Southbourne Allocation Development Plan Document - Regulation 19 Consultation

3. To which part of the Southbourne Allocation Development Plan Document does this representation relate?

Southbourne Allocation DPD Main Document

4. Do you consider the Southbourne Allocation Development Plan Document is:

4. (1) Legally compliant Yes

4. (2) Sound Yes

5. Please give details of why you consider the Southbourne Allocation Development Plan Document to not be legally compliant or is unsound. Please be as precise as possible. If you wish to support the legal compliance or soundness of the Southbourne Allocation DPD, please also use this box to set out your comments.

Whilst we do not have soundness or legal compliance concerns with the Southbourne Allocation Development Plan Document, we have comments with regards to transport matters and matters on extra care housing.

Comments related to transport

Following the Reg 18 consultation WSCC have reviewed the evidence base and undertaken further discussions with the strategic site promoters. The County Council would like to update some areas of the DPD, clarifying some aspects of the site access arrangements for vehicular traffic and sustainable modes. Some further work is required by the strategic site promoters around the sustainable transport strategy. Therefore, our comments are not objections to the DPD, but suggestions on the need to refine some of the sustainable mitigation measures.

Vision

The proposed vision is in line with the relevant national and local policies. However, it currently misses a key opportunity to embed the vision-led approach to transport planning that is outlined in the accompanying Transport Assessment (TA). As currently worded, it seeks to maximise opportunities without indicating a minimum acceptable level for use of sustainable modes of transport. From a transport perspective, including a minimum mode share within the vision could act as a guiding light for the development against which future planning applications can be considered. It is suggested that in line with the accompanying Transport Assessment, a minimum sustainable transport (public transport & active travel) mode share for external trips of 32% is added to the vision. This relates to the analysis of vision-led trips in section 5.6 of the TA and the figures presented in table 5:12 - Mode split Comparison (Total External Trips) - of 18% Public Transport plus 14% active Travel mode shares.

Transport and Sustainable Travel Principles

Paragraph 5.26 - The intent within this paragraph is noted. However, the development will be adding traffic to Inlands Road as this will be a means of access to the site, Therefore, the opportunity for traffic to be reduced or redirected as implied within the current wording is unlikely to be possible. It is suggested that paragraph 5.26 should be reworded to encourage traffic reduction where possible and a comprehensive package of improvements that includes speed limit reductions alongside physical infrastructure to improve the comfort and safety of pedestrians and cyclists. The wording 'Relevant application must take the opportunity' also allows development to be taken forward in a piecemeal fashion alongside various applications, rather than as part of a comprehensive development of the site. This raise concerns as piecemeal development could result in difficulties securing the necessary infrastructure. it is suggested the paragraph should be reworded to help encourage comprehensive development of the site and required infrastructure delivery.

The last sentence which identifies opportunities to improve active travel links could be improved by including reference to the bus stops on the A259 served by the 700 bus service and also the Bourne Community College.

Paragraph 5.29 - This paragraph references a bus route/gate (which is also known as a 'modal filter'). There is currently a high-level of uncertainty over whether a bus service will route through the site. As such, the wording should be rephrased so as only to require the design of internal access roads to allow for a future bus service, including retrofitting a bus gate, but not assume that there will be a bus service from the start.

Comments related to extra care housing

Paragraphs 5.18 and 5.19 reference the CLP policy and older persons housing. In the WSCC Market Position Statements, it is noted that there is no need for net growth in supply of care home beds in the county, as several providers have developed new services and report a high volume of voids. However, the County Council is interested in developing Extra Care Housing schemes and would welcome conversations around this with future developers. Further information on WSCC's Market Positions Statements are available at: https://www.westsussexconnecttosupport.org/alt-home/market-position- statement-and-commissioning-strategy/

6. Please set out the modification(s) you consider necessary to make the Southbourne Allocation DPD legally compliant and sound, in respect of any legal compliance or soundness matters you have identified at 5 above. You will need to say why each modification will make the Southbourne Allocation DPD legally compliant or sound. It will be helpful if you are able to suggest revised wording of any policy or text. Please be as precise as possible.

WSCC have set out our recommended modifications in Section 5 of this form. To avoid doubt, there are no concerns with the overall soundness and legal compliance of the Development Plan Document.

For clarification, we also suggest making the following changes to Appendix A - Infrastructure Delivery Plan Update:

1. In the justification/rationale column under Inlands Road Level Crossing, add "Also provide improved pedestrian facility over the crossing, likely to require minor widening of the crossing."

2. High quality walking and cycling route to A259 bus stops

In justification/rationale column, add "Provide safe, comfortable and convenient walking and cycling route from the development along Inlands Road to the A259 to access the bus stops. This should include footway improvements to provide a continuous route and traffic management measures to improve conditions for cyclists which may include review and reduction of speed limits.". Phasing "To coincide with a construction of access to the southern and eastern parcels of the development" As this scheme does not form part of the County Council's plans for investment in the highway network and will be essential to deliver the proposed vision, the delivery lead for this infrastructure should be the developer.

