Southbourne Allocation Development Plan Document: Regulation 18 Consultation Main Document

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Housing Delivery - It is considered that all 3 scenarios should consider capacity to provide over and above 800 homes to provide flexibility in supply to ensure the Local Plan housing requirement is met. This will take account of potential unforeseen factors which may affect delivery of land parcels within the allocation option areas. In view of landscape sensitivity constraints associated with scenario 1, including local gap, it is uncertain whether 800 dwellings can be delivered, and this should be reflected as a challenge. Green Ring - This scenario may enable the delivery of the western section of the Southbourne Green Ring, which is identified as a benefit. However, it should also be identified as a challenge that this scenario does not provide the opportunity to comprehensively deliver the Green Ring, which is achievable in Scenario 3. Landscape Impact - We agree with the identification of impact on landscape gap as a key challenge and constraint for this scenario. This scenario includes an area identified as part of the Hermitage and Southbourne Local Gap from the Landscape Gap Assessment (CDC, 2019). Furthermore, the location of the existing gas pipeline through the north of this scenario is likely to push development closer into the landscape gap and affect the integrity of the gap. Therefore, it is considered that this scenario may affect the integrity of the local gap and it is uncertain whether the provision of a landscape corridor on the western edge of the scenario will enable appropriate mitigation of impact and delivery of c800 homes. Transport Impact - The draft DPD raises a challenge regarding potential transport impact if a multi-modal vehicular bridge is not delivered as part of this scenario and the impact of increased footfall on the pedestrian level crossing at Church footpath. The potential impact will need to be robustly explored with Network Rail and necessary transport modelling undertaken by the Council. Flood Risk - There are surface water flooding constraints affecting this scenario on the western edge of Southbourne particularly affecting land to the north of the railway line but also land to the south. The Environment Agency surface water flood maps identify a significant area north of the railway line on the western edge affected by high risk (3.3% chance each year) and medium risk (1 - 3.3% chance). In accordance with NPPF paragraph 167 a sequential approach should be applied to plan making taking account of all sources of flood risk and the current and future impacts of climate change. In the absence of a sequential test for the scenario area to assess whether there are any reasonably available alternative sites in areas of lower flood risk and in view of landscape gap constraints it is uncertain whether this scenario is capable of delivering c800 dwellings. Utilities Consultation Area - It is appropriate to identify the challenge concerning the percentage of land for development including the access road being located within the utilities consultation zone. This may affect the deliverability of key utility and infrastructure requirements required for the sustainable delivery of this scenario. Brent Geese - It is appropriate to identify that this scenario would result in a significant loss of land within the Brent Geese 'Secondary Support Area', which would need to be mitigated. A clear strategy is required to demonstrate this is capable of mitigation. Landownerships - The draft DPD identifies a key benefit that the northern side of the site allocation could be largely facilitated by a single landowner which may support a co-ordinated and comprehensive approach to master planning and delivery of infrastructure. With this scenario, there is a potential disadvantage in relying on a single landowner if any specific deliverability issues arise. The delivery of Scenario 1 (Land to the West) also requires co- ordination of land ownerships south of the railway line which should also be identified as a potential challenge. Scenarios 2 and 3 involve the co-ordination of land ownerships but delivery is not reliant on a single landowner and there is potential for development to come forward earlier in the Plan period with land parcels coming forward concurrently. [See attached document for full submission]

Housing Capacity - As set out above it will be necessary to identify the potential challenge associated with this option in delivering c800 dwellings when landscape gap, ecology, flood risk and potential highways capacity constraints are considered through the DPD. Distribution of Development - In comparison to Scenario 3 the approach to the distribution of development on the western edge provides a less balanced delivery of growth. Scenario 3 provides an opportunity to balance the distribution of c800 dwellings, which is also likely to be more deliverable in terms of highways impact and in view of landscape and flood risk constraints in the western scenario. Transport Impact - It should be recognised as stated in the SA that Scenario 1 performs least well in transport terms as it relies on the provision of a singular multi modal bridge, only has one point of vehicular access, provides no opportunity to improve pedestrian and cycle access to the railway station and creates a barrier to movement and integration between new development and existing development in the village. Ecology - In ecology terms the SA identifies that this scenario has the potential to impact on the ecological status of the Ems Water Body (bordering the north of Southbourne Parish) which is vulnerable and currently has poor ecological status as confirmed by the Environment Agency. This should be reflected in the challenges for this scenario. [See attached document for full submission]

