SUBMISSION CORE STRATEGY

STATEMENT OF COMPLIANCE – CORE STRATEGY

(REGULATION 28 STATEMENT)

OCTOBER 2007

Contents

Page Introduction .

Consultation under Regulation 25 – Issues & Options

Appendix 1.1 List of stakeholders 6. Appendix 1.2 Consultation letter to stakeholders 30. Appendix 1.3 Web- site text 31. Appendix 1.4 Public exhibition sites 32. Appendix 1.5 Press release/ Splash FM consultation 33. Appendix 1.6 List of consultees 34. Appendix 1.7 Issues & Options Questionnaire 36. Appendix 1.8 Results of Issues & Options consultation 48. Appendix 1.9 Sustainability Appraisal Scoping report analysis 60.

Consultation under Regulation 26- Core strategy Preferred Options

Appendix 2.1 Press release/Vibe article/Website & Public Notice 64. Appendix 2.2 Consultation cover letter 69. Appendix 2.3 Open day consultation letter 71. Appendix 2.4 Consultation comments form 73. Appendix 2.5 List of consultees – statutory and general 78. Appendix 2.6 List of respondents to Core Strategy 100. Appendix 2.7 List of respondents for Sustainability Appraisal 107. Appendix 2.8 Consultation responses - Core Strategy 108. Appendix 2.9 Consultation responses – Sustainability Appraisal 289.

2 Introduction

This Statement of Compliance has been prepared in accordance with the Town and Country Planning (Local Development) () Regulations 2004 and Planning Policy Statement 12: Local Development Frameworks.

The Statement highlights the consultation and community involvement that Worthing Borough Council has undertaken while preparing the Core Strategy and associated documents, which is in accordance with Regulations 25 (Pre- submission consultation) and Regulation 26 (Pre-submission public participation) and the processes and procedures outlined in the Worthing Borough Council’s Submitted Statement of Community Involvement, which was submitted to the Secretary of State in October 2005 and formally adopted by Full Council 3rd October 2006.

Consultation under Regulation 25

Worthing Borough Council carried out a major consultation exercise under Regulation 25 on the Issues and Options document. The consultation ran from 28 November 2005 to 31 January 2006. Prior to the public consultation, input on Issues and Options were received from representatives of Worthing’s Local Strategic Partnership. The Issues and Options document was prepared in the autumn of 2005.

The Sustainability Appraisal Scoping Report was consulted on separately at the end of June 2005. The key consultation stakeholders were English Nature, Environment Agency, English Heritage and the Countryside Agency. Six responses were received and they can be viewed in Appendix 1.9

The Issues and Options documents were deposited for comment and observation at the following locations during office hours for the six week consultation period.

Planning Reception Main Library Main Reception Portland House Richmond Road Town Hall Richmond Road Worthing Chapel Road Worthing West . Worthing . West Sussex.

Goring Library Broadwater Library Durrington Library Mulberry Lane Dominion Road Salvington Road Worthing Worthing Worthing West Sussex West Sussex West Sussex

Findon Valley Library Lime Trees Avenue Worthing West Sussex.

3 The Worthing Borough Council’s website contained copies of the documents and further supplementary information. In addition, several staffed exhibition stands were set up at public sites throughout the Borough. At all of the above sites the public were encouraged to take copies of the documents and respond with their comments on a questionnaire. A list of the public sites is contained in Appendix 1.4

Officers attended meetings and gave presentations to the Local strategic Partnership, Transport Liaison Group. Planning Users Group, Private Landlord’s Forum and Worthing Borough Council Members

Hard copies of the documents were sent out to statutory consultees, key stakeholders, local interest groups, developers and residents groups. In total 74 individual responses were received from the stakeholders and the general public. An analysis of the responses can be seen in Appendix 1.8

Consultation under Regulation 26

As a result of the responses received from the public consultation on the Issues and Options the groundwork was prepared to formulate the Core Strategy Preferred Options document. Account was also taken of the Worthing Community Strategy, Government guidance, the West Sussex Structure Plan and the emerging South East Plan. A number of independent studies were also undertaken to provide a sound evidence base for the emerging policies set out in the Core Strategy Preferred Options.

The draft policies in the Preferred Options Core Strategy document were subject to a full sustainability appraisal. The results were documented in the Sustainability Appraisal document, which was produced in conjunction with the Preferred Options. Both documents were included in the public consultation period that ran from 25th September to 6th November 2006.

Notices and information about the documents were placed in the Worthing Herald and the Council’s newsletter – Vibe, which is distributed to all households in the Borough. The text can be viewed in Appendix 1.8

The documents were made public on the Council’s website www.Worthing.gov.uk, alongside more supporting text and information. The documents were also placed on deposit at;

Portland House Richmond Road Main Library Richmond Road Town Hall Chapel Road Goring Library Mulberry Lane Broadwater Library Dominion Road Durrington Library Salvington Road Findon Valley Library Lime Trees Avenue

Copies of the documents were sent to the specific consultation organisation alongside a comments form that could be used to make representation on any of

4 the policies and issues contained in the documents. Leaflets were distributed to all households in the Borough, ensuring that the communication process covered all sections of the community.

A dedicated consultation database called Limehouse was used to give the public and consultation bodies the opportunity to make recommendations online. The documents were also made available in CD format in order to make it easier for the public to make representations on specific areas.

A staffed mobile exhibition facility was used in the Town Centre on two weekends during the consultation period. This gave the public the opportunity to watch a DVD on the emerging planning system and talk to planning officers on any issues and thoughts that they had on what should happen in the town,

Presentations were given to Council Members and stakeholder groups to inform them of the major issues contained in the documents that would be important in planning terms over the next 15-20 years.

Planning officers organised an Open day on 25 October in Worthing Town Hall. All stakeholders and the public were given the opportunity to come into the Town Hall and inspect the information boards and the actual documents. The venue was staffed all day and everybody had the opportunity to discuss any issues with planning officers.

A total of 311 representations from individuals/organisations were received during the general consultation on the Preferred Policy Options Core Strategy. There were 18 representations on the Sustainability Appraisal. A summary of all the representations made and the responses to the issues raised are in Appendices 2.8 and 2.9

5 Appendix 1.1 List of Stakeholders for Key Issues and Options Consultation

Organisation Designation first name Surname Address1 Address2 Address3 PostCode Downview 1 Griffiths John Griffiths 1 High Beeches Road Worthing BN11 4QR

2 Bradley Peter Bradley Rock Place Farm Rock Road Washington RH20 3BQ Ability Housing Staines, 3 Association Steve Hurrell The Coach House Gresham Road Middlesex TW18 2AE Adur District 4 Council Planning Policy Colette Blackett Civic Centre Ham Road Shoreham BN43 6PR Adur, Arun & 5 Worthing PCT Farhang Tahzib 1 The Causeway Goring by Sea Worthing BN12 6BT Adur, Arun & Asst Director of 6 Worthing PCT Public Health Catherine Scott The Causeway Goring-by-Sea Worthing BN12 6BT

7 Affinity Paul Castle 51 Fishbourne Road West Sussex PO19 3HZ Alliance Environmental Wharf House, Wharf 8 Planning Christian Halliday Road Guidlford Surrey GU1 4RP Amberley Parish Water Lane, Pulborough, 9 Council Parish Clerk C Whittington Leather Bottle Cottage Storrington West Sussex RH20 3NN Parish Clerk to the Angmering, West 10 Council Council Ray Huskisson The Corner House The Square Sussex BN16 4EA Clerk of Appledram Parish Appledram Donnington, 11 Council Parish Meeting Saskia Heasman 14 Waterside Drive Chichester West Sussex PO19 2RN Ardington Hotel, Steyne 12 Ardington Hotel Owner Richard Margaroli Gardens Worthing West Sussex 13 Council Paula Welland Maltravers Road BN17 5LF

6 Arun District Head of Planning Maltravers 14 Council Services Karen Dower Arun Civic Centre Road Littlehampton BN17 5LF

Ashington Parish Road, Pulborough, 15 Council Parish Clerk K Dare Honeysuckle House Ashington West Sussex RH20 3JR Ashurst Parish 16 Council Parish Clerk H Hoxby 4 Shooting Field Steyning West Sussex BN44 3RQ B & W Facilities 17 Loudspeaker Manager Tim Hill Dale Road Worthing West Sussex BN11 2RX Clerk of Parish Barlavington Sutton, 18 Council Parish Council Lucy Wentworth 10 Greenfield Pulborough West Sussex RH20 1PP 27-29 Barton Willmore Glasshouse 19 Partnership N J Bather 6th Floor, Venture House Street London W1R 6BW Regional Planning 20 Bellway Estates Manager John Brindley Bellway House London Road Merstham RH1 3YU Parish Clerk of Parish , 21 Council Council L M Grocott 23 West Meade Liphook Hampshire GU30 7NB Chairman of Parish Bignor Parish Bignor, 22 Council Meeting T Tupper Manor Farm Pulborough West Sussex

Billingshurst Parish Council Office, The Village Hall, Billingshurst, 23 Council Parish Clerk E. A. Berry Billingshurst Roman Way West Sussex RH14 9QW

Birdham Parish Clerk of Donnington, 24 Council Parish Council Saskia Heasman 14 Waterside Drive Chichester West Sussex PO19 2RN Downlands Business 25 Boots The Chemist Veronica Lee Park Lyons Way Worthing BN14 9LA

7 Parish Clerk of Bosham 26 Council Parish Council D E Borsberry 42 Newport Drive Chichester West Sussex PO19 3QQ North Ash South East Road, New Ash 27 Bovis Homes Region The Manor House Green Longfield, Kent DA3 8HQ Clerk of Parish Boxgrove Parish 28 Council Council R J Martin 7 Boleyn Drive West Sussex PO21 3LG Unit 17, Willowbrook 29 Bradley Glass Ltd Director Robert Ball Road Worthing West Sussex BN14 8NA Bramber Parish Briarbear, Lower Station 30 Council Parish Clerk A Hyde Road Henfield West Sussex BN5 9UR Brighton & Hove 31 Council Planning Policy Liz Hobden Kings House Grand Avenue BN3 2LS Planning 32 British Gas Plc Manager P Sheppard Aviary Court Wade Road RG24 8GZ Acting County British Horse Bridleways 33 Society Officer Patricia Butcher 14 Benjamin Road Maidenbower Crawley RH10 7QY

British Rail British Rail Estate 34 Property Board Manager 1 Eversholt Street NW1 2DD British Telecommunication 35 s Project Manager N D Abbott Chapman Warren 3 Grosvenor St W1X 9FA Broadbridge Heath 36 Parish Council Parish Clerk T Hooker 2 School Close Horsham West Sussex RH12 4UA Clerk of Bury Kesters House, The Bury, Nr 37 Bury Parish Council Parish Council Alison Miller Street Pulborough West Sussex RH20 1PA Planning Co- General Aviation 66 College 38 C/O Bloomfields Ordinator A P Bloomfield Awareness Council Road Maidstone, Kent ME15 6SJ

8 Waterside House, 39 Cable & Wireless David Price Post Point 14 Waterside Park Longshot Lane, RG12 1XL Campaign for Real 40 Ale Chief Executive Mike Benner 230 Hatfield Road St Albans Herts AL1 4LW Campaign to Protect Rural Worthing, West 41 England (Sussex) Chair Kathleen Worvell 5 Grange Close Sussex BN12 5LR

Planning Cedar Court, 221 Hagley Halesowen, West 42 Castlemore Manager Matthew Parry Road Hayley Green Midlands B63 1ED

43 CDHA Project Manager Colin Chambers 113/119 Davigdor Road Hove East Sussex BN3 1RE

44 Cellnet P Foster 1 Brunel Way SL1 1XL Central Worting Residents 45 Association Chairman V Lilley 6 Wenban Road Worthing West Sussex

46 Chancellors M Chyrstal 45 High Street Odiham Hook RG29 1LF Head of Environment & 47 Council Housing Keith Morgan East Pallant House Chichester PO19 1TY

Chidham Parish Clerk of Chidham 48 Council Parish Council B W Mann 107 New Brighton Road Emsworth Hants PO10 7QS Cinema Theatre Chairman of CTA 49 Association Casework Richard Gray 45 Arnold Road Bow London E3 4NU