3. As an additional row item, add 'High Quality walking and cycling route to Southbourne Station and Stein Road'.

In justification/rationale column "Provide safe comfortable and convenient route from the development to Stein Road linking to the rail station and providing crossing facilities to improve safe access towards Bourne Community College, the leisure centre and the convenience store. This is likely to include measures to link to and enhance facilities at Cooks Lane to be provided by other development adjacent to that road." As this scheme does not form part of the County Council's plans for investment in the highway network and will be essential to deliver the proposed vision, the delivery lead for this infrastructure should be the developer.

4. Further amendments to the IDP Update Table are detailed below:

S/N 1 - Scheme -Foot/cycle bridge over Railway
line (e.g. between Cooks Lane site and Priors Orchard)*. Suggested amendment - Change delivery lead to developer and acknowledge that the location
and delivery arrangements will be subject to land availability on both sides of the railway line.

S/N 2 - Scheme - Southbourne bus service
improvements/extension. Rationale: To integrate bus
services into the initial phases of development to help create strategic options for behavioural changes and mode choice.
Suggested amendment - As Stagecoach has indicated that it is unlikely to see a case for diverting the 700 service into the site, direct on-site public transport integration is not currently achievable. However, public transport access may still be supported through improvements to the existing services on the A259.
We suggest rewording the scheme as, ‘Increase 700 service frequency to 15 minutes on weekdays, and 15 minutes during weekends’.

7. If your representation is seeking a modification to the plan, do you consider it necessary to participate in examination hearing session(s)?

No, I do not

8. If you wish to participate in the hearing session(s), please outline why you consider this to be necessary:

Not Applicable

It is suggested that paragraph 5.26 should be reworded to encourage traffic reduction where possible and a comprehensive package of improvements that includes speed limit reductions alongside physical infrastructure to improve the comfort and safety of pedestrians and cyclists. The wording ‘Relevant application must take the opportunity’ also allows development to be taken forward in a piecemeal fashion alongside various applications, rather than as part of a comprehensive development of the site. This raise concerns as piecemeal development could result in difficulties securing the necessary infrastructure. it is suggested the paragraph should be reworded to help encourage comprehensive development of the site and required infrastructure delivery.
The last sentence which identifies opportunities to improve active travel links could be improved by including reference to the bus stops on the A259 served by the 700 bus service and also the Bourne Community College.

3. To which part of the Southbourne Allocation Development Plan Document does this representation relate?

Southbourne Allocation DPD Main Document

4. Do you consider the Southbourne Allocation Development Plan Document is:

4. (1) Legally compliant Yes

4. (2) Sound Yes

5. Please give details of why you consider the Southbourne Allocation Development Plan Document to not be legally compliant or is unsound. Please be as precise as possible. If you wish to support the legal compliance or soundness of the Southbourne Allocation DPD, please also use this box to set out your comments.

Whilst we do not have soundness or legal compliance concerns with the Southbourne Allocation Development Plan Document, we have comments with regards to transport matters and matters on extra care housing.

Comments related to transport

Following the Reg 18 consultation WSCC have reviewed the evidence base and undertaken further discussions with the strategic site promoters. The County Council would like to update some areas of the DPD, clarifying some aspects of the site access arrangements for vehicular traffic and sustainable modes. Some further work is required by the strategic site promoters around the sustainable transport strategy. Therefore, our comments are not objections to the DPD, but suggestions on the need to refine some of the sustainable mitigation measures.

Vision

The proposed vision is in line with the relevant national and local policies. However, it currently misses a key opportunity to embed the vision-led approach to transport planning that is outlined in the accompanying Transport Assessment (TA). As currently worded, it seeks to maximise opportunities without indicating a minimum acceptable level for use of sustainable modes of transport. From a transport perspective, including a minimum mode share within the vision could act as a guiding light for the development against which future planning applications can be considered. It is suggested that in line with the accompanying Transport Assessment, a minimum sustainable transport (public transport & active travel) mode share for external trips of 32% is added to the vision. This relates to the analysis of vision-led trips in section 5.6 of the TA and the figures presented in table 5:12 - Mode split Comparison (Total External Trips) - of 18% Public Transport plus 14% active Travel mode shares.

Transport and Sustainable Travel Principles

Paragraph 5.26 - The intent within this paragraph is noted. However, the development will be adding traffic to Inlands Road as this will be a means of access to the site, Therefore, the opportunity for traffic to be reduced or redirected as implied within the current wording is unlikely to be possible. It is suggested that paragraph 5.26 should be reworded to encourage traffic reduction where possible and a comprehensive package of improvements that includes speed limit reductions alongside physical infrastructure to improve the comfort and safety of pedestrians and cyclists. The wording 'Relevant application must take the opportunity' also allows development to be taken forward in a piecemeal fashion alongside various applications, rather than as part of a comprehensive development of the site. This raise concerns as piecemeal development could result in difficulties securing the necessary infrastructure. it is suggested the paragraph should be reworded to help encourage comprehensive development of the site and required infrastructure delivery.

The last sentence which identifies opportunities to improve active travel links could be improved by including reference to the bus stops on the A259 served by the 700 bus service and also the Bourne Community College.

Paragraph 5.29 - This paragraph references a bus route/gate (which is also known as a 'modal filter'). There is currently a high-level of uncertainty over whether a bus service will route through the site. As such, the wording should be rephrased so as only to require the design of internal access roads to allow for a future bus service, including retrofitting a bus gate, but not assume that there will be a bus service from the start.