The draft DPD raises a challenge concerning the potential transport impact if a multi-modal vehicular bridge is not delivered as part of this scenario and the increased footfall on the pedestrian level crossing at Church footpath. The potential impact will need to be explored with statutory providers including Network Rail and appropriate transport modelling will need to be undertaken by the Council in preparation of the DPD. It is uncertain at this stage what the impact of not delivering the bridge will be. [See attached document for full submission]

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Pedestrian Railway Footbridge - This scenario identifies the potential to deliver land for a pedestrian and cycle bridge adjacent to the railway line within 'Land at Cooks Lane' which is also a priority of the Southbourne Neighbourhood Plan. This will enable a connection to the Green Ring south of the railway line, Southbourne Infant and Juniors School and services / facilities in the village. The land to facilitate the crossing between the Land at Cooks Lane and Priors Orchard to the south of the railway line is within the control of our client, Elivia Homes. The railway crossing is deliverable and ongoing engagement is being undertaken with the Council and Network Rail regarding design and delivery of the bridge. Green Ring - It is appropriate to identify the benefit associated with the delivery of the eastern section of the Green Ring. This scenario includes 'Land at Cooks Lane', which is required to deliver a large proportion of the Green Ring to the north of the railway line, linking to the Green Ring to the north and also to the south (Priors Orchard) through the provision of the railway footbridge. Multi Modal Railway Bridge - There is a potential benefit associated with the delivery of a new multi-modal vehicular bridge that would connect the A259 to Priors Leaze Lane through various parcels of land east of Inlands Road. It is identified that this would relieve pressure from the crossing point at Inlands Lane, and congestion at the Stein Road crossing. The requirement to deliver the bridge is a matter for the Council to explore with statutory providers, including Network Rail. The Council should undertake appropriate transport modelling as part of the preparation of the DPD to determine the impact of this scenario if the bridge is not delivered. Education Provision - This scenario enables the delivery of a new 2FE school, which is a clear benefit. This option is supported and will enable a more balanced distribution of education provision in Southbourne Village, distributing traffic across the village and providing associated pedestrian, cycle connections and links to the Green Ring. Landscape Impact - In landscape terms this scenario does not have a significant landscape impact and maintains the integrity and purposes of the Southbourne to Hambrook Local Gap identified in the Landscape Gap Assessment (2019). This scenario also retains the landscape corridor to the wildlife area to the east and has the ability to integrate existing water resources within a blue and green infrastructure strategy. This scenario also proposes to deliver development in the least constrained parts of the Parish, in accordance with the Landscape Capacity Study for Chichester (2019). The landscape corridor to the eastern edge also provides a spatial and visual gap to the north of the railway line. In landscape terms there is no constraint on delivery of c800 homes and this scenario performs better that Scenario 1 - Land to the West where the wider allocation option is more constrained in landscape terms. Gas Pipeline - In relation to the location of the gas pipeline it is understood that this would not constrain the sustainable delivery of c800 dwellings within this scenario. There will be a requirement for the Council to engage with statutory consultees regarding land within the consultation zone and the delivery of the northern access point connecting to Stein Road. Site Access - This scenario identifies the potential for a secondary access from South Lane to Stein Road and it is appropriate that the Council undertakes further technical work regarding options to achieve access in this location and to consider alternative options. Flood Risk - In flood risk terms the broad area for development in Scenario 2 is within flood zone 1 and flood risk is not a constraint on the delivery of c800 dwellings or more. There is an area to the east (outside of the growth area) adjacent to Hambrook within flood zone 2 and 3 but this does not affect the deliverability of this growth scenario. Within the wider scenario area there is limited surface water flooding which does not affect the delivery of c800 homes and there is only potential impact on site access options. An FRA and drainage / SuDs strategy has been prepared for the Land at Cooks Lane site (within the wider allocation) which demonstrates the sustainable delivery of c100 homes in this location. Further technical work will need to be undertaken by the Council in relation to the potential location of a multi modal vehicular bridge and drainage strategy for this location. Landownerships - We consider that a comprehensive and co-ordinated approach can be achieved to effectively realise the objectives of the emerging Southbourne Allocation DPD and Submission Local Plan. Elivia Homes is supportive of working closely with other landowners to ensure a comprehensive and co-ordinated approach to master planning and infrastructure delivery. Through the preparation of the IDP and CIL Business Plan there is scope to co-ordinate proportionate financial contributions to key infrastructure required to support delivery of the wider allocation. [See attached document for full submission]

