Southbourne Allocation Development Plan Document - Regulation 19 Consultation

The Commissioners considers that if the identified issues (set out in the wider representations) in the evidence base were to be addressed, to allow for full and accurate consideration of the land to the west of Southbourne as a reasonable alternative to the land to the east, the land to the west would be identified to the preferred option/the appropriate strategy for suitable, feasible and deliverable development at Southbourne.

Policy SA1 identifies land to the east of Southbourne (as shown in Figure 1 of the DPD) for development to accord with the requirements set out in Policy A13 of the Chichester Local Plan 2021-39. The Commissioners objects to Policy SA1 and therefore to the wider DPD. This objection is made on the basis that SA1 is not appropriately ‘justified’, as supported by a review of the evidence base and the issues set out in the wider representations. The Commissioners considers that if these issues in the evidence base were to be addressed, to allow for full and accurate consideration of the land to the west of Southbourne as a reasonable alternative to the land to the east, the land to the west would be identified to the preferred option/the appropriate strategy for suitable, feasible and deliverable development at Southbourne.

The Commissioners’ land to the west of Southbourne is a suitable and available for development in a logical and sustainable location, as is demonstrated in the enclosed Vision Document, prepared by Tor&Co. The Vision Document is informed by detailed technical work and sets out the potential for well designed, high quality residential-led development to form a sustainable extension that integrates with the existing settlement, to grow Southbourne in a comprehensive manner that supports a vibrant and sustainable community. The indicative Masterplan seeks to connect people with nature and features a network of inclusive and safe open spaces that serve as amenity space, movement corridors and support a diverse range of habitats and biodiversity; whilst ensuring that development would respond to the wider landscape setting. There is scope to deliver in excess of the housing requirement set out in Policy A13, including new homes of a range of type and tenure to meet local needs, including affordable housing. This would be alongside extensive public open space and community uses in a new local centre, which could include shops and a new primary school for the benefit of existing and future residents. The new homes and amenities would be well connected and linked to the existing settlement by a network of active travel routes, to support sustainable transport and encourage movement. The development would also be supported by a new multimodal bridge that addresses severance caused by the railway line.

It is considered that the relative performance of the western site is understated in the current assessment and that a more balanced interpretation of the evidence would recognise the potential performance of the land to the west.

The Commissioners does not consider that the reasonable alternative (land to the west) has been fully taken into account based on proportionate evidence and, therefore, the DPD is not considered to be justified (sound). This brings into question whether the DPD overall has been positively prepared and is consistent with achieving sustainable development, due to the limitations in the Assessment in terms of transport and highways detailed above and the importance of a robust long-term transport strategy in achieving sustainable development.

The comparative assessments that have been made between the land to the west and the land to the east and the conclusions reached within the CDC evidence base, including in relation to transport and sustainable travel, are not considered to be based on robust evidence.

In terms of provision of active travel connectivity, the Assessment Framework evidence base document scores the land to the west as ‘red’ and the land to the east as ‘green’; noting the quantum of points of possible connections. As set out in the Strategic Transport Note, prepared by Pell Frischmann (enclosed), The Commissioners considers that, whilst the number and location of connections to the existing active travel network is an appropriate starting point, the scoring should not be influenced primarily by the distribution of connection points – instead, there should be consideration of how effectively those connections relate to key destinations within the settlement. The Commissioners considers that in practice, the effectiveness of active travel networks is more closely influenced by the extent to which the route provides direct, legible and attractive connections to established facilities and services. In this respect the western site’s proximity to existing community infrastructure (including Bourne Community College and Leisure Centre) and potential to integrate with existing trip attractors and support shorter, localised journeys should be a relevant consideration, currently not explicitly reflected in the assessment. It is considered that the RAG rating applied to the land to the west in the Assessment Framework Document does not fully reflect the functional active travel benefits associated with its relationship to existing infrastructure.

In relation to the potential for a bridge crossing the railway for pedestrians and cyclists, both the land to the west and land to the east are scored as ‘green’. However, the Assessment Framework states that “currently it is understood that only a pedestrian bridge is likely on the western side” so there would be no improvement in cycle connectivity. In fact, the western bridge is proposed to be all modes (as detailed in evidence previously provided to CDC) and should be factored into an improvement in active travel/cycle connectivity.