Comments related to extra care housing

Paragraphs 5.18 and 5.19 reference the CLP policy and older persons housing. In the WSCC Market Position Statements, it is noted that there is no need for net growth in supply of care home beds in the county, as several providers have developed new services and report a high volume of voids. However, the County Council is interested in developing Extra Care Housing schemes and would welcome conversations around this with future developers. Further information on WSCC's Market Positions Statements are available at: https://www.westsussexconnecttosupport.org/alt-home/market-position- statement-and-commissioning-strategy/

6. Please set out the modification(s) you consider necessary to make the Southbourne Allocation DPD legally compliant and sound, in respect of any legal compliance or soundness matters you have identified at 5 above. You will need to say why each modification will make the Southbourne Allocation DPD legally compliant or sound. It will be helpful if you are able to suggest revised wording of any policy or text. Please be as precise as possible.

WSCC have set out our recommended modifications in Section 5 of this form. To avoid doubt, there are no concerns with the overall soundness and legal compliance of the Development Plan Document.

For clarification, we also suggest making the following changes to Appendix A - Infrastructure Delivery Plan Update:

1. In the justification/rationale column under Inlands Road Level Crossing, add "Also provide improved pedestrian facility over the crossing, likely to require minor widening of the crossing."

2. High quality walking and cycling route to A259 bus stops

In justification/rationale column, add "Provide safe, comfortable and convenient walking and cycling route from the development along Inlands Road to the A259 to access the bus stops. This should include footway improvements to provide a continuous route and traffic management measures to improve conditions for cyclists which may include review and reduction of speed limits.". Phasing "To coincide with a construction of access to the southern and eastern parcels of the development" As this scheme does not form part of the County Council's plans for investment in the highway network and will be essential to deliver the proposed vision, the delivery lead for this infrastructure should be the developer.

3. As an additional row item, add 'High Quality walking and cycling route to Southbourne Station and Stein Road'.

In justification/rationale column "Provide safe comfortable and convenient route from the development to Stein Road linking to the rail station and providing crossing facilities to improve safe access towards Bourne Community College, the leisure centre and the convenience store. This is likely to include measures to link to and enhance facilities at Cooks Lane to be provided by other development adjacent to that road." As this scheme does not form part of the County Council's plans for investment in the highway network and will be essential to deliver the proposed vision, the delivery lead for this infrastructure should be the developer.

4. Further amendments to the IDP Update Table are detailed below:

S/N 1 - Scheme -Foot/cycle bridge over Railway
line (e.g. between Cooks Lane site and Priors Orchard)*. Suggested amendment - Change delivery lead to developer and acknowledge that the location
and delivery arrangements will be subject to land availability on both sides of the railway line.

S/N 2 - Scheme - Southbourne bus service
improvements/extension. Rationale: To integrate bus
services into the initial phases of development to help create strategic options for behavioural changes and mode choice.
Suggested amendment - As Stagecoach has indicated that it is unlikely to see a case for diverting the 700 service into the site, direct on-site public transport integration is not currently achievable. However, public transport access may still be supported through improvements to the existing services on the A259.
We suggest rewording the scheme as, ‘Increase 700 service frequency to 15 minutes on weekdays, and 15 minutes during weekends’.

7. If your representation is seeking a modification to the plan, do you consider it necessary to participate in examination hearing session(s)?

No, I do not

8. If you wish to participate in the hearing session(s), please outline why you consider this to be necessary:

Not Applicable

As such, the wording should be rephrased so as only to require the design of internal access roads to allow for a future bus service, including retrofitting a bus gate, but not assume that there will be a bus service from the start.

3. To which part of the Southbourne Allocation Development Plan Document does this representation relate?

Southbourne Allocation DPD Main Document

4. Do you consider the Southbourne Allocation Development Plan Document is:

4. (1) Legally compliant Yes

4. (2) Sound Yes

5. Please give details of why you consider the Southbourne Allocation Development Plan Document to not be legally compliant or is unsound. Please be as precise as possible. If you wish to support the legal compliance or soundness of the Southbourne Allocation DPD, please also use this box to set out your comments.

Whilst we do not have soundness or legal compliance concerns with the Southbourne Allocation Development Plan Document, we have comments with regards to transport matters and matters on extra care housing.

Comments related to transport

Following the Reg 18 consultation WSCC have reviewed the evidence base and undertaken further discussions with the strategic site promoters. The County Council would like to update some areas of the DPD, clarifying some aspects of the site access arrangements for vehicular traffic and sustainable modes. Some further work is required by the strategic site promoters around the sustainable transport strategy. Therefore, our comments are not objections to the DPD, but suggestions on the need to refine some of the sustainable mitigation measures.

Vision

The proposed vision is in line with the relevant national and local policies. However, it currently misses a key opportunity to embed the vision-led approach to transport planning that is outlined in the accompanying Transport Assessment (TA). As currently worded, it seeks to maximise opportunities without indicating a minimum acceptable level for use of sustainable modes of transport. From a transport perspective, including a minimum mode share within the vision could act as a guiding light for the development against which future planning applications can be considered. It is suggested that in line with the accompanying Transport Assessment, a minimum sustainable transport (public transport & active travel) mode share for external trips of 32% is added to the vision. This relates to the analysis of vision-led trips in section 5.6 of the TA and the figures presented in table 5:12 - Mode split Comparison (Total External Trips) - of 18% Public Transport plus 14% active Travel mode shares.