Accessibility to Services - A further benefit of this scenario is accessibility to key services and facilities in Southbourne Village and also further afield via public transport links. This scenario is well related to the settlement edge of Southbourne and accessible within reasonable walking and cycling distances to services and facilities in Southbourne including supermarkets, health facilities and public transport services. From the Land at Cooks Lane, the nearest primary school is located within 250m and the nearest secondary school 750m to the west. The West Coastway Railway Line and Southbourne Train Station are located to the south-west, which is highly accessible by walking and cycling. The SA also identifies that Scenario 2 provides closer access to the railway station and employment opportunities further afield. Transport Impact - In transport terms the SA identifies that scenario 2 performs most favourably as it utilises the existing multi-modal bridge and pedestrian crossing via Inlands Road and includes the provision of a pedestrian / cycle footbridge and new multi modal bridge. This should be recognised in the benefits. Ecology - In ecology terms this option does not involve the loss of any land from the Brent Geese Support Area and this should be recognised as a benefit. [See attached document for full submission]

The draft DPD raises a potential challenge related an increase in traffic on Inlands Road Crossing if a multi-modal vehicular bridge is not delivered as part of this scenario. The potential impact will need to be explored with statutory providers including Network Rail and appropriate transport modelling will need to be undertaken by the Council in preparation of the DPD. It is uncertain at this stage what would be the impact of not delivering the bridge. [See attached document for full submission]

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Distribution of Development - The balanced approach to the distribution of development in this scenario provides the option for further sustainable and proportionate growth in the future appropriate to the role and function of Southbourne as a settlement Hub in the Local Plan settlement hierarchy. Transport Impact - This option is potentially more deliverable in transport terms when assessed against scenarios 1 and 2, as stated in the SA Report. This scenario is more readily accessible with the main access from Stein Road into land to the east and west. It also benefits from multiple points of potential vehicular and pedestrian / cycle access, as well as the opportunity to deliver a complete pedestrian / cycle route around the northern part of the village through the delivery of a green ring. Distributing development on 'suitable' sites around Southbourne also reduces the potential need for a multi modal bridge. As stated in response to scenarios 1 and 2 the Council will need to engage with statutory consultees and undertake appropriate transport modelling to assess transport impact including in relation to Stein Road, Inlands Road crossings, Church footpath and Penny Lane footpath. Green Ring - We agree it is important to identify the delivery of an almost complete Green Ring, as prioritised in the Southbourne Neighbourhood Plan, as another key benefit to this scenario. In this respect this scenario performs better than scenarios 1 and 2. Pedestrian Railway Footbridge - Within Scenario 2 and 3 the Land at Cooks Lane provides the safeguarded land to enable the delivery of a new pedestrian and cycle footbridge over the railway line which is a key priority of the Southbourne Neighbourhood Plan. The footbridge is also a key element of the Green Ring that provides a safe and direct pedestrian and cycle link to the Primary School, railway station and Southbourne Village centre. The land to facilitate the crossing is within the control of Elivia Homes, as stated above. The railway crossing is deliverable and ongoing engagement is being undertaken with the Council and Network Rail regarding design and delivery of the bridge. Landscape Impact - This scenario provides a balanced approach to the distribution of development around Southbourne which has less impact on National Landscapes and maintains the integrity of the settlement gaps to the east and west of Southbourne as identified in the Local Gap Assessment (CDC, 2019). The SA identifies that this scenario would have less impact in comparison to scenarios 1 and 2 on the National Landscape to the south. Scenario 3 also locates development within areas that have greater capacity for change as identified in the Landscape Capacity Study for Chichester (2019). Education Provision - The location of the new primary school in this scenario is the same as scenario 2 'Land to the East' which enables a more balanced distribution of education provision in Southbourne Village, distributing traffic across the village and provides associated pedestrian, cycle connections and links to the Green Ring. Gas Pipeline - In relation to the location of the gas pipeline consultation zone it is understood that this would not constrain the sustainable delivery of c800 dwellings within this scenario. There will be a requirement for the Council to engage with statutory consultees regarding land within the consultation zone and the delivery of the northern access point. Brent Geese - This scenario would have an impact on the Brent Geese Secondary Support Area which will require mitigation but the impact is less than scenario 1 and it is understood that appropriate mitigation options have been identified. Flood risk - In relation to flood risk and areas of surface water flooding, a balanced approach to locating development on the west and least of Southbourne enables development to be located in areas of lowest risk and provides greater certainty in delivering c800 dwellings. Landownerships - In the context of landownerships, Elivia Homes considers that a comprehensive and co-ordinated approach can be achieved to effectively realise the objectives of the emerging Southbourne Allocation DPD and Submission Local Plan. Elivia Homes is supportive of working closely with other landowners to ensure a comprehensive and co-ordinated approach to masterplanning and infrastructure delivery. Through the preparation of the IDP and CIL Business Plan there is scope to co-ordinate proportionate financial contributions to key infrastructure required to support delivery of the wider allocation. [See attached document for full submission]