Clapham Parish Clerk of Clapham 50 Council Parish Council Caroline Tomkins 7 Woodland Close Clapham West Sussex BN13 3XR

9 Broadwater 51 Cluttons S J Melligan 1 Eastwood Court Road Romsey SO51 8JJ

Cocking Parish Clerk of Cocking Cocking, 52 Council Parish Council G Miles 41 The Croft West Sussex GU29 0HQ

Coldwaltham London Road, Pulborough, 53 Parish Council Parish Clerk A McSherry 6 Chapel Close Watersfield West Sussex RH20 1SA Colgate Parish 54 Council Parish Clerk E M Dunsbee 11 Chennells Way Horsham West Sussex RH12 5TW 201-211 Commission for Borough High 55 Racial Equality St Dunstan's House Street SE1 1GZ

56 Compass Travel Faraday Close Worthing West Sussex BN13 3RB Component Units 4 & 5 Teville 57 Moulders Ray Harrison Industrials Dominion Way Worthing BN14 8NA

Compton Parish Clerk of Compton Waterlooville, 58 Council Parish Council Tracy Predeth 6 Morelands Road Purbrook Hants PO7 5PT 41-45 Connex South Blackfriars 59 Central Friars Bridge Court Road SE1 8PG Coombes Parish Coombes, 60 Meeting J Passmore Church Farm Lancing West Sussex BN15 0RS Countryside South East South East Regional 61 Agency Region Office 19 Dacre Street SW1H 0DH Countryside South East 20th Floor, Portland 62 Agency Regional Office House Stag Place London SW1E 5RS Cowfold Parish Cowfold, 63 Council Parish Clerk J Wright 117 Acorn Avenue Horsham West Sussex RH13 8RT CPRE (Sussex 64 Branch) Kathleen Worvell 5 Grange Close Ferring West Sussex BN12 5LR

10 Director of Crawley Borough Environment & 65 Council Housing Jim Redwood Town Hall The Boulevard Crawley RH10 1UZ Cushman & Wakefield (Healey 66 & Baker) Partner M Crook 43/45 Portman Square London W1A 3BG

David Wilson Land & Planning Wilson House, North North Heath 67 Homes South East Manager D Banfield Heath Ind. Est Lane Horsham RH12 5QE

68 Dialogue Sebastian Hanley 136-148 Tooley Street London SE1 2TU Clerk of Donnington Parish Donnington 69 Council Parish Council A D Pearce 25 Barker Close Chichester West Sussex PO18 8BJ

Duncton Parish Clerk of 70 Council Parish Council R J Martin 7 Boleyn Drive Pagham West Sussex PO20 3LG

Earnley Parish Clerk of Thorncraft, Piggery Hall 71 Council Parish Council S Dobbin Lane West Sussex PO20 8PZ Chairman of Parish Eartham Parish Eartham, 72 Meeting Meeting Angela Hobson The Old Vicarage Chichester West Sussex PO18 0LP Clerk of Parish Easebourne Ashfield Cottage, 1 73 Council Parish Counci; Carole Allan Ashfield Close Midhurst West Sussex GU29 9RP Clerk of East East Dean Parish Dean Parish East Dean, 74 Council Council K M Barrett 8 Droke Lane Cottages Chichester West Sussex PO18 0JH Clerk of East Lavington Parish Mansion House, Seaford Lavington Park, 75 Parish Council Council Kate Bain College West Sussex GU28 0NB

11 East Wittering and and Bracklesham East Wittering, 76 Bracklesham Parish Council J Griffith 1a New Parade Chichester West Sussex PO20 8EA East Worthing 77 Action Group A Gregg 22 Archibald Road Worthing West Sussex BN11 2SL

Ebernoe Parish Clerk of Angel Street, 78 Council Parish Council R A F Ford Arnops Leith Petworth West Sussex GU28 0BG Commercial Strategy 79 EDF Energy Manager J Park Wealden House Lewes Road East Grinstead RH19 3TB Clerk of Elsted and and Treyford Milland, 80 Parish Council Parish Council L M Grocott 23 West Meade Liphook Hants GU30 7NB 195-205 High 81 English Heritage S Williams Eastgate Court Street GU1 3EH 195-205 High 82 English Heritage Regional Planner S Williams Eastgate Court Street GU1 3EH English Nature Sussex & Surrey 83 Team Team Manager Chris Edwards Phoenix House 33 North Street Lewes BN7 2PH Environment Planning Liaison Little High 84 Agency officer Emma Winchester Saxon House Street Worthing BN11 1DH Environment Planning Liaison Guildbourne 85 Agency officer Erica Gray Southern Regional Office House Chatsworth Road BN11 1LD Environment Business Agency (Sussex Services Little High 86 Office) Manager Katrina Rankin Saxon House Street Worthing BN11 1DH Federation of Small 87 Businesses Roger Foregard 10 Freshfields Drive Lancing BN15 9LN

12 Federation of Small Businesses 88 (Sussex) Elizabeth Frances Greyfriars Farm Greyfriars Lane Storrington RH20 4HE Clerk of Fernhusrt Parish Parish Parish Council Office, Glebe Road, Haslemere, 89 Council Council David Bleach Village Hall Fernhurst Surrey GU27 3EH Ferring Parish Clerk of Ferring Ferring, 90 Council Parish Council R W Frost 1 Elm Park Worthing West Sussex BN12 5RN Findon Parish Clerk of Findon 91 Council Parish Council M S Bland 4 Steep Lane Findon West Sussex BN14 0UF Clerk of Fishbourne Parish Fishbourne Fishbourne, 92 Council Parish Council G J Tipper 4 Mill Close Chichester West Sussex PO19 3JW Clerk of Parish Fittleworth Parish Dyers Cottage, Little Fittleworth, 93 Council Council Peter Henderson Bognor Pulborough West Sussex RH20 1JT Clerk of Parish Funtington Parish 94 Council Council B W Mann 107 New Brighton Road Emsworth Hampshire PO10 7QS 1 Walnut Tree 95 GOSE John Crow Bridge House Close Guidlford SEWS Planning 1 Walnut Tree 96 GOSE Team David Paine Bridge House Close GU1 4GA SEWS Planning 1 Walnut Tree 97 GOSE Team Phillipa Sambrook Bridge House Close GU1 4GA

Graffham Parish Clerk of Bridge House, Severals Bepton, 98 Council Parish Council Richard J Barker Road Midhurst West Sussex GU29 0LR North Street, 99 Guildcare Methold House Worthing West Sussex BN11 1DU

100 Guinness Trust Regional Director Cath Cain 3rd Floor Beulah Court Albert Road Horley, Surry RH6 7HP

13 Parish Clerk of Harting 101 Council Parish Council Sadie Friend 3 Hanger Way Petersfield Hampshire GU31 4QE Henfield Parish High Street, 102 Council Parish Clerk P Hill Henfield Village Hall Henfield West Sussex BN5 9DB

Heyshott Parish Clerk of Heyshott, 103 Council Parish Council P M Hadley Thicketts Midhurst West Sussex GU29 0DL High Salvington Residents 104 Association P Povey 26 Furze Road Worthing West Sussex BN13 3BH Highdown Copse Residents West Worthing, West 105 Association John Fox 5 Laurel Close Durrington Sussex BN13 3PY Wing 1B, Federated 106 Highways Agency Network Manager Peter Minshull House London Road Dorking RH4 1SZ Federated 107 Highways Agency PPD Team 4th Floor, Wing C House London Road RH4 1SZ 54 Queen 108 Hillreed Homes Alistair Hume Hillreed House Street Horsham RH13 5AD

Regional Home Builders Planner, Southampton, 109 Federation Southern Region Pete Errington 4 Orchards Way Highfield Hants SO17 1RD Horsham District Deputy Director 110 Council of Planning Paul Rowley Park North North Street Horsham RH12 1RL

Hunston Parish Clerk of Hunston 111 Council Parish Council Carol Smith 6 Locksash Close West Wittering Chichester PO20 8QP Hyde 112 Housing/CDHA John Morris 113-119 Davigdor Road Hove East Sussex BN3 1RE Environmental 113 Hyder Consulting Officer Emily Low 29 Bressenden Place London SW1E 5DZ

14 Ilex Conservation 114 Group Tanner 5 Laburnam Close Ferring Worthing BN12 5EJ Itchingfield Parish Barnes Green, 115 Council Parish Clerk J Critchley 33 Smugglers Way Horsham West Sussex RH13 0PP

116 ITPS Potts Two Mile House Tow Mile Ash Horsham RH13 7LA Downlands Business 117 J Sainburys PLC Paul Stefanski Park Lyons Way Worthing BN14 9LA

Durrington, 118 John Ashworth C/O Tesco New Road Worthing BN13 3PB 119 John Goldspink Co-op Superstore Newland Street Worthing BN11 1JU

120 Jones Day Angela Turner 21 Tudor Street London EC4Y 0DJ Kelsey Housing 2 Perry Hall 121 Association Barbara Fendt Kelsey House Road Orpington, Kent BR6 0JJ

Kirdford Parish Clerk of Kirdford, 122 Council Parish Council Jane Kirk Butts Cottage Billingshurst West Sussex RH14 0ND Lancing Parish South Street, 123 Council Parish Clerk R J Wickens esq. The Parish Hall Lancing West Sussex BN15 8AJ Parish Clerk of Lavant Graffham, 124 Council Parish Council E C Austin 2 Kelsey's Petworth West Sussex GU28 0QD [email protected]. Leigh House, 147 Leigh 125 Levvel uk Liz Weaver Road Wimbourne Dorset BH21 2AD Chairman of Parish Lynch Parish Hollycombe, 126 Meeting Meeting J J Willings Chimneys Liphook Hampshire GU30 7LR

15 Clerk of Fernhurst, Parish Lynchmere Village Hall, Haslemere, 127 Council Parish Council David Bleach c/o Parish Council Office Glebe Road Surrey GU27 3EH Clerk of Parish Lodsworth Parish Midhurst, West 128 Council Council Carol South New Pond Farm Pitsham Lane Sussex GU29 9RA Lower Beeding 129 Parish Council Parish Clerk P Brown 1 Patchings Horsham West Sussex RH13 5HJ

Loxwood Parish Clerk of Billingshurst, 130 Council Parish Council Peter Evans 12 Weald Court Station Road West Sussex RH14 9RS Clerk of Parish Lurgashall Parish Windfall Wood Haslemere, 131 Council Council P Szell Crofts Folly Common Surrey GU27 3BX Planning Malcolm Judd & Research 132 Partners manager F Wise 70 High Street Chislehurst BR7 5AQ Chairman of Marden Parish Marden Parish , 133 Meeting Meeting B Clarke The Old Rectory Chichester West Sussex PO18 9JE

134 Martlet Homes Housing Director Heather Grant Martlet House Southern Gate Chichester PO19 8SE Masjed Assalam Islamic Cultural 135 Centre Ali Abdul Rahman Ivy Arch Road Worthing West Sussex BN14 8BX Internal Communications 136 MGM Assurance Manager Julian Simpson MGM house Heene Road Worthing BN11 2DY Michael Cook 11 Goring 137 Associates Ltd Chairman T Clark Brooklyn Chambers Road Worthing BN12 4AP

16 Mid Sussex District 138 Council Planning Policy Judith Hewitt Oaklands Oaklands Road Haywards Heath RH16 1SS Milland Parish Clerk of Milland Milland, 139 Council Parish Council L Grocott 23 West Meade Liphook Hampshire GU30 7NB

National Grid Co 140 Plc Supervisor Eileen Denyer PO Box 7324 Coleshill B46 1AR Land & National Grid Development NGT House, Warwick 141 Transco Manager Technology Park Gallows Hill CV34 6DA National Trust 142 (Southern Region) Jane Arnott Polesden Lacey Dorking RH5 6BD 1 Eversholt 143 Network Rail Town Planner Chris Price The Podium Road NW1 2DN

