Three, there are unrestricted views potentially available to the South Downs National Park as noted at paragraph 2.16 of the Assessment Framework. 2.28 The majority of the site under Scenario 1 is identified as a Brent Geese Secondary Support Area. The Solent Wader and Brent Goose Strategy Guidance on Mitigation and Off-Setting Requirements Report (2018) makes clear in relation to such areas that “Loss of or damage to Secondary Support Areas should be discouraged, and on-site avoidance and mitigation measures considered wherever possible. However, where impacts cannot be avoided or adequately mitigated on-site, there may be scope for a more flexible approach to off-setting the impacts to these sites, provided the continued ecological function of the network is maintained and significant enhancements additionally delivered, for example by improved long term management.” The eastern section of the BLD (Scenario 2) is not subject to this designation and as such is a clear alternative which would avoid the loss of or damage to the Secondary Support Area. The SADPD has seemingly skipped the first step of the mitigation hierarchy (avoidance) and instead focused on minimisation and mitigation. The SADPD process should be updated to follow the mitigation hierarchy and consider opportunities for avoidance before other forms of mitigation, particularly in light of the availability of other spatial scenarios which would not affect this designation. 2.29 In light of the above, the benefits and challenges in relation to Scenario 1 should be updated, including the summary text, in order to accurately reflect the comments provided above. 2.21 We note however, that there are multiple landowners to the south of the railway line and indeed part of the land to the north of the railway line is owned by West Sussex County Council, and as recognised by the SADPD, further negotiation is likely to be required in respect of the bridge, including with Network Rail. This is similarly reflected in Appendix A which notes that a ‘land swap’ may be required to deliver the bridge footing. Further detail is therefore likely to be required in order to assess whether the bridge can be delivered and considered a benefit of the scheme. If further discussions have taken place, including with Network Rail, it is important that this is shared as part of future consultations and to inform the assessment of any financial implications so this can be factored into the viability and deliverability of this Scenario. [See attached document for full submission]
2.23 In the absence of a bridge, any intensification of the existing use of this crossing is likely to face objection by Network Rail. Network Rail are likely to expect a safe (grade separated) alternative, given likely increases in walking demands. Any order to extinguish the footpath, in the absence of a bridge, is likely to fail because the order making authority (Chichester District Council) will need to consider the detriment to existing users of the crossing when they come to their decision. The footpath cannot simply be taken away from existing users. The significance of this risk needs to be given appropriate weight in the SADPD decision making process. The matter is considered further in the technical note by i-Transport at Appendix Two, which include a case study from a development site that was similarly close to a pedestrian level crossing of a railway line. [See attached document for full submission]
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2.30 Wates support Scenario 2 and consider this to be the most appropriate solution to accommodate additional growth at Southbourne. [See attached document for full submission]
Benefits 2.31 As identified in the SADPD this scenario would include a series of benefits. In addition to those stated we would highlight the following: • Strong connectivity to the existing settlement by pedestrian and cycle by a number of potential routes which are not reliant on third party land. • Cycle improvements on Cooks Lane can be provided, enhancing links to the railway station. • Development would deliver the eastern section of the Green Ring which would benefit from easier access by existing residents as a result of the strong connectivity identified. This would form part of the substantial open space proposed under Scenario 2 which would retain a landscape corridor to the wildlife area to the east and has the ability to integrate existing water courses within a blue and green infrastructure strategy such as linking with the existing Ham Brook watercourse (rare chalk stream). This area is well located for providing a development buffer as well as strategically linking with the Southbourne Parish ‘Wildlife Corridors’ which run in a north to south direction, to the west of Hambrook. • Built development would not be located in the gap from the Landscape Gap Assessment and would not result in perceived coalescence of settlements. • Development would form a balanced and cohesive spatial growth structure which aligns with the current growth pattern of the settlement. Current consented residential schemes and Scenario 2 would serve to form an extension that continues to 'infill’ gaps in the urban form as well as linking with existing good transport corridors (see