Southbourne Allocation DPD Reg 18 Interim Sustainability Appraisal

Comment

Representation ID: 6910

Received: 12/12/2024

Respondent: Metis Homes

Agent: Nova Planning

7.1 To further demonstrate the benefits of Scenarios 4 and 5, Table 3.1 of the Sustainability Appraisal (SA) for the Southbourne Allocation Development Plan Document (DPD) has been reproduced and Scenarios 4 and 5 have been added.

7.2 As the DPD is at an early stage of the plan making process, it is agreed that in some cases it is difficult to differentiate between the Scenarios. This means that the “score” against the Objectives is the same across all five Scenarios. However, through the supporting commentary and having regard to the evidence set out in these representations, it is demonstrated that when ranking the five Scenarios, 4 and 5 are ranked higher than Scenarios 1, 2 and 3. This is largely due to the fact that 4 and 5 do not rely on a multi modal bridge and prioritise development close to existing services and facilities. This has positive effects in terms of air quality, mitigating climate change and accessibility. By removing the vehicular bridge, development viability is improved and the has a positive effect on the delivery of affordable housing.

7.3 The revised table can be found at Appendix C of these representations, together with commentary
summarising the key findings.

[See attached document for full submission]

Comment

Representation ID: 6912

Received: 12/12/2024

Respondent: Metis Homes

Agent: Nova Planning

8.8 In summary, the alternative Scenarios 4 and 5 support the delivery of the Local Plan Review and the Vision and Objectives of the Southbourne DPD, unlike Scenarios 1, 2 and 3. For these reasons, it is considered that they represent a far more justified and sustainable basis on which to deliver development in the BLD.

Air/Environmental Quality
8.9 Paragraph 3.7 of the SA methodology (AECOM, September 2024) notes that the impacts on air quality largely depend on the degree to which each option proposes to manage an increase in traffic and congestion. Scenarios 4 and 5 perform favourably as they do not rely on a multi modal bridge, which would encourage car journeys, particularly around the village. They also maximise land to the south where existing services and facilities and easily accessible by foot or cycle and where there is a bus route along the A259. Scenario 4 performs more favourably as it locates the new primary school alongside the existing secondary school, reducing the need to travel between the two sites and dis-incentivising short vehicle trips which would have a negative effect on air quality.

8.10 Scenarios 1, 2 and 3 perform less favourably as they either rely on a multi modal bridge and/or they locate development north of the railway, away from existing services, facilities and public transport. The emphasis on sustainable transport and the corresponding reduction in traffic, means that whilst uncertainty remains at this stage, Scenarios 4 and 5 are ranked higher. Once mitigation is identified and the proposals progress, the level of uncertainty will decrease.

Biodiversity
8.11 By directing development to the southern part of the BLD, the impact on the Brent Geese Secondary Support Area (BGSSA) will be reduced, particularly in Scenario 5 which directs development north of the railway to the east.

8.12 The areas of traditional orchard to the east are noted (paragraph 3.13), although as identified at paragraph 3.15, impacts on biodiversity can be mitigated through design. As such, an uncertain effect is recorded at this stage, which is likely to improve as proposals progress.

8.13 As noted in the SA, it can be difficult to determine significant effects on biodiversity as these are largely dependent on mitigation measures, particularly during the design phase (paragraph 3.15). The ability to differentiate between Scenarios at this early stage is therefore difficult. Nevertheless, the reduced impact on BGSSA in Scenario 5 (as well as Scenario 2) is beneficial.

Climate Change Adaptation
8.14 Paragraph 3.16 of the SA notes that there are areas at high risk of flooding north of the railway line, in close proximity to the proposed multi modal bridge (Scenarios 1 and 2) which will potentially affect access. The sequential and exception tests may apply. Scenarios 4 and 5 do not rely on a road bridge, reducing the risk. This is also applicable to Scenario 3, albeit there are negative effects associated with the increased distance from existing services and facilities, resulting in a lower ranking.

Climate Change Mitigation
8.15 Paragraph 3.20 of the SA notes that the built footprint of Southbourne will increase under all Scenarios and this will result in an increase in emissions. It goes on to note that Southbourne has existing services and facilities, which creates a more positive picture when considering per capita emissions. In this regard, Scenarios 4 and 5 perform more favourably as they direct development to the areas closest to these services and facilities first. Paragraph 3.22 of the SA states that, “as all three options deliver the same quantum of growth, they will likely lead to similar overall emissions. This is not considered accurate. While growth may be the same, when people can benefit from sustainable transport choices, there will be a positive effect on climate change mitigation. Scenarios which provide alternatives to a road bridge, will dis-incentivise short car journeys. Scenarios which prioritise walking and cycling (Scenarios 4 and 5) are ranked higher.

Communities and Health
8.16 As a correction, we disagree with the conclusion that new services and facilities would be closer to the village centre (paragraph 3.25)

8.17 In addition, we do not believe that Scenario 3 has a positive effect on this objective as it disperses facilities and is not served by existing facilities. The amended table 3.1 reflects this.

8.18 Whilst all Scenarios will deliver open space and a part of the Green Ring, Scenarios 4 and 5 perform more favourably as they prioritise walking and cycling as the preferred mode of transport around Southbourne, providing opportunities for people to interact. Scenario 4 performs most favourably as it also locates the primary school next to existing facilities, creating an opportunity for a community hub around the schools and leisure centre.