Transport and Sustainable Travel Principles

Paragraph 5.26 - The intent within this paragraph is noted. However, the development will be adding traffic to Inlands Road as this will be a means of access to the site, Therefore, the opportunity for traffic to be reduced or redirected as implied within the current wording is unlikely to be possible. It is suggested that paragraph 5.26 should be reworded to encourage traffic reduction where possible and a comprehensive package of improvements that includes speed limit reductions alongside physical infrastructure to improve the comfort and safety of pedestrians and cyclists. The wording 'Relevant application must take the opportunity' also allows development to be taken forward in a piecemeal fashion alongside various applications, rather than as part of a comprehensive development of the site. This raise concerns as piecemeal development could result in difficulties securing the necessary infrastructure. it is suggested the paragraph should be reworded to help encourage comprehensive development of the site and required infrastructure delivery.

The last sentence which identifies opportunities to improve active travel links could be improved by including reference to the bus stops on the A259 served by the 700 bus service and also the Bourne Community College.

Paragraph 5.29 - This paragraph references a bus route/gate (which is also known as a 'modal filter'). There is currently a high-level of uncertainty over whether a bus service will route through the site. As such, the wording should be rephrased so as only to require the design of internal access roads to allow for a future bus service, including retrofitting a bus gate, but not assume that there will be a bus service from the start.

Comments related to extra care housing

Paragraphs 5.18 and 5.19 reference the CLP policy and older persons housing. In the WSCC Market Position Statements, it is noted that there is no need for net growth in supply of care home beds in the county, as several providers have developed new services and report a high volume of voids. However, the County Council is interested in developing Extra Care Housing schemes and would welcome conversations around this with future developers. Further information on WSCC's Market Positions Statements are available at: https://www.westsussexconnecttosupport.org/alt-home/market-position- statement-and-commissioning-strategy/

6. Please set out the modification(s) you consider necessary to make the Southbourne Allocation DPD legally compliant and sound, in respect of any legal compliance or soundness matters you have identified at 5 above. You will need to say why each modification will make the Southbourne Allocation DPD legally compliant or sound. It will be helpful if you are able to suggest revised wording of any policy or text. Please be as precise as possible.

WSCC have set out our recommended modifications in Section 5 of this form. To avoid doubt, there are no concerns with the overall soundness and legal compliance of the Development Plan Document.

For clarification, we also suggest making the following changes to Appendix A - Infrastructure Delivery Plan Update:

1. In the justification/rationale column under Inlands Road Level Crossing, add "Also provide improved pedestrian facility over the crossing, likely to require minor widening of the crossing."

2. High quality walking and cycling route to A259 bus stops

In justification/rationale column, add "Provide safe, comfortable and convenient walking and cycling route from the development along Inlands Road to the A259 to access the bus stops. This should include footway improvements to provide a continuous route and traffic management measures to improve conditions for cyclists which may include review and reduction of speed limits.". Phasing "To coincide with a construction of access to the southern and eastern parcels of the development" As this scheme does not form part of the County Council's plans for investment in the highway network and will be essential to deliver the proposed vision, the delivery lead for this infrastructure should be the developer.

3. As an additional row item, add 'High Quality walking and cycling route to Southbourne Station and Stein Road'.

In justification/rationale column "Provide safe comfortable and convenient route from the development to Stein Road linking to the rail station and providing crossing facilities to improve safe access towards Bourne Community College, the leisure centre and the convenience store. This is likely to include measures to link to and enhance facilities at Cooks Lane to be provided by other development adjacent to that road." As this scheme does not form part of the County Council's plans for investment in the highway network and will be essential to deliver the proposed vision, the delivery lead for this infrastructure should be the developer.

4. Further amendments to the IDP Update Table are detailed below:

S/N 1 - Scheme -Foot/cycle bridge over Railway
line (e.g. between Cooks Lane site and Priors Orchard)*. Suggested amendment - Change delivery lead to developer and acknowledge that the location
and delivery arrangements will be subject to land availability on both sides of the railway line.

S/N 2 - Scheme - Southbourne bus service
improvements/extension. Rationale: To integrate bus
services into the initial phases of development to help create strategic options for behavioural changes and mode choice.
Suggested amendment - As Stagecoach has indicated that it is unlikely to see a case for diverting the 700 service into the site, direct on-site public transport integration is not currently achievable. However, public transport access may still be supported through improvements to the existing services on the A259.
We suggest rewording the scheme as, ‘Increase 700 service frequency to 15 minutes on weekdays, and 15 minutes during weekends’.

7. If your representation is seeking a modification to the plan, do you consider it necessary to participate in examination hearing session(s)?

No, I do not

8. If you wish to participate in the hearing session(s), please outline why you consider this to be necessary:

Not Applicable

3. To which part of the Southbourne Allocation Development Plan Document does this representation relate?

Southbourne Allocation DPD Main Document

4. Do you consider the Southbourne Allocation Development Plan Document is:

4. (1) Legally compliant Yes

4. (2) Sound Yes

5. Please give details of why you consider the Southbourne Allocation Development Plan Document to not be legally compliant or is unsound. Please be as precise as possible. If you wish to support the legal compliance or soundness of the Southbourne Allocation DPD, please also use this box to set out your comments.