Appendix Three). • Development would not impact Brent Geese Secondary Support area. • Land to the east contains a mix of Grade 1, 2 and 3 agricultural land. • There are fewer existing PRoWS on the east of Southbourne, with therefore more opportunities to improve connectivity into the wider landscape. • The proposal is less reliant on a bridge than Scenario 1 with a greater quantum of development capable of being delivered in advance of the provision of any bridge. • Vehicular accesses have been agreed in principle with West Sussex County Council in respect of South Lane and the A259 Main Road. See Appendix Two for further details. • Growth to the east of Southbourne has the benefit of previous community support through the earlier Neighbourhood Plan process. Challenges 2.32 Our comments on the stated challenges in relation to Scenario 2 are as follows: • Based on our previous assessment work we understand that access to the site would not be prevented by the gas pipeline and that the pipeline easements would not preclude the works proposed (access etc) taking place. Whilst it is considered that vehicular access can be provided without infringement on the gas pipeline, in the event that access is required over it previous correspondence with SGN by RSK has advised that it will be permissible for roads to cross the pipeline, at right angles wherever possible, and with suitable protective measures in place. • It is considered that the reliance on the vehicular bridge is overstated. Scenario 2 could provide an alternative access north of the railway line (via Inlands Road) and a larger amount of land south of the railway. This means that Scenario 2 is less reliant on the bridge than Scenario 1. The challenges section should clarify this. Furthermore, the current live planning application (24/01161) is yet to be determined by the Council. • Paragraph 5.30 of the Consultation document raises concerns regarding the intensification of use of the Inland Road level crossing. Inlands Road has much lighter traffic flows than Stein Road, and only a small proportion of development traffic would use Inlands Road, and a single arm crossing. The issue at Inlands Road is therefore one of safety rather than capacity. Development at Scenario 2 provides an opportunity to introduce double barriers and therefore address this concern, whilst alleviating additional pressure on the Stein Road crossing. Paragraph 5.30 should be reworded accordingly. It is of course fair to say that the impact of development on the operation on the level crossings will need to be assessed. However, Inlands Road is not the key constraint. • Paragraph 5.31 suggests that the South Lane access is not appropriate in view of width and hedgerows and requires further technical work. This work has been undertaken. An access has been designed and subject to a safety audit and agreed in principle with WSCC. Further details are provided in Appendix Two. • All three scenarios involve multiple landowners. Whilst it is noted that planning applications have already started to come forward for development it is considered this provides further justification for Scenario 2 in ensuring a logical new eastern boundary to the settlement is created, with supporting infrastructure and new homes. The SADPD will ensure a coherent solution to development to the east of Southbourne comes forwards. Wates control the majority of the land to the east and are an experienced land promoter with a significant track record of delivering this scale of development • A small proportion of the land to the east is at risk of flooding (indeed this applies to all three Scenarios). Wates have commissioned further technical work on a range of matters, including in respect of flood risk, in support of Scenario 2 to provide further technical reassurance that this would not preclude development in this location. Based on work undertaken to date it is understood that the areas at risk of flooding are not an in-principle constraint to development and can be addressed through appropriate technical solutions and/or masterplanning of the site. Furthermore, the representations from i-Transport confirm that there are different options for the provision of access into the site and that one such access point (South Lane) has already been agreed in principle with the local highways authority. If flooding were to restrict the construction of the bridge (Wates Developments consider all risks can be mitigated), then other access routes into the site are available that are not impacted by flooding thereby eliminating development risk on this specific issue. As set out in the introduction we are keen to meet with the Council following the close of the consultation to further discuss our submissions and to agree the timescales for sharing any additional information prior to future consultation on the SADPD. 2.33 The conclusions in relation to Scenario 2 should be updated to reflect our above comments. 2.34 Draft Policy SB2 of the Submission Southbourne Neighbourhood Plan (February 2021) included proposed policy wording for the allocation of land east of Southbourne Village for development. This included a series of requirements to ensure the delivery of key components and recognised the additional technical work required to confirm the appropriate delivery of these, including timings. Whilst clearly some updates will be required to reflect the latest position, it is considered this would form a useful starting point in drafting the proposed allocation policy in the SADPD. [See attached document for full submission]