It is also relevant that the western site is being promoted by the Commissioners with an intention for enhanced crossing provision, supported by land control arrangements to facilitate delivery, whereas we understand that delivery of a comparable bridge on the eastern side would remain dependent on third-party land assembly and agreement with Network Rail. The Commissioners’ appointed viability consultant, Savills, has confirmed (and previously provided evidence shared with CDC) that development to the west remains viable and deliverable when accounting for the cost of the bridge. The assessment of the relative performance of the options in terms of the opportunity to deliver pedestrian and cycle crossings over the railway line is necessarily based on what can be demonstrated at this stage, and is influenced by deliverability considerations and land ownership constraints, which will likely evolve over time, and as such the scoring should be seen as indicative rather than definitive in terms of long-term connectivity outcomes. The differing degrees of delivery certainty and the capacity for cycles are relevant considerations, that weigh in favour of the land to the west, and should be captured in the Assessment Framework scoring.
The proposal for a multimodal bridge is also relevant in terms of impact of development on the local road network. Both the land to the west and east are scored ‘red’. The Commissioners agrees that the considerations assessed (access arrangements and traffic distribution) are relevant but consider that the sensitivity of assessment to underlying assumptions should be recognised and interpreted with appropriate caution. In particular, the Commissioners is concerned that the relative performance of the western site in terms of traffic distribution may be understated where the assessment places greater weight on short-term operational differences rather than on longer-term network resilience and adaptability.

The assessment in terms of proximity to existing bus stops understates the longer-term public transport potential of the western site, as it is based on the current network and does not consider how bus services may evolve in relation to proposed development. In the Assessment Framework, both scenarios are scored ‘red’, however we note that paragraph 4.12.19 of the Sustainability Appraisal states that for Option 1 (west) approximately 50% of the proposed development would be within 400m of an existing bus stop, whereas this is 30% for Option 3 (east). There should accordingly be a distinction in the Assessment Framework. Similarly, the assessment in terms of access to the train station (which appropriately considers distance and access improvement opportunities) is based on current connectivity patterns rather than potential enhancements. Please refer to the appended Note for details.

The Commissioners considers that until the updated LGA has been reviewed, the DPD cannot be considered to be justified or sound. If the identified issues in the evidence base are addressed to allow for full and accurate consideration of the land to the west of Southbourne, as a reasonable alternative to the land to the east, it is considered that the land to the west would be identified as the preferred option, and a suitable, feasible and deliverable option for development and an appropriate strategy for development at Southbourne.

A review and note in response to the updated CDC Landscape Gap Assessment (LGA) has been prepared by Tor&Co and is enclosed.
In the Assessment Framework, the land to the west is scored ‘amber’ in relation to the retention of landscape gaps. Paragraph 4.11.10 of the Sustainability Appraisal states that Option 1 is “ranked least favourably because it largely falls within the identified landscape gap between Southbourne and Hermitage”, with no further explanation. However, at paragraph 4.11.5 it is noted that all options including the land to the east fall within an identified landscape gap.

It is considered that the updated LGA does not assess variations in the landscape and each parcel of the Landscape Gap/the differing contributions they make to maintaining the physical and perceived separation of Hermitage and Southbourne at an appropriately fine-grained level. The LGA does not demonstrate why all parts of the Landscape Gap are afforded the same level of importance in maintaining settlement separation, and most critically it does not identify which areas are fundamental to the continued integrity and function of the Gap or which make a more limited contribution.

Further, the LGA does not assess the implications of the currently pending planning application for residential development south of the railway line (ref.25/03010/OUTEIA) which the Commissioners acknowledge represent a potentially significant change to the spatial relationship between the settlements. The Assessment Framework document references the LGA prepared by Tor&Co and previously submitted by The Commissioners and acknowledges the conclusion that there would be no significant detrimental impact on the gap, and the argument that the remaining area to the south of the railway line would maintain sufficient separation. However, the Assessment Framework scoring then states that the pending planning application “could undermine that position somewhat”. This is seemingly the basis for the amber score, and it is concerning that there is no robust assessment of the implications of the pending planning application within the updated LGA or wider evidence base. A robust evidence base should assess the cumulative implications of both committed development and significant pending planning proposals in order to understand how the Landscape Gap would function under realistic future development scenarios.