Whilst we do not have soundness or legal compliance concerns with the Southbourne Allocation Development Plan Document, we have comments with regards to transport matters and matters on extra care housing.

Comments related to transport

Following the Reg 18 consultation WSCC have reviewed the evidence base and undertaken further discussions with the strategic site promoters. The County Council would like to update some areas of the DPD, clarifying some aspects of the site access arrangements for vehicular traffic and sustainable modes. Some further work is required by the strategic site promoters around the sustainable transport strategy. Therefore, our comments are not objections to the DPD, but suggestions on the need to refine some of the sustainable mitigation measures.

Vision

The proposed vision is in line with the relevant national and local policies. However, it currently misses a key opportunity to embed the vision-led approach to transport planning that is outlined in the accompanying Transport Assessment (TA). As currently worded, it seeks to maximise opportunities without indicating a minimum acceptable level for use of sustainable modes of transport. From a transport perspective, including a minimum mode share within the vision could act as a guiding light for the development against which future planning applications can be considered. It is suggested that in line with the accompanying Transport Assessment, a minimum sustainable transport (public transport & active travel) mode share for external trips of 32% is added to the vision. This relates to the analysis of vision-led trips in section 5.6 of the TA and the figures presented in table 5:12 - Mode split Comparison (Total External Trips) - of 18% Public Transport plus 14% active Travel mode shares.

Transport and Sustainable Travel Principles

Paragraph 5.26 - The intent within this paragraph is noted. However, the development will be adding traffic to Inlands Road as this will be a means of access to the site, Therefore, the opportunity for traffic to be reduced or redirected as implied within the current wording is unlikely to be possible. It is suggested that paragraph 5.26 should be reworded to encourage traffic reduction where possible and a comprehensive package of improvements that includes speed limit reductions alongside physical infrastructure to improve the comfort and safety of pedestrians and cyclists. The wording 'Relevant application must take the opportunity' also allows development to be taken forward in a piecemeal fashion alongside various applications, rather than as part of a comprehensive development of the site. This raise concerns as piecemeal development could result in difficulties securing the necessary infrastructure. it is suggested the paragraph should be reworded to help encourage comprehensive development of the site and required infrastructure delivery.

The last sentence which identifies opportunities to improve active travel links could be improved by including reference to the bus stops on the A259 served by the 700 bus service and also the Bourne Community College.

Paragraph 5.29 - This paragraph references a bus route/gate (which is also known as a 'modal filter'). There is currently a high-level of uncertainty over whether a bus service will route through the site. As such, the wording should be rephrased so as only to require the design of internal access roads to allow for a future bus service, including retrofitting a bus gate, but not assume that there will be a bus service from the start.

Comments related to extra care housing

Paragraphs 5.18 and 5.19 reference the CLP policy and older persons housing. In the WSCC Market Position Statements, it is noted that there is no need for net growth in supply of care home beds in the county, as several providers have developed new services and report a high volume of voids. However, the County Council is interested in developing Extra Care Housing schemes and would welcome conversations around this with future developers. Further information on WSCC's Market Positions Statements are available at: https://www.westsussexconnecttosupport.org/alt-home/market-position- statement-and-commissioning-strategy/

6. Please set out the modification(s) you consider necessary to make the Southbourne Allocation DPD legally compliant and sound, in respect of any legal compliance or soundness matters you have identified at 5 above. You will need to say why each modification will make the Southbourne Allocation DPD legally compliant or sound. It will be helpful if you are able to suggest revised wording of any policy or text. Please be as precise as possible.

WSCC have set out our recommended modifications in Section 5 of this form. To avoid doubt, there are no concerns with the overall soundness and legal compliance of the Development Plan Document.

For clarification, we also suggest making the following changes to Appendix A - Infrastructure Delivery Plan Update:

1. In the justification/rationale column under Inlands Road Level Crossing, add "Also provide improved pedestrian facility over the crossing, likely to require minor widening of the crossing."

2. High quality walking and cycling route to A259 bus stops

In justification/rationale column, add "Provide safe, comfortable and convenient walking and cycling route from the development along Inlands Road to the A259 to access the bus stops. This should include footway improvements to provide a continuous route and traffic management measures to improve conditions for cyclists which may include review and reduction of speed limits.". Phasing "To coincide with a construction of access to the southern and eastern parcels of the development" As this scheme does not form part of the County Council's plans for investment in the highway network and will be essential to deliver the proposed vision, the delivery lead for this infrastructure should be the developer.

3. As an additional row item, add 'High Quality walking and cycling route to Southbourne Station and Stein Road'.

In justification/rationale column "Provide safe comfortable and convenient route from the development to Stein Road linking to the rail station and providing crossing facilities to improve safe access towards Bourne Community College, the leisure centre and the convenience store. This is likely to include measures to link to and enhance facilities at Cooks Lane to be provided by other development adjacent to that road." As this scheme does not form part of the County Council's plans for investment in the highway network and will be essential to deliver the proposed vision, the delivery lead for this infrastructure should be the developer.

4. Further amendments to the IDP Update Table are detailed below:

S/N 1 - Scheme -Foot/cycle bridge over Railway
line (e.g. between Cooks Lane site and Priors Orchard)*. Suggested amendment - Change delivery lead to developer and acknowledge that the location
and delivery arrangements will be subject to land availability on both sides of the railway line.