North Horsham Horsham, West 144 Parish Council Parish Clerk T O'Hara Roffey Millennium Hall Crawley Road Sussex RH12 4DT Clerk of North Munham Parish East Wittering, 145 Parish Council Council Louise Chater 1 Charlmead Chichester West Sussex PO20 8DN Durrington 146 Northbrook College Campus David Percival Littlehampton Road Worthing West Sussex BN12 6NU Clerk of Parish Northchapel Petworth Road, Godalming, 147 Council Parish Council Sarah Colville Broadlane End Cottage Chiddingfold Surrey GU8 4SU Nuthurst Parish 148 Council Parish Clerk T Rowe 24 Heron Way Horsham West Sussex RH13 6DQ Orange Personal 70/72 149 Communications Aylesford House Clarendon CV32 4PE Clayton Lane, Oving Parish Clerk of Oving Bracklesham Chichester, West 150 Council Parish Council R Parsons Primrose Cottage Bay Sussex PO20 8JQ

17 Executive 151 Parexel MMS Director Terence Brightmore Wicker House High Street Worthing BN11 1DJ Parham Parish Rackam, 152 Council Parish Clerk G Rowe Pine Cottage Pulborough West Sussex RH20 2EU Parish Coldharbour 153 Council Clerk R Metcalfe Green Oak House Lane Patching BN13 3XE

Patching Parish Clerk of Patching Coldharbour Patching, West 154 Council Parish Council R Metcalfe Green Oak House Lane Sussex BN13 3XE Downlands 155 Paul Stefanski C/O Sainbury's Business Park Worthing BN14 9LA

156 Peacock & Smith Suite 2a, Josephs Well Hanover Walk Leeds LS3 1AB

Petworth Parish Clerk of Petworth 157 Council Parish Council Jean Huggett 44 Orchard Close Petworth West Sussex GU28 0SA

Clerk of Plaistow Plaistow and and Ifold Parish Kirdford, 158 Parish Council Council S Kemp 28 Cornwood Bilingshurst West Sussex RH14 0NP

159 Planning Agent Richard Maile 72 Portland Road Worthing West Sussex BN11 1QG Planning Bureau Planning 26-32 Oxford 160 Ltd Assistant N Pugsley Homelife House Road Bournemouth BH8 8EZ Property Westwood 161 Powergen Manager J Whale Westwood Way Business Park CV4 8LG

Pulborough Parish Pulborough Swan View, 162 Council Parish Clerk S White Parish Council Office Social Centre Pulborough RH20 2BF

18 Head of Logistics 163 QS Plc & Distribution Jane Lovatt Goring Business Park Woods Way Goring by Sea BN12 4QY

164 Raglan HA John Walker 68 Victoria Road Horley West Sussex RH6 7PZ

165 Railtrack plc Town Planner N Banks Railtrack House Euston Square NW1 2EE 1 Maddox 166 Rapleys LLP Planner Aidan Thatcher Maddox House Street London W1S 2PZ Redrow Homes Redrow House, Faraday 167 Southern Ltd John Tarvit Office Park Faraday Road Basingstoke RG24 8QQ

168 Resident Shafique Uddin 42 Goring Road Worthing West Sussex BN12 4AD

169 Resident Guinaz Khan 21 Lennox Road Worthing West Sussex BN11 1DD 170 Resident Andrew Lamb 171 Resident David Parker 14 Balcombe Court West parade Worthing BN11 3PL

172 Resident Jim Baker 5 King Edward Avenue Worthing West Sussex BN14 8DB

173 Resident John Shaddick 80 Offington Lane Worthing West Sussex BN14 9RS

174 Resident M Jupp 34 Adur Avenue Worthing West Sussex BN13 3LF

175 Resident Gareth Jones 51 Reigate Road Worthing West Sussex BN11 5NE

176 Resident C K Dhajan 41 Wenban Road Worthing West Sussex BN11 1HY

177 Roffey Homes 15a Buckingham Road Worthing West Sussex BN11 1TH Parish Clerk of Rogate 178 Council Parish Council Annabel Beecheno Durford Mill Cottage Rogate Road Petersfield, Hants GU31 5AZ

19 179 Rose Willmot Y.C Team Leader Rick Matthews Littlehampton Road Durrington West Sussex Royal Comm. on Historic Monuments of 24 Brooklands 180 England Recording Section Avenue CB2 2BU Planning & 90 Chancery 181 Royal Mail Group development Katy Walker C/O ATISREAL Lane London WC2A 1EU

Rudgwick Parish Horsham, West 182 Council Parish Clerk B J Kenward 6 Pathfield Road Rudgwick Sussex RH12 3HS Rusper Parish Rusper, 183 Council Parish Clerk C L Sowden 5 Cooks Mead Horsham West Sussex RH12 4PU Environment & College Milton 184 Scottish Power Planning Group 45-47 Hawbank Road North G74 5EG SE England 1 Walnut Tree 185 Regional Assembly Director P Bevan Bridge House Close GU1 4GA Second Site Planning 186 Property Manager P Sheppard Aviary Court Wade Road Basingstoke RG24 8GZ

187 Seeboard plc J Park Asset Management Russell Way RH10 1UL Executive Director of SEEDA Development & 188 Headquarters Infrastructure Paul Hudson Cross Lanes GU1 1YA Director of Transport & 189 SEERA Planning Mike Gwillam Berkley House Cross Lanes GU1 1UN Development 190 Servite Houses Manager Gareth Davies Toddington Lane Littlehampton West Sussex BN17 7PP Shermanbury 3 Barrack Cottages, Shermanbury, 191 Parish Council Parish Clerk L Kyle Brighton Road, Horsham West Sussex RH13 8HQ

20 Shipley Parish Rosemary Cottage, Shipley, 192 Council Parish Clerk J Nunn Dragons Lane Horsham West Sussex RH13 8GD Showmens Guild of 193 GB C P Hennigan Clerk of Parish Sidlesham Parish Sidlesham, 194 Council Council John Paul The Cottage, Mill Lane Chichester West Sussex PO20 7LU

Singleton Parish Clerk of Singleton Pagham, 195 Council Parish Council Jenny Martin 7 Boleyn Drive West Sussex PO21 3LG Slinford Parish 196 Council Parish Clerk B Turner PO Box 360 Horsham West Sussex RH13 5GW Smithkline Director & Vice 197 Beecham President L Scrannage Worthing West Sussex BN14 8QH Sompting Parish 198 Council V Cousins 33 The Ridings East Preston West Sussex BN16 2TW Sompting Parish 199 Council Parish Clerk Kate Rhodes 101 Aldsworth Avenue Goring by Sea West Sussex BN12 4UT South Broadwater Residents 200 Association B Tompsett 83 King Edward Avenue Worthing West Sussex BN14 8DQ

201 South East Water 3 Church Road Haywards Heath RH16 3NY

Clerk of Southbourne Park Road, Southbourne Southbourne The Parish Office, Community Southbourne, 202 Parish Council Parish Council L Tirebuck Barnes Wing College Emsworth PO10 8PJ

Pease Pottage, 203 Southern Horizon Amanda Green Unit 7, The Pavilions Brighton Road Crawley RH11 9BD

21 Southern Housing 204 Group Liz Hills 9 Denne Parade Horsham West Sussex RH12 1JW Development 205 Southern Water Control B Douglas Southern House Sparrowgrove OTTERBOURNE SO21 2SW Managing 206 Southern Water Director Stuart Derwent Southern House Yeoman Road Worthing BN13 3NX

Planning Otterbourne, 207 Southern Water Engineer R Douglas Southern House Sparrowgrove Hampshire SO21 2SW

Planning Worthing, West 208 Southern Water Manager C Kneale Southern House Yeoman Road Sussex BN13 3NX

Southwater Parish Church Lane, Horsham, West 209 Council Parish Clerk C Tobin The Council Office Southwater Sussex RH13 9BT Planning 210 Sport England Manager Mick Anson 51a Church Street Caversham RG4 8AX Stagecoach Managing 211 (South) Director A.W Dyer Bus Station Chichester West Sussex PO19 2DQ with Stedham with Iping Parish Mount Cross, Quags Minsted, 212 Parish Council Council Jane Crawford Corner Midhurst West Sussex GU29 0JH Managing 213 Steeles of Worthing Director Alan Steele Southdownview Way Worthing West Sussex BN14 8NL

Steyning Parish Steyning, West 214 Council Parish Clerk L Spiers The Steyning Centre Fletchers Croft Sussex BN44 3XZ Chairman of Parish Stopham Parish Stopham, 215 Meeting Meeting Brian Barttelot Stopham Park Pulborough West Sussex RH20 1EB

22 Storrington & Thakeham Sullington Parish Road, 216 Council Parish Clerk I Marshall Sullington Parish Hall Storrington West Sussex RH20 3PP Clerk of Stoughton Parish Stoughton Parish , 217 Council Council Marilyn Wright Whitegates Chichester West Sussex PO18 9EA Managing Director, Strategic Rail Strategic 218 Authority Planning Jim Steer 55 Victoria Street SW1H 0EU

219 Strutt & Parker C Noel 201 High Street Lewes BN7 2NR Surrey & Sussex 18-20 Massetts 220 SHA York House Road Horley RH6 7DE Surrey Sussex Strategic Health 18-20 Massetts 221 Authority York House Road Horley RH6 7DE Sussex Downs Conservation Victorian Barn, Victorian 222 Board Officer Martin Beaton Business Centre Ford Lane Ford, BN18 0EF Sussex Downs Victorian Conservation Sussex Downs Business 223 Board Officer Victoria Barn Centre Ford Lane BN18 0EF Policy & partnership 224 Sussex Enterprise Advisor Liz Cadman Greenacre Court Station Road Burgess Hill RH15 9DS Sussex Learning & 53 Queens 225 Skills Council Princes House Road Brighton BN1 3XB Sussex Ornithological 226 Society Hon.Recorder J A Hobson 23 Hillside Road Storrington RH20 3LZ 227 Chief Inspector Jason Taylor 21 Chatsworth Road Worthing BN11 1NA

23 Sussex Wildlife Conservation 228 Trust Officer Janyis Hyatt Woods Mill Henfield BN5 9SD Sutton Parish Clerk of Sutton Sutton, 229 Council Parish Council Lucy Wentworth 10 Greenfield Pulborough West Sussex RH20 1PP Clerk of Parish Tangmere Parish Tangmere, 230 Council Council Moya Monachan 9 Wyvern Close Chichester West Sussex PO20 2GQ Tetlow King 231 Planning Assistant Planner Tracy-Ann Scanlan 32 High Street West Malling Kent ME19 6QR Storrington Thakeham Parish The Thakeham Parish Road, Pulborough, 232 Council Parish Clerk J Denman Council Office Thakeham West Sussex RH13 0TR Construction & Thames Water Development 1 Kew Bridge 233 Utilities Ltd Dept Thames Water Road Brentoford TW8 0EF The Aspaleia Euro House, 3 Teville 234 Project David Cotterell Place Worthing West Sussex BN11 1UQ

235 The Elim Church Andrew Fadoju 50 Charmandean Road Worthing West Sussex BN14 9NA

The Environment 236 Agency Sussex Area Office Saxon House Little High Street BN11 1DH

The Planning Planning 26-32 Oxford Bournemouth, 237 Bureau Limited Technician Philip Thompson Homelife House Road Dorset BH8 8EZ Local Development The Planning Framework Temple Quay 2 The Square, 238 Inspectorate Division Jane Huntbach Rm 325, Eagle Wing House Temple Quay BS1 6PN The Property The Village Estate 239 Doctor C Ennis Agency Salvington Hill Worthing BN13 3BE

24 240 Theatres Trust The Director 22 Charing Cross Road London WC2 0QL

241 THT South Mick Sykes 61 Ship Street Brighton East Sussex BN1 1AE

Tillington Parish Clerk to Tillington 242 Council Parish Council Jean Huggett 42 Orchard Close Petworth West Sussex GU28 0SA Todd Miller 243 Thomas R Miller 17 Liverpool Gardens Worthing West Sussex BN11 1RY 244 Transco Asset Officer S Meredith South East LDZ 2 Leesons Hill BR5 2TN Trotton with Clerk of Trotten Chithurst Parish with Chithurst Chithurst, 245 Council Parish Council M O Bentall Copyhall Cottage Petersfield Hampshire GU31 5EY