Housing Delivery - This scenario is capable of providing for c800 dwellings or higher in view of the balanced distribution of development. This would provide sufficient flexibility to ensure the housing requirement to be met and also enable the potential for future growth proportionate to the role and function of Southbourne in the Local Plan settlement hierarchy. Transport Impact - The SA identifies that Scenario 3 performs well in transport terms as it has multiple points of potential vehicular and pedestrian cycle access, as well as the opportunity to deliver a complete pedestrian / cycle route around the northern part of the village through the delivery of a green ring. This should be recognised as a benefit. Flood Risk - The SA identifies that Scenario 3 performs best in flood risk terms as it does not contain any areas of high risk or surface water or fluvial flooding which should be identified as a benefit. Railway Connectivity - Options 3 (and 2) perform most favourably in relation to proximity to the railway station in comparison to Scenario 1 which should be identified as a benefit. [See attached document for full submission]

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

Growth Scenario Ranking - Scenario 3 It is considered that this scenario (3) should be ranked 1st in order of sustainability and consistency with national and local policy. This scenario is considered more sustainable and deliverable in comparison to scenarios 1 and 2. This scenario provides a balanced and sustainable pattern of development which has the least impact in landscape terms and is likely to be more deliverable in respect of transport impact. This scenario also enables the delivery of almost complete Green Ring in accordance with the Southbourne Neighbourhood Plan. In this scenario there is scope for a coordinated approach between landownerships to ensure a comprehensive approach and delivery of key infrastructure. Growth Scenario Ranking - Scenario 2 It is considered that this scenario should be ranked 2nd in order of sustainability and consistency with national and local policy. This scenario enables the delivery of c800 homes which are deliverable in relation to local constraints and infrastructure requirements. A comprehensive and co-ordinated approach to master planning and infrastructure delivery is also achievable in respect of landownerships. This scenario is considered more sustainable to Scenario 1 ‘Land to the West’ which is constrained in respect of landscape gap, gas pipeline, ecology and flood risk which raise uncertainty regarding c800 homes can be sustainable delivered. Growth Scenario Ranking - Scenario 1 This scenario should be ranked 3rd in order of sustainability and consistency with national and local policy in comparison to Scenario 2 and 3. Scenario 1 ‘Land to the West’ is the most constrained growth option in terms of landscape gap, ecology, transport and flood risk impacts, which raises significant uncertainty regarding the ability to sustainably deliver c800 dwellings. [See attached document for full submission]