S/N 2 - Scheme - Southbourne bus service
improvements/extension. Rationale: To integrate bus
services into the initial phases of development to help create strategic options for behavioural changes and mode choice.
Suggested amendment - As Stagecoach has indicated that it is unlikely to see a case for diverting the 700 service into the site, direct on-site public transport integration is not currently achievable. However, public transport access may still be supported through improvements to the existing services on the A259.
We suggest rewording the scheme as, ‘Increase 700 service frequency to 15 minutes on weekdays, and 15 minutes during weekends’.

7. If your representation is seeking a modification to the plan, do you consider it necessary to participate in examination hearing session(s)?

No, I do not

8. If you wish to participate in the hearing session(s), please outline why you consider this to be necessary:

Not Applicable

3. To which part of the Southbourne Allocation Development Plan Document does this representation relate?

Southbourne Allocation DPD Main Document

4. Do you consider the Southbourne Allocation Development Plan Document is:

4. (1) Legally compliant Yes

4. (2) Sound Yes

5. Please give details of why you consider the Southbourne Allocation Development Plan Document to not be legally compliant or is unsound. Please be as precise as possible. If you wish to support the legal compliance or soundness of the Southbourne Allocation DPD, please also use this box to set out your comments.

Whilst we do not have soundness or legal compliance concerns with the Southbourne Allocation Development Plan Document, we have comments with regards to transport matters and matters on extra care housing.

Comments related to transport

Following the Reg 18 consultation WSCC have reviewed the evidence base and undertaken further discussions with the strategic site promoters. The County Council would like to update some areas of the DPD, clarifying some aspects of the site access arrangements for vehicular traffic and sustainable modes. Some further work is required by the strategic site promoters around the sustainable transport strategy. Therefore, our comments are not objections to the DPD, but suggestions on the need to refine some of the sustainable mitigation measures.

Vision

The proposed vision is in line with the relevant national and local policies. However, it currently misses a key opportunity to embed the vision-led approach to transport planning that is outlined in the accompanying Transport Assessment (TA). As currently worded, it seeks to maximise opportunities without indicating a minimum acceptable level for use of sustainable modes of transport. From a transport perspective, including a minimum mode share within the vision could act as a guiding light for the development against which future planning applications can be considered. It is suggested that in line with the accompanying Transport Assessment, a minimum sustainable transport (public transport & active travel) mode share for external trips of 32% is added to the vision. This relates to the analysis of vision-led trips in section 5.6 of the TA and the figures presented in table 5:12 - Mode split Comparison (Total External Trips) - of 18% Public Transport plus 14% active Travel mode shares.

Transport and Sustainable Travel Principles

Paragraph 5.26 - The intent within this paragraph is noted. However, the development will be adding traffic to Inlands Road as this will be a means of access to the site, Therefore, the opportunity for traffic to be reduced or redirected as implied within the current wording is unlikely to be possible. It is suggested that paragraph 5.26 should be reworded to encourage traffic reduction where possible and a comprehensive package of improvements that includes speed limit reductions alongside physical infrastructure to improve the comfort and safety of pedestrians and cyclists. The wording 'Relevant application must take the opportunity' also allows development to be taken forward in a piecemeal fashion alongside various applications, rather than as part of a comprehensive development of the site. This raise concerns as piecemeal development could result in difficulties securing the necessary infrastructure. it is suggested the paragraph should be reworded to help encourage comprehensive development of the site and required infrastructure delivery.

The last sentence which identifies opportunities to improve active travel links could be improved by including reference to the bus stops on the A259 served by the 700 bus service and also the Bourne Community College.

Paragraph 5.29 - This paragraph references a bus route/gate (which is also known as a 'modal filter'). There is currently a high-level of uncertainty over whether a bus service will route through the site. As such, the wording should be rephrased so as only to require the design of internal access roads to allow for a future bus service, including retrofitting a bus gate, but not assume that there will be a bus service from the start.

Comments related to extra care housing

Paragraphs 5.18 and 5.19 reference the CLP policy and older persons housing. In the WSCC Market Position Statements, it is noted that there is no need for net growth in supply of care home beds in the county, as several providers have developed new services and report a high volume of voids. However, the County Council is interested in developing Extra Care Housing schemes and would welcome conversations around this with future developers. Further information on WSCC's Market Positions Statements are available at: https://www.westsussexconnecttosupport.org/alt-home/market-position- statement-and-commissioning-strategy/

6. Please set out the modification(s) you consider necessary to make the Southbourne Allocation DPD legally compliant and sound, in respect of any legal compliance or soundness matters you have identified at 5 above. You will need to say why each modification will make the Southbourne Allocation DPD legally compliant or sound. It will be helpful if you are able to suggest revised wording of any policy or text. Please be as precise as possible.

WSCC have set out our recommended modifications in Section 5 of this form. To avoid doubt, there are no concerns with the overall soundness and legal compliance of the Development Plan Document.

For clarification, we also suggest making the following changes to Appendix A - Infrastructure Delivery Plan Update:

1. In the justification/rationale column under Inlands Road Level Crossing, add "Also provide improved pedestrian facility over the crossing, likely to require minor widening of the crossing."