Upper Beeding Hyde Street, Steyning, West 246 Parish Council Parish Clerk I Caygill Ladymeade Upper Beeding Sussex BN44 3TG Chairman of Parish Upwaltham Upwaltham, 247 Meeting Parish Meeting Susan Kearsey Upwaltham House Farm Petworth West Sussex GU28 0LX Warnham Parish Rose Cottage, 33 Ferring Ferring, 248 Council Parish Clerk G L Benham Street Worthing West Sussex BN12 5JN Lyndhurst 249 WASH Martin Pearson Worthing Hospital Road Worthing

Washington Parish Oakhurst, Harbolets West Pulborough, 250 Council Parish Clerk L Quirk Road Chiltington West Sussex RH20 2LG Church Street, West Chiltington West Pulborough, 251 Parish Council Parish Clerk T Thomas The Reading Room Chiltington West Sussex RH20 2JW Clerk of West West Dean Parish Dean Parish 252 Council Council P R Outen 132 West Dean Chichester West Sussex PO18 ORX

25 High Street, West Grinstead The Parish Office, Village Partridge Horsham, West 253 Parish Council Parish Clerk Sheppard Hall Green Sussex RH13 8HX Clerk of West Itchenor Parish Donnington, 254 Parish Council Council Saskia Heasman 14 Waterside Drive Chichester West Sussex PO19 8RN Clerk of West West West Lavington Lavington Parish Lavington, 255 Parish Council Council M Piggott 2 Pine Close Midhurst West Sussex GU29 0EW

West Sussex Head of Planning 256 County Council Services Chris Cousins The Grange Tower House Chichester PO19 1RH West Sussex Learning Liverpool 257 Partnership Patricia Tame Southfields House Gardens Worthing BN11 1RY No Chairman at 258 Parish Council present Clerk of West Middleton on West Wittering Wittering Parish Red House, 100 Sea, Bognor 259 Parish Council Council J Brown Middleton Road Regis West Sussex PO22 6DL Clerk of Westbourne Parish Westbourne Hermitage, 260 Council Parish Council J Graham 19 Mill End Emsworth Hampshire PO10 8BJ Westbury Homes Strategic Land Hook, 261 (Holdings) Ltd Manager Phil Hull Bartley House Station Road Hampshire. RG27 9PE Clerk of Westhampnett , 262 Parish Council Parish Council Kate Gill 78 Grafton Road Chichester West Sussex PO20 0JB Clerk of Wisborough Wisborough Green Parish Green, 263 Parish Council Council Louise Davies PO Box 255 Billingshurst West Sussex RH14 0WT

26 Wiston Parish Gordon- Chanctonbury Wiston, Steyning, 264 Council Parish Clerk A Johnson Wiston Estate Office, Ring Road West Sussex BN44 3EA

265 Women's Aid Monica Nabb PO Box 4127 Worthing West Sussex BN11 1AF

70/72 Leamington on 266 Wood Frampton J Bicknell Aylesford House Clarendon Spa CV32 4PE 70-72 Clarendon 267 Wood Frampton J Bicknell Aylesford House Street Leamington Spa CV32 4PE

Woodmancote Brighton Road, Henfield, West 268 Parish Council Parish Clerk C Warren Tithe Barn Woodmancote Sussex BN5 9ST Clerk of Parish Woolbeding Woolbeding, 269 Council Parish Council A Reynolds Bucksfield House Midhurst West Sussex GU29 0QB Workability West Dove Lodge, 49 Beach 270 Sussex Maxine Thomas Road Littlehampton West Sussex BN17 5JG Director of Worthing & Service Southlands NHS Development & Lyndhurst 271 Trust Strategy Martin Pearson Worrthing Hospital Road Worthing BN11 2DH Worthing 272 Astrological Society Curator G L Boots 101 Ardingly Drive Goring by Sea Worthing BN12 4TW Worthing Borough 273 Council Anne Barlow Town Hall Chapel Road Worthing Worthing Borough 274 Council Bob Smytherman Town Hall Chapel Road Worthing Worthing Branch 275 Disabilities Network Carol Gatford 54 Edmonton Road Durrington West Sussex BN13 2TB

27 Worthing Chamber of Trade and 276 Commerce T Skerratt 7 Richmond Road Worthing West Sussex BN11 1PN Worthing Churches 277 Homeless Tony Chasteauneuf 5 Byron Road Worthing Worthing Churches 278 Together Mike Tyler 39 Sea Lane Goring Worthing BN12 4QD Worthing Community Arts 279 Council Jo Hutchinson 9 Marine Close Worthing BN11 5DG Worthing Community C/O Servite 280 Partnership Housing Jane Claxton Town Hall Bognor Regis Worthing Council for Volautary 281 Service Julia Carrette Colonnade House Warwick Street Worthing BN11 3DH Worthing Council of Community 282 Associations Chair Ian Richardson 16 Ashwood Close Worthing BN11 2AF Colonnade House, 283 Worthing CVS Julia Carrette Warwick Street Worthing West Sussex BN11 3DH Worthing Homes 284 Limited Mary Evans Davison House North Street Worthing Worthing Society 285 for the Blind Frances Knight 75 Richmond Road Worthing West Sussex BN11 4AQ Worthing Town Town Centre 286 Centre Initiative Manager Sharon Clarke 7 Richmond Road Worthing West Sussex BN11 1PN WS Fire & Rescue 287 Service Roy Barraclough Fire Station Ardsheal Road Worthing

288 WSCC Martin Downy First Floor Durban House Bognor Regis

289 WSCC Mike Kendall Room 101 County Hall Chichester

28

29 Appendix 1.2 Consultation cover letter Issues and Options

Our Reference: CM/ CAH/ CSUDP Your Reference: Direct Line; (01903) 221358 2nd December 2005 Dear Sir/Madam

ISSUES AND OPTIONS – CORE STRATEGY AND UNLOCKING DEVELOPMENT POTENTIAL

As you will be aware, Worthing Borough Council is preparing a new Local Development Framework (LDF) which will guide the future development and planning of the Borough over the next decade.

The Issues and Options Paper is the next stage in the LDF process and represents the first opportunity to consult on the main issues facing the Borough. It sets out a range of options that need to be considered. This is not intended to be a comprehensive list but a starting point to generate discussion on what the preferred direction should be for the Core Strategy and Unlocking Development Potential documents.

Making your Comments

A questionnaire has been prepared to help you consider the issues and options set out in the consultation paper. The questions have been grouped under the same headings as the Issues and Options Paper. You may wish to complete all of the questionnaire or simply reply on those areas of particular interest to you.

Copies of the Issues and Options Paper and questionnaire can be obtained from the Strategic Housing and Planning Group, Worthing Borough Council, Portland House, Richmond Road, Worthing, West Sussex BN11 1LF or by telephoning 01903 221364. They can also be downloaded from the Worthing Borough Council Internet site at: http://www.worthing.gov.uk/A-ZofServices/ServicesN- Z/PolicyDevelopmentUnit/StrategicHousingandPlanning/

All completed questionnaires and comments should be forwarded no later than 5pm on 31 January 2006 to the Strategic Housing and Planning Group at the above address. Please note that representations cannot be treated as confidential as they will be made available for public viewing. If you feel your details are sensitive please ensure that when filling out the official representation form you only disclose details you are happy to be seen in the pubic realm.

For further information about the Issues and Options stage please contact the Strategic Housing & Planning Team at [email protected] or call (01903) 221364.

Yours faithfully,

Clare Mangan

Strategic Housing & Planning Manager

30 Appendix 1.3 Wording on WBC website: Issues & Options

Local Development Framework: Core Strategy and Unlocking Development Potential - Issues and Options.

One of the primary documents to be developed for the Local Development Framework is the Core Strategy and Unlocking Development Potential - Issues and Options This will contain an overall vision for the future development of the town and will cover a 10 year period 2008 - 2018. It will establish the overall approach Worthing Borough Council, working with its partners in the local and regional community, will use to realise this vision through guiding and enabling the future use and development of land and improving and protecting the town's environment and facilities.

The Unlocking Development Potential document will identify where development land opportunities exist and how their development will help address the main issues facing the Borough. The document will address site allocations and land supply issues for future housing and economic growth, together with town centre/seafront regeneration.

Worthing's residents are actively encouraged to look at the Issues and Options document and comment on whether they agree or disagree with them. They will also have the opportunity to identify any other issues and options that they feel are relevant.

A consultation period for the Issues and Options document will commence from 28 November until 31January. A questionnaire has been designed in order to allow residents to comment on any of the Issues and Options that the document contains.

31 Appendix 1.4 Public Exhibition sites calendar

Venue Attendees December 1 December 2 Sainsbury’s: Lyon’s KC/AM Farm 10-15 December 3 December 4 December 5 December 6 Tesco: Durrington KC/AM 10-15 December 7 December 8 December 9 Co-op: Teville Gate KC/AM 10-15 December 10 Guildbourne Centre LR/NK/AM 10-15 December 11 December 12 Aquarena KC/AM 16-19 December 13 Aquarena Morning (07.30-09.30) NK December 14 December 15 December 16 December 17 December 18 December 19 Worthing Leisure Centre LR/TW 18-20 December 20 Worthing Leisure Centre AM/LR 9-12 December 21 December 22 December 23

January 6 January 7 Guildbourne Centre CM/NK/TW 10-15 January 24 January 25 Gordon Room CM/NK 19.30 – 21.00 January 26 January 27 January 28

32 Appendix 1.5 Issues & Options Press release

PRESS RELEASE FROM WORTHING BOROUGH COUNCIL BOROUGH COUNCIL TO CONSULT ON FUTURE CHANGES TO PLANNING POLICY IN WORTHING

Worthing is working towards adopting a Local Development Framework (LDF) within the next three years. The LDF for the Borough will comprise a number of Local Development Documents that will establish the spatial strategies, taking into account the economic, social and environmental issues that will face the town.

One of the primary documents to be developed is the Core Strategy and Unlocking Development Potential - Issues and Options This will contain an overall vision for the future development of the town and will cover a 10 year period 2008 - 2018. It will establish the overall approach Worthing Borough Council, working with its partners in the local and regional community, will use to realise this vision through guiding and enabling the future use and development of land and improving and protecting the town's environment and facilities.

The Unlocking Development Potential document will identify where development land opportunities exist and how their development will help address the main issues facing the Borough. The document will address site allocations and land supply issues for future housing and economic growth, together with town centre/seafront regeneration.

Worthing's residents are actively encouraged to look at the Issues and Options and comment on whether they agree or disagree with them. They will also have the opportunity to identify any other issues and options that they feel are relevant.

Cabinet Member for Economic Development, Planning & Tourism Reg Green says:

"The Core Strategy and Unlocking Development Potential is a pivotal document for Worthing's future planning policy. It is very important that key stakeholders and the general public take the opportunity to have their say in deciding what are the crucial planning issues and options that will face the town over the next 10 to 15 years."

A consultation period for the Issues and Options document will commence from 28 November until 31January. Over this period there will be displays in the Town Hall, Portland House and Central Library, where the documents can be examined and questionnaires can be taken away and filled in. There will also be displays and exhibitions in many other public buildings in the town during the consultation period. The documents can also be seen on the Borough Council's website at www.worthing.gov.uk. A copy can also be requested from the Strategic Housing and Planning Group by telephoning 221364.

Contact details: Ken Costello - Principal Planning Officer 01903 221359

33 Splash FM – public call in to assess Issues and Options

The Council organised a public consultation exercise using the local radio station –Splash FM. The station used commercials voiced by WBC’s Mayor to inform the public about the Issues and Options process and invited them to call in and discuss it on air.

Each day the public were asked by the Mayor to respond to one of the Options set out in the document. They could respond on air and start s debate on the question that was asked during the day.

Sample Questions

“What do we do with ugly industrial estates?”

“ Do we allow the hotels to reduce beds and upgrade or do nothing and let the market place close the inefficient ones?”

“Do we insist that new developments have renewable energy supplies?”

“Should we help essential public workers, like teachers and nurses, by encouraging subsidised housing?”

Sample Replies

“Industrial units need to be maintained and improved for the good of the economy”

“We need more affordable housing – especially for young people”

“Christmas shopping very disappointing….no atmosphere. More things to do on the streets…...performances,… fun things”

The question and answer sessions went on for the whole Issues and Options period

The Q & A sessions had the potential to reach between 40-50,000 listeners at peak times during the morning.