8.19 The land south of the railway line is already well served by existing facilities and amenities, including access to high frequency rail and bus services and a strategic cycle route – with the potential to improve through the creation of the CHEMROUTE. Providing development to the south of the railway line will help ensure that these existing facilities and amenities are sustained alongside of a new local centre focussing on complementary services. The provision of pedestrian and cycle connections on one side of the settlement, where land has already been safeguarded for this purpose, would ensure that the community (north and south of the railway line) was connected, providing a more positive approach to placemaking. This means that whilst all Scenarios will have a positive effect on this objective, Scenarios 4 and 5 are ranked higher.

Economy and Employment
8.20 Whilst the SA concluded that it is difficult to differentiate between Scenarios 1, 2 and 3, Scenarios 4 and 5 perform more favourably due to their proximity to existing businesses along the A259 which provide employment opportunities as well as the regular bus service which provides links to employment opportunities in Emsworth, Havant, Portsmouth and Chichester. In addition, in delivering homes close to these existing businesses, the local economy will benefit.

8.21 Scenario 4 potentially performs better in relation to the industrial estate at Clovellly Road, development in Scenario 5 would be closer to the railway station. They have therefore been assessed equally against this objective.

Historic Environment
8.22 As noted at paragraph 3.36 of the SA, all of the Scenarios are in proximity to heritage assets. This includes Scenarios 4 and 5. However, it is recognised that the impacts will largely depend on the design and layout of development, so the negative effect is likely to be mitigated as proposals progress for all Scenarios. Hence a degree of uncertainty is noted (paragraph 3.36).

8.23 The ranking set out in amended Table 3.1 is currently based on a high level assessment which reflects the location of heritage assets. As the nature and extent of historical assets and settings is identified, the assessments and rankings may be refined.

Housing
8.24 Scenarios 4 and 5 will deliver the same quantum of development (800 homes) as Scenarios 1, 2 and 3 but place less pressure on the viability of the development. This provides more certainty on housing delivery. The Assessment Framework displayed on board 7 of the consultation exhibition shows that Scenarios 1 and 2 have a significantly poor/negative effect on deliverability (viability). As viability is at best, marginal, the inclusion of a road bridge jeopardises the delivery of housing and in particular, the delivery of affordable housing. This will have negative implications for the creation of a well-balanced community with a mix of house types and tenures.

8.25 The SA also notes a severance between the existing community to the south and proposed development to the north. This would be reduced, albeit not removed, through Scenarios 4 and 5 which seek to integrate new development with existing to the south. The creation of pedestrian and cycle bridges will help integrate communities.

Land, Soils and Resources
Land to the south of the railway line is in smaller parcels and generally unsuitable for agriculture. Further north, land becomes more open and suitable for farming. As Scenarios 4 and 5 maximise land to the south first, less land will be required from the north, having less of an impact on the loss of agricultural land. Scenarios 4 and 5 are therefore ranked higher. As they do not extend as far north as Scenarios 1, 2 and 3, there will also be reduced pressure on the land around the gas pipeline.

Landscape
8.26 Land to the south of the railway is more contained and surrounded by existing development, particularly in Scenario 5. The landscape becomes more open further north and therefore, new development will be more visible and closer to the South Downs National Park. The SA notes the potential for coalescence between settlements along the A259 (paragraph 3.48). However, Scenario 4 would retain a gap between Southbourne and Hermitage and Scenario 5 is bordered to the east by the strategic wildlife corridor. The more contained and enclosed character of land to the south and the retention of gaps between settlements mean that Scenarios 4 and 5 will have less of an impact in landscape terms and therefore, perform more favourably.

8.27 The Local Plan identifies a landscape gap to the west. Whilst there are likely to be negative effects on landscape with all 5 Scenarios, the eastern Scenarios are ranked higher as they direct development away from this gap.

Transport and Accessibility
8.28 The DPD places an unjustified emphasis on facilitating vehicle journeys. This is particularly true of Scenarios 1 and 2 which include a road bridge over the railway. This does not support the objective of contributing to the achievement of sustainable development (paragraph 16a of the NPPF).

8.29 The transport and accessibility benefits of Scenarios 4 and 5 are set out in these representations. Given that a new multi-modal bridge is unjustified, Scenarios 4 and 5 propose measures which reduce the need to travel by locating development in the first instance, close to existing services and facilities. Secondly, they promote walking and cycling and will be designed to ensure it is convenient, safe and enjoyable to use these modes of transport instead of the private car. They will help deliver the CHEMROUTE along the A259, improving access to Chichester, Emsworth and Havant for cyclists. Finally, development south of the railway benefits from existing public transport (bus and rail).
8.30 Whilst Scenarios 4 and 5 both perform positively, Scenario 4 is ranked higher due to the opportunity to co-locate the schools and other local infrastructure around a community hub.

Water
8.31 As the quantum f development is the same in all Scenarios, they will have similar impacts on water supply.

8.32 The SA notes that the Ems Water Body borders the north of Southbourne Parish and overlaps slightly with the Parish to the north-west (paragraph 3.72). Scenarios 4 and 5 direct development away from the northern part of the BLD, limiting the effects on this catchment.

[See attached document for full submission]