2. High quality walking and cycling route to A259 bus stops

In justification/rationale column, add "Provide safe, comfortable and convenient walking and cycling route from the development along Inlands Road to the A259 to access the bus stops. This should include footway improvements to provide a continuous route and traffic management measures to improve conditions for cyclists which may include review and reduction of speed limits.". Phasing "To coincide with a construction of access to the southern and eastern parcels of the development" As this scheme does not form part of the County Council's plans for investment in the highway network and will be essential to deliver the proposed vision, the delivery lead for this infrastructure should be the developer.

3. As an additional row item, add 'High Quality walking and cycling route to Southbourne Station and Stein Road'.

In justification/rationale column "Provide safe comfortable and convenient route from the development to Stein Road linking to the rail station and providing crossing facilities to improve safe access towards Bourne Community College, the leisure centre and the convenience store. This is likely to include measures to link to and enhance facilities at Cooks Lane to be provided by other development adjacent to that road." As this scheme does not form part of the County Council's plans for investment in the highway network and will be essential to deliver the proposed vision, the delivery lead for this infrastructure should be the developer.

4. Further amendments to the IDP Update Table are detailed below:

S/N 1 - Scheme -Foot/cycle bridge over Railway
line (e.g. between Cooks Lane site and Priors Orchard)*. Suggested amendment - Change delivery lead to developer and acknowledge that the location
and delivery arrangements will be subject to land availability on both sides of the railway line.

S/N 2 - Scheme - Southbourne bus service
improvements/extension. Rationale: To integrate bus
services into the initial phases of development to help create strategic options for behavioural changes and mode choice.
Suggested amendment - As Stagecoach has indicated that it is unlikely to see a case for diverting the 700 service into the site, direct on-site public transport integration is not currently achievable. However, public transport access may still be supported through improvements to the existing services on the A259.
We suggest rewording the scheme as, ‘Increase 700 service frequency to 15 minutes on weekdays, and 15 minutes during weekends’.

7. If your representation is seeking a modification to the plan, do you consider it necessary to participate in examination hearing session(s)?

No, I do not

8. If you wish to participate in the hearing session(s), please outline why you consider this to be necessary:

Not Applicable

1. In the justification/rationale column under Inlands Road Level Crossing, add “Also provide improved pedestrian facility over the crossing, likely to require minor widening of the crossing.”

2. High quality walking and cycling route to A259 bus stops
In justification/rationale column, add “Provide safe, comfortable and convenient walking and cycling route from the development along Inlands Road to the A259 to access the bus stops. This should include footway improvements to provide a continuous route and traffic management measures to improve conditions for cyclists which may include review and reduction of speed limits.”. Phasing “To coincide with a construction of access to the southern and eastern parcels of the development” As this scheme does not form part of the County Council’s plans for investment in the highway network and will be essential to deliver the proposed vision, the delivery lead for this infrastructure should be the developer.

3. As an additional row item, add ‘High Quality walking and cycling route to Southbourne Station and Stein Road’.
In justification/rationale column “Provide safe comfortable and convenient route from the development to Stein Road linking to the rail station and providing crossing facilities to improve safe access towards Bourne Community College, the leisure centre and the convenience store. This is likely to include measures to link to and enhance facilities at Cooks Lane to be provided by other development adjacent to that road.” As this scheme does not form part of the County Council’s plans for investment in the
highway network and will be essential to deliver the proposed vision, the delivery lead for this infrastructure should be the developer.

4. Further amendments to the IDP Update Table are detailed below:
1 - Foot/cycle bridge over Railway line (e.g. between Cooks Lane site and Priors Orchard) - Suggested amendment - Change delivery lead to developer
and acknowledge that the location and delivery arrangements will be subject to land availability on both
sides of the railway line.
2. Southbourne bus service improvements/extension - Suggested amendment - As Stagecoach has indicated that it is unlikely to see a case for diverting the 700 service into the site, direct on-site public transport integration is not currently achievable. However, public transport access may still be supported through improvements to the existing services on the A259.
We suggest rewording the scheme as, ‘Increase 700 service frequency to 15 minutes on weekdays, and 15 minutes during weekends’.

3. To which part of the Southbourne Allocation Development Plan Document does this representation relate?

Southbourne Allocation DPD Main Document

4. Do you consider the Southbourne Allocation Development Plan Document is:

4. (1) Legally compliant Yes

4. (2) Sound Yes

5. Please give details of why you consider the Southbourne Allocation Development Plan Document to not be legally compliant or is unsound. Please be as precise as possible. If you wish to support the legal compliance or soundness of the Southbourne Allocation DPD, please also use this box to set out your comments.

Whilst we do not have soundness or legal compliance concerns with the Southbourne Allocation Development Plan Document, we have comments with regards to transport matters and matters on extra care housing.

Comments related to transport

Following the Reg 18 consultation WSCC have reviewed the evidence base and undertaken further discussions with the strategic site promoters. The County Council would like to update some areas of the DPD, clarifying some aspects of the site access arrangements for vehicular traffic and sustainable modes. Some further work is required by the strategic site promoters around the sustainable transport strategy. Therefore, our comments are not objections to the DPD, but suggestions on the need to refine some of the sustainable mitigation measures.