34 Appendix 1.6 List of Issues & options consultees

Organisation

Allen Anthony Greenwood Ass Ltd Barton Willmore Partnership Bellway Homes Berkeley Hotel

Berry Blue Sky Planning Broadwater Residents Action Group

Burlington Hotel C.B.R.E C.P.R.E (Adur & Worthing District) Clarke

Cluttons CPRE Sussex

DC Planning Development Planning Partnership Donin Elm Grove First School English Nature (Sussex & Surrey Team)

Findon Parish Council

GlaxoSmithKline GOSE

GVA Grimley Hall Hayes High Salvington Residents Association

Home Builders Federation Kingston Parish Council Lambert Smith Hampton

Levvel Martlet Homes Nathaniel Lichfield & Partners National Trust (Southern Region) Network Rail Network Strategy-South East Northbrook College Parker Powell R W Hilder & Co RAG Rapleys LLP Roffey Homes

35 Sapphire Primary Care Developments SEEDA SEERA Servite Houses Shaw

Sobrido Heselton South Broadwater Residents Association South Downs Joint Committee Southern Water

Splash Fm

Sport England Strutt & Parker Sussex Enterprise Sussex Wildlife Trust Tanner Tarring Residents Association Thomas White Young Green Planning Woollard Worthing Astrological Society Worthing Borough Council Worthing Borough Council Worthing Borough Council Worthing First Worthing Residents Ass Worthing Town Centre Initiative

36 Appendix 1.7 – Questionnaire

ISSUES AND OPTIONS

CORE STRATEGY AND UNLOCKING DEVELOPMENT POTENTIAL

Questionnaire

Making your Comments This questionnaire has been prepared to help you consider the issues and options set out in the consultation paper. The questions have been grouped under the same headings as the Issues and Options Paper. You may wish to complete all of the questionnaire or simply reply on those areas of particular interest to you. Copies of the questionnaire can be obtained from the Strategic Housing and Planning Group or by telephoning 01903 221364. It can also be downloaded from the Worthing Borough Council Internet site at:

http://www.worthing.gov.uk/A-ZofServices/ServicesNZ/ PolicyDevelopmentUnit/StrategicHousingandPlanning/

Please return all completed questionnaires and comments no later than 5pm on January

31st 2006 to: Strategic Housing and Planning Group, Worthing Borough Council, Portland House, Richmond Road, Worthing, West Sussex, BN11 1LF,

Comments can also be e-mailed to [email protected]

Your Contact Details

Contact Name

Organisation/Group*

Full Postal Address

Post Code Telephone Number E-mail Address

Is this the official view of the organisation/group named above? Yes No If you are an agent acting on behalf of a client, please include your contact details and the name of your client:

Agent's details:______Client:______

Please note that representations are not confidential and will be made available for public viewing. Data Protection

Please note that the information that you provide will be processed by Worthing Borough Council in accordance with the Data Protection Act 1998, to assist in the preparation of the Worthing Borough Council Local Development Framework.

37 ECONOMY

Providing for Employment & Enhancing Jobs Available to Local Residents Yes No 1. Release Greenfield land for new employment investment sites

2. Encourage changes of use (predominantly retail to office in the town centre);

3. Encourage redevelopment of currently vacant employment sites;

4. Promote new employment floorspace at higher densities in accessible locations, particularly within Town Centre locations and railway stations and in existing Trading Areas.

5. Encourage smaller economic activities elsewhere as required to meet the needs of the area.

Questions for Consultees

Which of the above Option (s) do you agree with? Are there any other ways in which employment sites and land can be provided? ………………………………………………………………………………………… …………………………………………………………………………………………

Protecting Existing Employment Floorspace Yes No

6. Maintain the current Policy B10 approach of the Local Plan and resist the loss of employment uses over 300sqm;

7. Resist the loss of all employment floorspace regardless of size;

8. Provide a criteria based policy approach to allow viability to be tested when determining applications for loss of all employment floorspace;

9. Identify less suitable employment sites for redevelopment whilst protecting the most suitable sites and buildings.

Questions for Consultees Which of the above Option (s) do you agree with? Are there any other ways in which to protect existing employment land? …………………………………………………………………………………………

Rundown and Outdated Employment Floorspace and Sites Yes No 10. Allow for some sites within rundown trading estates to be redeveloped for other uses which create jobs or mixed use including some residential;

11. Designate areas where flexibility on loss of floorspace will be acceptable;

12. Allow the market to determine the balance between supply and demand;

13. Designate employment improvement zones.

14. On larger sites promote high density mixed use development with an element of commercial use (B1, B2);

Questions for Consultees Which of the above Option (s) do you agree with? Are there any other ways in which the outdated employment areas could be

38 regenerated? ………………………………………………………………………………………… ………………………………………………………………………………………… Where would you designate an employment improvement zone? …………………………………………………………………………………………

Growth of a Creative Arts and Cultural Sector. Yes No 15. Define a Cultural Arts Quarter around the central Worthing station for artists, craftspeople and makers etc;

16. Define a Cultural Arts Quarter around what is now known as ‘The West End’ (starting at Crescent road through Rowlands Road);

17. Define what would include a Cultural Arts Quarter and where it should be located. Questions for Consultees

Do you agree with the definition of a Cultural Arts Quarter? If yes, which is your preferred location? …………………………………………………………………………………………

Are there any other ways in which Worthing could adapt to changes in the tourism market? …………………………………………………………………………………………

The Viability and Attraction of Tourist Attractions Yes No 18. Promote mixed-use attractions and leisure entertainment uses along the seafront;

19. Development of tourist attractions that appeal to more specialised, niche tourism activities.

20. Direct financial contributions from development towards the physical enhancement of the seafront;

Questions for Consultees Which of the above Option (s) do you agree with? Are there any other ways in which the LDF could improve the tourist attractions in Worthing? ………………………………………………………………………………………… ………………………………………………………………………………………… …………………………………………………………………………………………

Occupancy, Mix & Quality of Hotels and Serviced Accommodation OR

21. Provide more flexible policies to allow for a reduction in bedspaces to allow for upgrading; OR 22. Do nothing and allow the market to improve stock

Questions for Consultees

Which of the above Options do you agree with?

Are there any other ways in which the LDF could improve the hotel mix and quality?

Pressure for Change of Use for Hotels/Guest Houses

23. Re-define the current boundary of the Central Accommodation Area OR 24. Delete the current Central Accommodation Area boundary and policy approach; OR 25. Provide a flexible policy approach which allows for some accommodation loss based on viability assessment

39

Questions for Consultees Which of the above Option (s) do you agree with? Are there any other ways in which the LDF could improve the hotel mix and bedstock? ……………………………………………………………………………………..…

ENVIRONMENT

Climate change Yes No 26. Ensure new development is built to higher sustainability standards.

27. Ensure more mixed uses reducing lengthy distribution and commuting systems.

28. Ensure that development is located close to areas with good public transport links to reduce the need to travel by car.

29. Increase urban densities to reduce sub-urban sprawl.

30. Ensure that 10% of energy on large scale developments is produced by renewable energy.

31. Promote sustainable water management.

32. Renewable energy technology as part of larger developments.

33. Adopt a more flexible and positive approach to proposals for renewable energy.

Questions for Consultees Which of the above Option (s) do you agree with? Are there any other ways in which the LDF could improve or address climate change? …………………………………………………………………………………………

Protecting Urban Areas

34. Favour development in the town centre even if it affects its historic make up as the need for living and working in town centres and not Greenfield sites outweighs its impact. OR 35. Allow development in historic areas but only when they are sympathetic to the character of the area and buildings. OR 36. For development affecting the character of a historic area or building only allow this when complying with high quality design standards. Questions for Consultees Which of the above Option (s) do you agree with? Are there any other ways in which the LDF could improve urban areas? ………………………………………………………………………………………… Protecting The Identity of Worthing and Urban Coalescence

37. Retain strategic gaps but allow development on edges of settlements limiting the visual coalescence as much as possible. OR 38. Abandon the principle of strategic gaps and rely on local and regional countryside policies. OR 39. Retain strategic gaps not allowing any new urban land uses. OR 40. Allow limited loss of strategic gap land. OR 41. Redefine strategic gaps to allow development. Questions for Consultees Which of the above Option (s) do you agree with? Are there any other ways in which the LDF could protect strategic gaps and rural areas?

40 …………………………………………………………………………………………

Biodiversity Yes No 42. Protect existing areas and seek opportunities to increase biodiversity at all levels of development.

43. Protect from threats such as development. 44. Protect such areas less as other issues are more important.

45. Designate additional areas and increase awareness through education.

46. Seek financial contributions from developments to enhance such areas.

47. Seek alternative areas where proposed developments result in the loss of areas of biodiversity. Question for Consultees Which of the above Option (s) do you agree with? Are there any other ways in which the LDF could encourage and enhance biodiversity? ………………………………………………………………………………………… …………………………………………………………………………………………

Sustainable ‘New’ Development Yes No 48. Require larger developments to maximise solar gain through orientation/ passive energy.

49. Encourage the re-use of buildings including conversion of dwellings.

50. Re-use and recycle construction materials from demolition on-site during construction.

51. Ensure provision of recycling and/or composting facilities within or adjacent to development.

Questions for Consultees Which of the above Option (s) do you agree with? Are there any other ways in which the LDF could encourage and enhance biodiversity?

HOUSING

Housing Provision and Capacity Yes No 52. Promote residential development of sites within the built up area where it is currently resisted, (for example on designated industrial land or open space);

53. Bring forward Greenfield sites on the edge of the built up area.

54. Set higher than the PPG3 threshold (30-50dph) densities for town centre, edge of town centre, seafront locations; OR 55. Provide housing at the highest densities for all site across the Borough, regardless of location; OR 56. Define areas / zones in which different density thresholds should apply;

57. Promote the development of airspace over existing buildings such as petrol filling stations and superstores.

Questions for Consultees Which of the above option (s) do you agree with? Are there any additional options? …………………………………………………………………………………………

41

Affordable Housing

58. Affordable housing is defined as housing provided with a subsidy to enable the asking price or rent to be substantially lower than the prevailing market prices or rents in the locality.

Question for Consultees

If not the above please suggest an alternative option in the appropriate comments box.

59. Retain the 30% affordable housing at 1 hectare or 25 units over the Core Strategy period;

OR

60. Apply 30% at a lower threshold of 0.5h or 15 units;

OR

61. Consider a Tiered Approach based on the number of market units proposed: 40% on a threshold of 05ha or 15 units (on site provision) 20% on 11-14 units (on site provision) OR 20% on 6-10 units (as a commuted sum calculated on the basis of serviced free land equivalent to the type and size of units in the original proposal;

62. Consider a Variable Approach based on Market Value of proposal: A higher percentage of affordable housing be provided on sites where the scheme has a higher market value A lower percentage of affordable housing OR provided on sites where the scheme has standard market.

63. Consider a Variable Approach based on current tenure mix: A higher percentage of affordable housing to be provided on sites within wards with a lower than average proportion of affordable housing A lower percentage of affordable housing to be provided on sites within wards with a higher than average proportion of affordable housing

Yes No

64. Should all new housing proposals contribute to affordable housing?

65. Should financial contributions be sought from non residential developments? 66. Seek a tenure mix on all individual affordable housing sites in line with current Housing Strategy targets;

67. Seek a higher % of the affordable housing units as social rented units on affordable housing sites above a set threshold (e.g. 15 units) and a lower % on sites

Question for Consultees Which of the above option(s) would you agree with?

Size & Type of New Housing

Options

68. Do not specify the proportion of units of different sizes;

42

OR 69. Continue to encourage a substantial proportion of smaller units through private sector development concentrating on 2 bed properties rather than 1 bed units. ; Yes No 70. In the case of affordable housing the size of units required will be as per Housing Strategy targets current at the time; or

71. Restrict the number of larger 4/5 bed units within private market sector

72. Facilitate a range of sizes within larger scale developments.

Question for Consultees Which of the above Option (s) do you agree with?