On this basis, the Commissioners considers that the Council’s updated LGA does not provide sufficient detail or transparency to justify the conclusions reached in respect of the land to the west and the wider Landscape Gap. The Council should update the LGA further to robustly assess the implications of all relevant committed and proposed development; and evaluate the relative contribution of individual landscape parcels at a finer spatial scale and identify areas that are critical for maintaining settlement separation. This would enable robust assessment and consideration of the reasonable alternative (the land to the west) so that it can be fully taken into account based on proportionate evidence.

The Assessment Framework and HRA cannot be considered to be accurate and proportionately evidenced, and do not allow fair and reasonable assessment of the land to the west in terms of the capacity to mitigate/protect existing wildlife and biodiversity, and the DPD therefore cannot be considered to be justified and sound. The identified issues in the evidence base need to be addressed.

A review of these documents has been undertaken by Pell Frischmann and is enclosed.

The Assessment Framework appropriately acknowledges and scores the land to the west ‘green’ in respect of the delivery of relevant sections of the Green Ring; creation of SANG to mitigate impact on the Chichester Harbour SPA; and preservation of wildlife corridors. However, in terms of the capacity to protect and/or mitigate existing wildlife and biodiversity, the land to the west is given a red ‘very poor’ score, with the land to the east as red ‘poor’. The main consideration in this is the loss of land which has been identified as Brent Geese Secondary Support area, identified as ‘significant’ (though with a potential area of mitigation north of the A27) for the west and ‘some’ for the east. The Commissioners considers that the ‘very poor’ assessment (makes a significant negative contribution to the objective) is overstated, given that the detailed information prepared by Pell Frischmann and provided in support of the DPD process to date makes clear that the proposed approach to mitigation fully accords with the Solent Waders and Brent Goose Strategy.

As further detailed in the appended note, it is considered that the Assessment Framework does not fully take into account the evidence base when assessing the relatively ability of each option to meet the ecological objectives. It fails to consider the Local Nature Recovery Strategy; and to acknowledge the potential for significant impacts from the land tot to the east on functionally linked land for both Chichester and Langston Harbours SPA and the Singleton and Cocking Tunnels. The Framework overstates the difference between the two options in terms of protection/mitigation of existing wildlife and biodiversity. There are a number of conclusions within the HRA that are not sufficiently evidenced or justified, including the justification for no adverse effect on integrity for Chichester and Langstone Harbours SPA (through loss of functionally linked land), no likely significant effect on Singleton and Cocking Tunnels SAC (through impacts to functionally linked land) and the absence of consideration of surface water impacts. Overall, the Assessment Framework and HRA cannot be considered to be accurate and proportionately evidenced, and do not allow fair and reasonable assessment of the land to the west in terms of the capacity to mitigate/protect existing wildlife and biodiversity, and the DPD therefore cannot be considered to be justified and sound.

The SFRA, Sequential Test (June 2026) and Assessment Framework have been reviewed by Pell Frischmann, and the relevant Note is enclosed.

In respect of ‘Development Locations within Flood Zones’, the Assessment Framework scoring states that if a vehicular bridge over the railway were to be required for Scenario 1 “then the site would score poorly, as that would be a significant piece of infrastructure which would have to be provided in an area which is at risk of flooding”. Pell Frischmann does not consider that there is reasonable justification for suggesting that the site would score poorly due to the route of the proposed bridge. Pell Frischmann does not consider that the route of access through the surface water flood zone on the northern side of the railway is an insurmountable constraint, subject to the outcome of a site-specific FRA and a suitable drainage strategy. It is considered that any impact on surface water flood zone risk can be appropriately offset with compensation, and that embedded mitigation and surface water management measures across the site would lead to an overall reduced level of flood risk. The potential for appropriate mitigation should be recognised in paragraph 4.4.1 of the Sustainability Appraisal, which currently states “Option 1 is particularly constrained in the event of an all modes bridge being delivered as part of that option, as that would need to be located in a relatively large area of high risk surface water flooding” with no consideration of the potential for mitigation. This should be clarified in updated evidence base, as currently this part is not accurate or ‘justified’.

In other areas, it is considered that the Sequential Test Report and SFRA Level 2 accurately demonstrate that the development of the land to the west can be accommodated without giving rise to unacceptable flood risk. Both reports conclude that the identified flood risks are localised and can be effectively mitigated through good site design and drainage strategies, and do not present a constraint to development.
The evidence confirms that all development scenarios are suitable for development in accordance with national planning policy, with identified flood risks capable of being effectively managed through appropriate mitigation measures and therefore not representing a barrier to development.