Vision

The proposed vision is in line with the relevant national and local policies. However, it currently misses a key opportunity to embed the vision-led approach to transport planning that is outlined in the accompanying Transport Assessment (TA). As currently worded, it seeks to maximise opportunities without indicating a minimum acceptable level for use of sustainable modes of transport. From a transport perspective, including a minimum mode share within the vision could act as a guiding light for the development against which future planning applications can be considered. It is suggested that in line with the accompanying Transport Assessment, a minimum sustainable transport (public transport & active travel) mode share for external trips of 32% is added to the vision. This relates to the analysis of vision-led trips in section 5.6 of the TA and the figures presented in table 5:12 - Mode split Comparison (Total External Trips) - of 18% Public Transport plus 14% active Travel mode shares.

Transport and Sustainable Travel Principles

Paragraph 5.26 - The intent within this paragraph is noted. However, the development will be adding traffic to Inlands Road as this will be a means of access to the site, Therefore, the opportunity for traffic to be reduced or redirected as implied within the current wording is unlikely to be possible. It is suggested that paragraph 5.26 should be reworded to encourage traffic reduction where possible and a comprehensive package of improvements that includes speed limit reductions alongside physical infrastructure to improve the comfort and safety of pedestrians and cyclists. The wording 'Relevant application must take the opportunity' also allows development to be taken forward in a piecemeal fashion alongside various applications, rather than as part of a comprehensive development of the site. This raise concerns as piecemeal development could result in difficulties securing the necessary infrastructure. it is suggested the paragraph should be reworded to help encourage comprehensive development of the site and required infrastructure delivery.

The last sentence which identifies opportunities to improve active travel links could be improved by including reference to the bus stops on the A259 served by the 700 bus service and also the Bourne Community College.

Paragraph 5.29 - This paragraph references a bus route/gate (which is also known as a 'modal filter'). There is currently a high-level of uncertainty over whether a bus service will route through the site. As such, the wording should be rephrased so as only to require the design of internal access roads to allow for a future bus service, including retrofitting a bus gate, but not assume that there will be a bus service from the start.

Comments related to extra care housing

Paragraphs 5.18 and 5.19 reference the CLP policy and older persons housing. In the WSCC Market Position Statements, it is noted that there is no need for net growth in supply of care home beds in the county, as several providers have developed new services and report a high volume of voids. However, the County Council is interested in developing Extra Care Housing schemes and would welcome conversations around this with future developers. Further information on WSCC's Market Positions Statements are available at: https://www.westsussexconnecttosupport.org/alt-home/market-position- statement-and-commissioning-strategy/

6. Please set out the modification(s) you consider necessary to make the Southbourne Allocation DPD legally compliant and sound, in respect of any legal compliance or soundness matters you have identified at 5 above. You will need to say why each modification will make the Southbourne Allocation DPD legally compliant or sound. It will be helpful if you are able to suggest revised wording of any policy or text. Please be as precise as possible.

WSCC have set out our recommended modifications in Section 5 of this form. To avoid doubt, there are no concerns with the overall soundness and legal compliance of the Development Plan Document.

For clarification, we also suggest making the following changes to Appendix A - Infrastructure Delivery Plan Update:

1. In the justification/rationale column under Inlands Road Level Crossing, add "Also provide improved pedestrian facility over the crossing, likely to require minor widening of the crossing."

2. High quality walking and cycling route to A259 bus stops

In justification/rationale column, add "Provide safe, comfortable and convenient walking and cycling route from the development along Inlands Road to the A259 to access the bus stops. This should include footway improvements to provide a continuous route and traffic management measures to improve conditions for cyclists which may include review and reduction of speed limits.". Phasing "To coincide with a construction of access to the southern and eastern parcels of the development" As this scheme does not form part of the County Council's plans for investment in the highway network and will be essential to deliver the proposed vision, the delivery lead for this infrastructure should be the developer.

3. As an additional row item, add 'High Quality walking and cycling route to Southbourne Station and Stein Road'.

In justification/rationale column "Provide safe comfortable and convenient route from the development to Stein Road linking to the rail station and providing crossing facilities to improve safe access towards Bourne Community College, the leisure centre and the convenience store. This is likely to include measures to link to and enhance facilities at Cooks Lane to be provided by other development adjacent to that road." As this scheme does not form part of the County Council's plans for investment in the highway network and will be essential to deliver the proposed vision, the delivery lead for this infrastructure should be the developer.

4. Further amendments to the IDP Update Table are detailed below:

S/N 1 - Scheme -Foot/cycle bridge over Railway
line (e.g. between Cooks Lane site and Priors Orchard)*. Suggested amendment - Change delivery lead to developer and acknowledge that the location
and delivery arrangements will be subject to land availability on both sides of the railway line.

S/N 2 - Scheme - Southbourne bus service
improvements/extension. Rationale: To integrate bus
services into the initial phases of development to help create strategic options for behavioural changes and mode choice.
Suggested amendment - As Stagecoach has indicated that it is unlikely to see a case for diverting the 700 service into the site, direct on-site public transport integration is not currently achievable. However, public transport access may still be supported through improvements to the existing services on the A259.
We suggest rewording the scheme as, ‘Increase 700 service frequency to 15 minutes on weekdays, and 15 minutes during weekends’.

7. If your representation is seeking a modification to the plan, do you consider it necessary to participate in examination hearing session(s)?

No, I do not

8. If you wish to participate in the hearing session(s), please outline why you consider this to be necessary:

Not Applicable