Specialist Housing Needs

Options Yes No 73. Ensure homes are designed to be more adaptable to meet changing needs;

74. Provide a policy which provides for a % of wheelchair properties within both private and affordable housing schemes;

75. Introduce a Lifetime Homes standard for a percentage of units within developments. Question for Consultees

Which of the above Option (s) do you agree with? Energy Efficient Homes or EcoHomes Options

76. Require all homes to be built to a set Eco-Homes standard (e.g. ‘good’ or ‘very good’);

OR

77. Require a proportion of new homes on schemes over a certain threshold to be built to a set Eco-Homes standard OR

78. Include a policy on sustainable high quality design with criteria.

Question for Consultees

Which of the above Options do you agree with?

RETAIL

Providing for Future Retail in Worthing Yes No 79. Identify the type of retail space we should be looking to create. There are several options including larger retail warehouses, larger retail units, smaller individual retail units, and mixed-use development.

80. Expand the Town Centre to allow for retail sites to be outlined to fulfil identified demand,

81. Provide for higher quality national chain stores through identifying sites that will accommodate larger floor areas within the retail core.

82. Identify sites for existing retailers who need larger floor areas

43 83. Identify new retail opportunities through mixed use Questions for Consultees

Do you agree with the above options? Are there any other ways in which Worthing can remain a prosperous town and shopping destination? …………………………………………………………………………………………

Central Shopping Area Yes No 84. Review shopping policy in the Town Centre. Possibilities include maintaining existing Shopping Area policy, providing a more flexible approach to encourage a wider range of uses, or the re-evaluation of current policy areas.

85. Designate a specific area for cafes/restaurants.

86. Create a policy to manage nighttime uses in the Town Centre. Concentrate such uses within a specific area, or look to distribute them more equally throughout the town.

87. Provide for small niche retail independents within Zone A.

88. Improve the appearance of the Town Centre.

89. Further pedestrianisation of the Town Centre.

Questions for Consultees Do you agree with the above options? Are there any other ways in which we could improve the Central Shopping Areas? …………………………………………………………………………………………

Prevent the Expansion of Out of Centre Retail Yes No 90. Do not allow any new retail units to locate at Lyons Farm;

91. Encourage new retail development on other sites (ideally within the Town Centre) through imposing restrictions on the type of retail able to locate at Lyons Farm, e.g. Limit permissions on this site to ‘bulky goods’ retailers.

Questions for Consultees Do you agree with the above options? Are there any other ways to address the pressure for out of centre retail? …………………………………………………………………………………………

District Centres Yes No 92. Maintain existing policy approach, ensuring thresholds regarding retail unit frontages are met in core areas, and allowing greater flexibility in non-core areas.

93. Apply a more flexible policy approach to site specific parts of district centres which are found to be in poor health, e.g. Broadwater Boulevard, to allow a wider range of uses which may attract custom to the area.

94. Re-designate the existing centres to remove unhealthy areas. An absence of retail policy in these areas may encourage a wider range of uses to locate in these areas.

95. Redevelop failing areas. Potential options could be new, modern retail units, improved landscaping and amenities.

Questions for Consultees

44 Do you agree with the above options? Can you think of any other ways in which we can improve failing areas within the district centres?

Neighbourhood Centres and Local Parades Yes No

96. Identify which centres/parades require a policy stance in order to continue to meet important local need.

97. Improve ‘less healthy’ parades through environmental improvements if necessary. E.g. More litterbins, phone boxes, planting/landscaping.

98. Improve access to centres/parades. Possible options include; providing further traffic calming measures by parades, provision of more bus services/ increased frequency of service. Improving and/or increasing cycle facilities at centres/parades is an option.

99. Further development of centres/parades. Is there potential for this and could it benefit some centres/parades?

100. Apply a more flexible policy approach to unhealthy centres/ parades, potentially remove required thresholds for A1, A2, A3 uses and allowing a wider range of uses that would benefit the centre/parades, e.g. Dentists, Doctors.

101. Re-define the boundaries of some centres/parades, possibly de-designating some areas of centres/parades from policy protection in order to concentrate retail functions and encourage other uses in unhealthy areas.

102. Allocate new shopping areas if necessary. Questions for Consultees

Do you agree with the above options? Can you think of any other issues concerning neighbourhood centres and local parades? …………………………………………………………………………………………

SOCIAL AND COMMUNITY

Community Safety Yes No 103. Ensure that all new development complies with Secure by Design Guidance

104. Enable the provision of facilities for young people to come forward

105. Ensure that new development contributes financially to measures which address safety issues identified in specific areas e.g. areas with a high incidence of criminal damage

106. Managing or restricting the concentration of nighttime economy activities in the town centre.

Questions for Consultees Do you agree with the above options? Are there any other ways in which the LDF could improve the Core Strategy? …………………………………………………………………………………………

Community/Social Issues Yes No 107. Community uses include premises used by community/voluntary groups, health, religious meeting places and advice/information services.

45 Questions for Consultees Does this include all community uses? If not, which other uses would you wish to include? ………………………………………………………………………………………… Yes No 108. Resist the loss of existing community facilities, unless they are replaced with those of an equivalent value.

109. Encourage the dual, intensification and diversification of use of community, education and leisure facilities.

110. Ensure any funding achieved through new development is directed, where applicable, towards areas of deprivation?

Question for Consultees Do you agree with the above options? Are there any other ways in which the LDF could improve Community and Social facilities? …………………………………………………………………………………………

Leisure and Culture Yes No 111. Resist the loss of any existing leisure/cultural facilities.

112. Identify those facilities which offer opportunities for improved leisure and recreation provision.

113. Identify those facilities which offer opportunities for redevelopment for other uses

114. Encourage the dual, intensification and diversification of use of leisure and cultural facilities.

Questions for Consultees Do you agree with the above options? Are there any other ways in which the LDF could improve Open Spaces and Recreation facilities? …………………………………………………………………………………………

Health Yes No 115. Working with partners to identify sites for new local care centres.

116. Seeking contributions towards health and social care facilities from new developments in areas where there is a deficiency of provision.

Questions for Consultees Do you agree with the above options? Are there any other ways in which the LDF could improve health facilities? …………………………………………………………………………………………

Education (Learning and Skills) Yes No 117. Work with further education providers to address needs for accommodation/new education provision

118. Working with partners to identify sites for new facilities.

119. Giving clear guidance on what will be expected of proposals for new training and educational facilities.

Questions for Consultees Do you agree with the above options? Are there any other ways in which the LDF could improve Learning and Skills? …………………………………………………………………………………………

TRANSPORT

46

Road Infrastructure Yes No The Borough Council cannot build the East Worthing Access Road on its own. The option will be what route should EWAR take:

120. Option 1- Dominion Way to the A27 just east of Lyons Farm.

121. Option 2 – Dominion Way until the GlaxoSmithKline sports ground before moving further eastwards, joining the A27, between Sompting and Sompting Village.

Question for Consultees Which of the options do you agree with?

Major New developments Yes No 122. Ensuring that major new developments make provision for the access needs they generate. Developer funding should facilitate the building of junction improvements, cycling and walking schemes and other infrastructure requirements.

Questions for Consultees Do you agree with the above option? Are there any other ways in which the LDF could improve the road infrastructure?

Road Congestion Yes No 123. Work with partners to deliver school and business Travel Plans, encouraging the use of alternative modes of transport other than the car, such as walking, car sharing and cycling.

124. Should more cycle routes and car sharing schemes be introduced to restrict car use?

125. Require the submission of a travel plan with all new business development?

Questions for Consultees Do you agree with the above options? Are there any other ways in which the LDF could reduce road congestion and car usage? …………………………………………………………………………………………

Parking Yes No 126. Does Worthing need more restrictive parking controls in the Town Centre and in the existing parking zones?

127. Define areas/zones in which different parking standards could apply e.g. setting lower standards for the Town Centre/edge of Town Centre and other sustainable locations.

128. Provide a Park and Ride site outside of the town to reduce parking pressures and congestion in the Town Centre.

129. Do we need to protect the number of existing spaces, reduce or increase them?

Questions for Consultees Do you agree with the above options? Are there any other ways in which the LDF could improve the parking situation in Worthing?

Public Transport/Sustainability Yes No

47 130. Is there a need to provide better public transport provision from new developments?

131. Should there be better public transport links from the Town Centre to the railway stations? Should there be more cycle routes from the Town Centre to the outlying areas?

132. Should developer funding be used to improve waiting areas and facilities at railway stations?

Questions for Consultees Do you agree with the above options? Are there any other ways in which the LDF could improve public transport in Worthing? …………………………………………………………………………………………

48 Appendix 1.8 Results of Issues & Options consultation

ENVIRONMENT

No Climate Change Resp Yes No

26. Ensure new development is built to higher sustainability 36 36 4 27. Ensure more mixed users reducing lengthy distribution 42 32 2 28. Ensure development is located close to areas with good transport 39 34 3 29. Increase urban densities to reduce sub-urban sprawl. 41 29 7 30. Ensure 10% energy produced by renewable energy 39 39 8 31. Promote sustainable water management 34 43 0 32. Renewable energy technology as part of larger developments 37 36 4 33. Adopt more flexible/positive approach to renewable energy 41 33 3

Protecting Urban Areas

No response 19 34. Release Greenfield land for new employment investment sites 8 35. Allow development in historic areas if sympathetic 17 36. For development affecting the character of a historic building 18

Protecting the Identity of Worthing and Urban Coalescence

No response 33 37.Retain strategic gaps but allow development on edges of settlements 7 limiting the visual coalescence as much as possible 4 38. Abandon principle of strategic gaps rely on local and regional 17 countryside policies 2 39. Retain strategic gaps not allowing new urban land-uses 9 40. Allow limited loss of strategic gap land 41. Redefine strategic gaps to allow development

No Biodiversity Resp Yes No

42. Protect existing areas seek opps to increase biodiversity 41 34 1 43. Protect from threats such as development 45 25 6 44.Protect such areas less as other issues are more important 48 5 23 45. Designate additional areas increase awareness through education 45 27 4 46. Seek financial contributions from developments to enhance areas 44 29 3 47. Seek alternate areas where proposed dvpments result in loss of biodiv 48 25 3

No Sustainable'New' Development Resp Yes No

48. Require larger developments to maximize solar gain through 38 33 5 orientation / passive energy 49. Encourage re-use of buildings including conversion of dwellings 38 36 2 50. Re-use and recycle construction materials from demolition on-site 39 35 2 construction. 51. Ensure provision of recycling +/or composting facilities within or 38 34 4

49 SOCIAL AND COMMUNITY

Community safety No Resp Yes No

103. Ensure new development complies with Secure by Design Guidance 41 34 2 104. Enable provision of facilities for young people to come forward 44 33 0 105. Ensure new development contributes financially to measures which 42 32 3 address safety issues identified in specific areas eg areas with a high incidence of criminal damage 106. Managing/restricting concentration of nightime economy activities 43 28 6

Community / Social Issues No Resp Yes No

107. Community uses include premises used by community/voluntary gps, 46 26 3 h108. lth Resist li loss i of existing ti lcommunity d dfacilities. i /i f ti i 42 32 3 109. Encourage dual intensification and diversification of use of 43 34 0 community,education and leisure facilities 110. Ensure funding achieved through new development is directed, where 47 23 7 applicable towards areas of deprivation

Leisure and Culture No Resp Yes No

111. Resist loss of any existing leisure/cultural facilities 40 77 10 112. Identify facilites offering opportunities for improvement 42 33 2 113. Identify facilities offering opportunities for redevelopment 43 24 10 114. Encourage the dual,intensification and diversification of facilities 40 35 2

Health No Resp Yes No

115. Working with partners to identify sites for new care centres 46 31 0 116. Seeking contributions towards health social care facilities 47 28 1 47 28 1

Education (Leaning Skills) No Resp Yes No

117. Work with further education providers to address accom needs 45 31 0 118. Working with partners to identify sites for new facilities. 45 27 1 119. Giving clear guidance on what will be expected of proposals 46 26 2