• It is considered that the reliance on the vehicular bridge is overstated. Scenario 2 could provide an alternative access north of the railway line (via Inlands Road) and a larger amount of land south of the railway. This means that Scenario 2 is less reliant on the bridge than Scenario 1. The challenges section should clarify this. Furthermore, the current live planning application (24/01161) is yet to be determined by the Council. [See attached document for full submission]
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2.35 Given the nature of Scenario 3, where relevant to Scenario 3, our earlier comments in respect of Scenarios 1 and 2 should be reflected in the assessment of Scenario 3. As noted above, our client’s consider Scenario 3 to also potentially be a suitable scenario, subject to further consideration on the delivery of infrastructure and how this could be equalised across the parties. We provide further comments on the specifics of Scenario 3 below. 2.36 It is noted that Scenario 3 proposes the location of the new primary school to the east of Southbourne as in Scenario 2. The SADPD notes the potential beneficial effects of distributing traffic across the village by spreading the educational facilities within Southbourne and connectivity to the Green Ring. We do not repeat our earlier comments but note that further technical assessment work may be required to support the SADPD from a highways perspective. As per our earlier comments, land to the east benefits from significantly more pedestrian and cycle connections into the existing settlement which will enhance the accessibility to both new and existing services and facilities. A proportion of the proposed new homes would therefore benefit from this greater connectivity to the east, compared to Scenario 1 which would only have the more limited connections. 2.37 Scenario 3 is suggested to not require the delivery of a multi-modal bridge. It is likely that additional evidence will be required to demonstrate this is the case, noting that in particular Scenario 3 would result in a significantly higher number of vehicles travelling down Stein Road. Our previous comments in relation to the delivery of the footbridge to the west also apply to this Scenario and are expanded on at Appendix Two. As with Scenario 1, further information is also required on the relationship of the proposed access and the pipeline. We note that our information indicates that the access road to the east would not be impacted by the pipeline with little loss of development area so this does not represent a constraint to the proportion of growth which could be accommodated to the east. 2.38 We disagree with the assertion that Scenario 3 would create a more balanced spatial growth pattern that is aligned with the shape and form of Southbourne. This is inconsistent with the statement in 2.16 and 2.17 of the DPD that settlement form is more compact to the west, but that recent development has already expanded from the eastern side of the village. Whilst Scenario 3 would result in a reduced scale of growth to the west, it is important to recognise that any development to the west of the village would be breaking out into open, agricultural land which would fundamentally change the form of the settlement. In contrast development to the east would be in the direction of existing low density development, meaning that the overall form of the settlement would not change substantially. Current ‘consented’ residential schemes and the eastern scenario development proposals would serve to form an extension that continues to ‘infill’ gaps in the urban form as well as linking with existing good transport corridors. As such, it is considered that the assertion that Scenario 3 would create a more balanced spatial growth pattern is not reflective of the evidence. It is noted that Scenario 3 would continue to deliver some of the benefits of ‘infilling’ gaps in the urban form to the east which would not be achieved under Scenario 1. 2.39 It is noted that this scenario is stated to “retain flexibility for future growth of the village if required.” The accompanying Figure for Scenario 3 does not include a proposed gap annotation (our assumption of the meaning of the green annotation although not identified on the key) to the west of the settlement as shown in Scenario 1. It is understood that proposed gaps are to be included in the DPD, however it is unclear whether this is under all scenarios. Furthermore, it is considered that all three Scenarios potentially retain flexibility for future growth whilst allowing comprehensive masterplanning through the DPD process rather than resulting in an onion skin approach to the growth of the settlement. This is particularly imperative in light of our wider comments on housing growth and the likely need for additional growth to be brought forward at Southbourne. [See attached document for full submission]
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