50 RETAIL

No Providing for Future Retail in Worthing Resp Yes No

79. Identify type of retail space we should look for to create. There are 42 28 5 several options including larger retail warehouses, larger retail units, smaller individual retail units and mixed-use development 80. Expand the Town Centre to allow for retail sites to be outlined to fulfil 46 17 4 identified demand 81. Provide for higher quality national chain stores through identifying 43 28 4 sites that will accommodate larger floor areas within the retail core 82. Identify sites for existing retailers who need larger floor areas 46 29 1 83. Identify new retail opportunities through mixed use. 43 33 1

Central Shopping Area

84. Review shopping policy in Town Centre. Possibilities include 45 30 2 maintaining existing Shopping Area policy, providing a more flexible approach to encourage a wider range of uses, or the re-evaluation of current policy areas. 85. Designate a specific area for cafes / restaurants 42 10 25 86. Create a policy to manage nightime uses in Town Centre. Concentrate 48 27 2 such uses within a specific area, or look to distribute them more equally throughout the town. 87. Provide for a small niche retail independents within Zone A 46 27 4 88. Improve the appearance of the Town Centre 42 33 1 89 Further pedestrianisation of the Town Centre 41 25 11

Prevent the Expansion of Out of Centre Retail

90. Do not allow any new retail units to locate at Lyons Farm 41 18 17 91. Encourage new retail development on other sites (ideally within Town 41 26 9 Centre) through imposing restrictions on the type of retail able to local at Lyons Farm, e.g. Limit permissions on this site to 'bulky goods' retailers

District Centres

92. Maintain existing policy approach ensuring thresholds regarding retail 47 17 12 unit frontages are met in core areas, and allowing greater flexibility in noncore areas 93. Apply a more flexible policy approach to site specific parts of district 42 33 1 centres which are found to be in poor health e.g. Broadwater Boulevard to allow a wider range of uses which may attract custom to the area. 94. Re-designate existing centres to remove unhealthy areas. An absence 44 26 5 of retail policy in these areas may encourage a wider range of uses to locate in these areas 95. Redevelop failing areas. Potential options could be new modern 41 32 3 retail units, improved landscaping and amenities.

Neighbourhood Centres and Local Parades

96. Identify which centres/parades require a policy stance in order to 45 30 2

51 continue to meet important local need. 97. Improve ' less healthy' parades through environmental improvements 44 31 2 98. Improve access to centres/parades. Possible options include, providing 47 29 1 further traffic calming measures by parades, provision of more bus services / increased frequency of service. Improving and/or increasing cycle facilities at centres/parades is an option 99. Further development of centres/parades. Is there potential for this and 49 24 4 could it benefit some centres / parades? 100. Apply more flexible approach to unhealthy centres/parades, 47 29 1 potentially remove required thresholds for A1, A2, A3 uses and allowing a wider range of uses that would benefit the centre/parades, e.g. dentists, doctors 101. Redefine boundaries of some centres/parades, possibly de- designating 51 22 4 some areas of centres/parades from policy protection in order to concentrate retail functions and encourage other uses in unhealthy areas. 102. Allocate new shopping areas if necessary 51 20 6

52 TRANSPORT

No Road Infrastructure Resp Yes No

The Borough Council cannot build the East Worthing Access Road on its own. The Option will be what route should EWAR take:

120. Option 1- Dominion Way to the A27 just east of Lyons Farm 54 18 4 121. Option 2 - Dominion Way until the GlaxoSmithKline sports ground before 53 12 11 moving further eastwards, joining the A27 between Somping and Sompting Village

Major New Developments

122. Ensuring that major new developments make provision for access needs 36 38 1 they generate. Developer funding should facilitate the building of junction improvements, cycling and walking schemes and other infrastructure requirements.

Road Congestion

123. Work with partners to deliver school/business travel plans, encouraging 38 36 1 the use of alternative modes of transport other than the car, such as walking, car sharing and cycling. 124. Should more cycle routes and car sharing schemes be introduced to 38 32 6 restrict car use?. 125. Require submission of a travel plan with all new business development 41 32 3

Parking

126. Does Worthing need more restrictive parking controls in the Town 37 6 31 Centre and in existing parking zones? 127. Define areas/zones in which different parking standards could apply e.g. 41 25 8 setting lower standards for the Town Centre / edge of Town Centre and other sustainable locations? 128. Provide Park Ride site outside of town to reduce parking pressures and 41 24 9 congestion in the Town Centre.. 129. Protect no of existing spaces / reduce / increase ? 46 25 3

Public Transport Sustainability

130. Is there a need to provide better public transport provision 37 35 3 131. Should there be better public transport links from Town Centre? 34 37 4 132. Should developer funding be used to improve railway stations ? 36 27 13

53 HOUSING

Housing Provision and Capacity No Resp Yes No

52. Promote residential development of sites within built up area 38 24 14 53. Bring forward greenfield sites on the edge of the built up area. 37 11 25

No response 25 54. Set higher than the PPG3 threshold densities for Town Centre 34 55. Provide housing at the highest densities for all sites across Borough 10 56. Define areas/zones in which different density threshholds apply 2 57. Promote development of airspace over existing buildings 39 26 10

Affordable Housing

No response 39

59. Retain 30% affordable housingat 1 hectare or 25 units over Core strategy Period 7 60. Apply 30% at a lower threshold of 0.5h or 15 units 4 61. Consider a tiered approach based on number of market units proposed: 10 - 40% on a threshold of 05ha or 15 units (on site provision) - 20% on 11-14 units ( on site provison) - 20% on 6-10 units (as commuted sum calculated on the basis of serviced free land equivalent to the type and size of units in the original proposal 62. Consider a variable approach based on Market Value of proposal: 3 A higher % of affordable housing be provided on sites where the scheme has a higher market value A lower % of affordable housing provided on sites where the scheme has standard market value 63. Consider a Variable Approach based on current tenure mix: a higher % of affordable housing to be provided on sites within wards with a lower than average proportion of affordable housing 5 A lower % of affordable housing to be provided within wards with a higher proportion of affordable housing No Resp Yes No 64. Should all new housing proposals contribute to afforable housing 44 18 15 65. Should financial contributions be sought from non redsidential devs 45 18 13 66. Seek a tenure mix on all individual afforable housing sites. 50 21 5 67. Seek a higher % of affordable housing units as social rented units 48 15 12

Size and Type of New Housing

No response 38

68. Do not specify proportion of units of different sizes 13 69. Continue to encourage substantial proportion of smaller units 18 70. Affordable housing - size of units required as per HS targets current. 50 23 4 71. Restrict no. of larger 4/5 bed units in private sector market 47 12 18 72. Facilitate a range of sizes within larger scale developments 43 29 5

54 Specialist Housing Needs

73. Ensure homes are designed to be more adaptable 40 32 2 74. Provide a policy which provides for a % of wheelchair properties 43 27 6 75. Introduce a Lifetime Homes standard for % of units in development 44 22 9

Energy Efficient Homes or EcoHomes

No response 32

76. Require all homes to be built to a set Eco-Homes standard (eg good or very good) 26 77. Require a proportion of new homes on schemas over a certain threshold to be built to a set Eco-Homes standard 1 78. Include a policy on sustainable high quality design with criteria 13

55 ECONOMY

Providing for Employment Enhancing Jobs available to Local Resident No Resp Yes No

1. Release greenfield land for new employment investment sites 33 5 37 2. Encourage changes of use (predominantly retail to office) 38 14 23 3. Encourage redevelopment of currently vacant employment sites 35 40 0 4. Promote new employment floorspace at higher densities. 37 36 3 5. Encourage smaller economic activities elsewhere as required 39 33 3

Providing Existing Employment Floorspace No Resp Yes No

6. Maintain current Policy B10 approach of Local Plan 46 14 14 7. Resist the loss of all employment floorspace regardless of size 45 6 23 8. Provide a criteria based policy approach to allow viability to be tested 39 31 5 42 27 5 Rundown and Outdated Employment Floorspace and Sites No Resp Yes No

10. Allow for some sites within rundown trading estates 40 32 5 11. Designate areas where flexibility on loss of floorspace acceptable 42 27 7 12. Allow the market to determine the balance between supply / demand 41 18 18 13. Designate employment improvement zones 46 24 7 14. On larger sites promote high density mixed use development 41 18 18

Support the Diversification of the Tourism Economy Encourage Growth of a Creative Arts Cultural Sector No Resp Yes No

15. Define a Cultural Arts Quarter around the central Worthing station 43 16 18 16. Define a Cultural Arts Quarter around 'The West End' 47 15 15 17. Define what would include a Cultural Arts Quarter and location 49 18 10 Do you agree with the definition of a Cultural Arts Quarter

The Viability and Attraction of Tourist Attractions No Resp Yes No

18. Promote mixed-use attractions and leisure entertainment 41 27 9 19. Development of tourist attractions that appeal to specialised 44 28 5 20. Direct financial contributions from dvlpment towards enhancement 41 32 4

Occupancy, Mix Quality of Hotels and Serviced Accomodation

no response 38 21. Provide more flexible policies to allow for reduction in bedspaces to 17 allow upgrading 22. Do nothing and allow the market to improve stock 15

Pressure for Change of Use for Hotels/Guest Houses

no response 39 23. Re-define the current boundary of the Central Accomodation Area 4 24. Delete the current Central Accomodation Area boundary 4 25. Provide flexible policy approach which alows for accomodation 39

56 Summary of responses

ECONOMY

Providing for Employment & Enhancing Jobs Available to Local Residents Support for encouraging redevelopment of currently vacant employment sites, promoting new employment floorspace at higher densities in accessible locations and encouraging smaller economic activities elsewhere Minimal support for release of Greenfield land Majority of responses against encouraging the change of use of retail to office in the town centre

Protecting Existing Employment Floorspace Majority did not want all employment floorspace protected but preferred a criteria based policy approach to allow viability to be tested. There was also support for identifying less suitable employment sites for redevelopment.

Rundown and Outdated Employment Floorspace and Sites Support for allowing a more flexible approach and where the trading estate as become rundown, to allow for redevelopment for alternative employment use or mixed use. There was also support for the designation of employment improvement ones.

Support the Diversification of the Tourism Economy and Encourage the Growth of a Creative Arts and Cultural Sector There was no clear cut picture to emerge from the options. Option 15 proposed highlighting the area around Worthing Station for Artists and Craftspeople. This had marginally more support than Option 16 which proposed an area around Rowlands Road. Overall there was marginally more support for defining what would include a Cultural Arts Quarter but with no distinct location.

The Viability and Attraction of Tourist Attractions The main picture to emerge was the support for mixed use attractions, the development of more specialized, niche tourism activities and ensuring financial contributions from development to enhance the seafront. The Preferred Option would therefore be to take forward mixed use attraction while supporting some niche specialized attractions.

Occupancy, Mix and Quality of Hotels and Serviced Accommodation There was no clear direction on this issue, responses were equally divided between a more flexible policy approach and a do nothing ‘scenario which would allow the market to decide.

Pressure for Change of Use for Hotels/Guest Houses The majority of respondents wanted to see a flexible policy approach to allow for some accommodation loss based on viability assessment.

57 ENVIRONMENT

Climate Change Majority of respondents supported a range of options to address climate change e.g. sustainability standards, increasing urban densities, promoting renewable energy.

Protecting Urban Areas General support for ensuring that the character of historic areas and buildings are protected.

Protecting the Identity of Worthing and Urban Coalescence Majority of respondents wanted to see strategic gaps retained and not to allow any new urban land uses.

Biodiversity Majority of responses did not want to see a reduction on the protection of areas of biodiversity importance, but wish to see the additional areas designated with financial contributions from development to enhance such areas. Sustainable New Development Most respondents wanted to see a range of measures to ensure that conversions were encouraged together with the recycling of materials.

HOUSING

Housing Provision and Capacity Most wished to see residential development promoted within the built up area on sites where it is currently resisted (e.g. industrial land or open space) There was little support for Greenfield sites wished to see the definition of areas/zones in which different density thresholds should apply .

Affordable Housing Whilst there was some support for maintaining the existing approach (30% on 25 units), the majority responses supported a tiered approach based on the number of market units proposed e.g. 40% on 15 units, 20% on 11-14 units and 20% on 6-10 units as a commuted sum. There was no clear picture on whether all housing proposals should contribute or whether non-residential developments should contribute. The majority wished to see a tenure mix on all affordable housing sites in line with the current Housing Strategy targets.

Size and Type of New Housing Most responses supported the promotion of smaller units in private sector developments, with affordable housing being in line with the Housing Strategy and ensuring a range of sizes within larger scale developments. However the majority did not wish to see a restriction on the number of 4/5 bed units within the private sector developments.

58 Specialist Housing Needs The majority wished to see homes designed to be more adaptable to meet changing needs and have a policy framework that provided for a % of wheelchair properties and lifetime homes.

Energy Efficient Homes or Eco-Homes The majority wished to see all homes built to a set Eco-Homes standard.

RETAIL

Providing for Future Retail in Worthing The majority of responses support all the options in this section. This would entail a policy approach which gave more certainty regarding the type of retail space needed, providing for quality national chain stores and identifying new retail opportunities through mixed use

Central Shopping Area There was support for reviewing the shopping policy in the town centre but the majority did not want to see a specific area designated for cafes/restaurants. However, there is clear support for more flexible approach to encourage a range of uses. Priority should be given to managing the nighttime economy, providing for small niche retail independents and improving the town centre environment including support for further pedestrianisation.

Prevent the Expansion of Out of Centre Retail Views were split on whether to allow any new retail at Lyons Farm but a majority supported new retail on other sites by restricting the type of retail at Lyons Farm.

District Centres The main support was in allowing a more flexible approach to retailing in the District Centres, with the redevelopment of some failing areas within a centre.

Neighbourhood Centres and Local Parades Balanced support of all options. This would promote improvements to the parades and provide a more flexible policy approach with the designation of new areas if necessary. The de-designation of under performing parades which no longer serve a neighbourhood or local function should also be considered.

SOCIAL AND COMMUNITY

Community Safety There was support for ensuring all development complies with Secure by Design Guidance. Facilities for young people were seen as very important, together with ensuring that new development contributes financially to measure which address safety issues.

59 Community/Social Issues Support for ensuring existing community facilities were kept or replaced. The dual use of such facilities should be encouraged, together with commuted payments being directed to areas of deprivation.

Leisure and Culture There was strong support for resisting the loss of any existing leisure/cultural facilities. The majority of responses wished to see the identification of opportunities for improvements to leisure and recreation provision. There was support for identifying opportunities for redevelopment for other uses, together with the dual use of some facilities.

Health There was support in ensuring that we work with partners to identify sites for new local care centres and seeking contributions from new development towards health and social care.

Education Support to address the needs of education providers, together with identifying sites for new facilities.

TRANSPORT

Road Infrastructure For the options on the East Worthing Access Road, there was more support for Option 1 (Dominian Way to the A27 just east of Lyons Farm), rather than a road further eastwards.

Major New Developments The majority of responses supported a policy approach that would ensure that major new developments make provision of the access needs they generate. Developer funding should facilitate the building of junction improvements, cycling and walking schemes.

Road Congestion The majority supported the need for school and business travel plans, with more cycle routes and car sharing schemes. New business development should be accompanied by a travel plan.

Parking The majority did not want to see more restrictive parking controls in the town centre and existing parking zones. There was support for different parking standards in different areas/zones and a park and ride outside the town .

Public Transport/Sustainability The responses highlighted the need to improve public transport provision, with better links from the town centre to the railways stations and more cycle routes to the outlying areas.

60 Appendix 1.9 Respondents & analysis of the Sustainability Scoping report consultation

Organisation Eastgate 195-205 High English Heritage Court Street Guildford South East Regional Countryside Agency Office 19 Dacre Street London Horsham District Council Park North North Street Horsham West Sussex Brighton & Hove Council Kings House Grand Avenue Hove Crawley Borough Council Town Hall The Boulevard Crawley West Sussex Haywards Mid Sussex District Council Oaklands Oaklands Road Heath West Sussex East Pallant Chichester District Council House Chichester West Sussex Berkley SEERA House Cross Lanes Guidlford SEEDA Headquarters Cross Lanes Guidlford The Adur, Arun & Worthing PCT Causeway Goring-by-Sea Worthing West Sussex 1 Walnut Treet GOSE Bridge House Close Guidlford West Sussex County Council The Grange Tower House Chichester West Sussex English Nature Sussex & Surrey Phoenix Team House 33 North Street Lewes East Sussex Southern Regional Guildbourne Chatsworth Environment Agency Office House Road Worthing 4th Floor, Federated Highways Agency Wing C House London Road Dorking Princes 53 Queens Sussex Learning & Skills Council House Road Brighton East Sussex Arun Civic Arun District Council Centre Maltravers Road Littlehampton West Sussex Adur District Council Civic Centre Ham Road Shoreham West Sussex Durrington, John Ashworth C/O Tesco New Road Worthing Worthing C/O Downlands Paul Stefanski Sainbury's Business Park Worthing West Sussex Co-op John Goldspink Superstore Newland Street Worthing West Sussex Victorian Barn, Victorian Business Sussex Downs Joint Committee Centre, Ford Lane, Ford Arundel West Sussex

61 Organisati Comments on English Consider 6 suggested LDF biodiversity indicators for inclusion. Nature 4.6: change ‘improved’ grassland to ‘unimproved’.

Give due consideration to protection of bats within planning policies. Roosts are protected against obstruction, damage or destruction.

Take account of habitat requirements for protected species incl. dormice, great crested newts and reptiles.

Requirements that a protected species survey should be carried out prior to an application to be included in policies.

Consider additional objectives and indicators (table A and B).

Consider joining Sussex Biological Records Centre for baseline data and monitoring.

Download SSSI condition from EN website.

Targets for WBC for chalk grassland, woodland and the urban BAP.

A list of national BAP and LBAP species previously recorded in the borough can be obtained from SBRC.

Information or national trends on populations of wild birds can be obtained from British Trust for Ornithology.

English Nature recommends that there is 1 ha of accessible natural green space per 1000 people. Other targets also provided for inclusion in local plans.

A policy for the protection of ancient woodland from significant loss of area should be included in the LDF.

Environme Add PPG23 Planning and Pollution to Appendix 1. nt Agency Expand 4.49 point 9 to: ‘Need to address areas of contaminated land, particularly if the site lies within a Source Protection Zone or on an Aquifer.’

6.3 Point 2 should be reworded to:

'Effective protection and enhancement of the environment.'

6.4 Objectives and Indicators:

6. We would suggest the following indicator is used as a measure of this objective:

% of new developments that enhance biodiversity.

7. We would suggest the indicators are changed to:

Number of developments given planning permission contrary to Environment Agency advice on Flood Risk.

% of new developments with Sustainable Drainage Systems (SuDs) installed.

11. We would recommend this objective is reworded to:

"Maintain and improve the quality and resources of the Borough's freshwater bodies and

62 waterways, groundwater and the marine environment, and achieve sustainable water resources management."

The second indicator should be replaced with:

% of new developments that incorporate water efficiency measures.

12. This objective should be reworded to:

Bring land affected by contamination into beneficial use

The indicator for this objective should be amended to:

Area of contaminated land remediated and brought into beneficial use.

Mention Teville Stream. This has now got the status of a designated main river. Teville Stream poses a moderate flood risk to a substantial part of north-east Worthing, including many of the trading estates.

In accordance with PPS23 the precautionary approach should be applied to re-development of all ‘Brownfield’ site in regards to potential contamination. Investigation prior to planning permission being granted.

English 4.49 mentions the importance of maintaining and enhancing the natural & built environment Heritage and the need to retain urban character and the protection of conservation areas and listed buildings.

Add some explanation behind the reference to retention of historic development patterns.

Add more to the threats to character e.g. urban extension, intensification, loss of visitor accommodation.

It is unclear how effective the proposed indicators would be in measuring progress towards objectives 8 and 14. Buildings at risk is of limited value and consideration should be given to: the need to ensure no loss of listed buildings, nationally important archaeological remains, historic parks and gardens etc and protection of locally important features.

A number of historic information sources are given by EH.

A list of possible indicators for heritage is given by EH.

When considering impacts upon the historic environment you are advised to consider the effect of cumulative impacts before concluding that impacts on individual heritage sites are not strategically significant.

Arun DC Mention the Government’s new Sustainable Development Strategy ‘Securing the future’.

4.1 says Worthing has 2nd largest population after Crawley but Arun is the largest in West Sussex in population terms.

PPS9 in draft, also mention PPG9. SMP in draft PPS6 no longer draft PPS10 no longer draft

GOSE Does the Regional Development Agency (SEEDA) have any schemes in your borough?

Will plans and projects in neighbouring authorities influence or be influenced by your plans?

63 Have you established plan objectives yet? When do you propose to test them against sustainability objectives? Have you considered basing your plan objectives on development needs and targets? How might you address the issues raised in ‘Planning for Housing Provision’?

How do you propose to canvass broad options for subsequent testing through the SA process? Will that be at the start of the iterative consultation process under Regulation 25 of the Town and Country Planning (Local Development) (England) Regulations? How will you ensure that realistic options are identified early on in the process to secure front loading of the process and minimise the risk of the examination being delayed or extended to address realistic options that were not picked up at an earlier stage?

Quality Assurance Check List. As an aid to self-assessment, you may wish to include this in subsequent sustainability appraisal documentation and show how you are working towards signing off all the actions.

Countrysid No comments received. e Agency Bryan • 4.12 The SMP is complete and will be reported to Members in January for adoption Curtis, Principal • Under the SMP sits a strategy for the coast between the Rivers Adur and Arun for the Engineer, delivery of future coast defence works which is not mentioned and I wonder whether it Engineerin should be? g Services, Worthing • Under 4.49 is protection of the coast and its long term role, the impact of climate change Borough - risk of flooding and the role of sea defences and need to address land contamination Council issues a matter for the LDF? Surely a more important high level matter for the LDF would be addressing coastal squeeze. I can't find any mention of this despite it being highlighted as a problem at a recent Masterplan workshop. I would prefer to see this matter highlighted as a generic problem for the LDF to deal with rather than singling out other items already covered by other plans, strategies and in some cases law.

• Under 5.6 shouldn't we guiding the reduction in the risk of flooding and protection of water resources towards sustainable drainage systems? You mention sustainable design in the objectives of 5.7 and note them in 6.4 7 so can't we be a little more specific?

• I can't quite see the relevance of the table under 6.4. Whilst the objectives are clear the indicators to I assume achieving them don't make sense. Take for instance number 7 the EA flood risk maps only highlight some areas which are at risk of flooding as there are many more. The indicator of the number of SUDs installed is good but I think this should include the number of properties covered by them together with some base specification which qualifies a system.

64 Appendix 2.1 Press release Core Strategy and Sustainability Appraisal Press Release From Worthing Borough Council

We can all play an important role in deciding HOW we use our land, WHAT we build on it and WHERE we actually build!

Worthing Borough Council has the responsibility to work towards adopting a Local Development Framework (LDF).The documents that make up the LDF will need to show how the needs of the community and development needs can be met. In November last year we consulted on the issues and options facing the town over the next 20 years. The responses received were considered and have helped inform what the policy approach should be in addressing issues and achieving the spatial vision for the Borough.

The ‘Preferred Options’ – two very important documents have been produced for which your views are sought.

The ‘Core Strategy’ - this document identifies and assesses the actual sites and proposals that could be developed to deliver the vision set out in the Core strategy.

The ‘Unlocking Development Potential Document’ (Site specific allocations) identifies and assesses the actual sites and proposals that could be developed to deliver the vision set out in the Core Strategy.

We would like to hear your views and opinions on these two documents.

The full documents can be viewed on the Council web-site on the LDF pages at www.worthing.gov.uk. Copies are also available for inspection at the Council Offices at Portland House, the Main Library, local libraries and at the Town Hall. An “Open Day” will be held in the Gordon Room at the Town Hall on 25 October, from 09.00- 17.00. Where you can discuss any details in the documents with planning officers. Also look out for the mobile LDF exhibitions on the 7 and 21 October in the town centre! Your views are sought on both documents and should be sent using the online consultation system or by completing a questionnaire available on request.

All Comments must be received by no later than Monday 6 November 2006. Remember – This is your chance to have your say!

If you require any more information you can contact the Strategic Housing and Planning Department at Portland House by calling us on 221359, or you can e-mail us at [email protected]

Contact: Ann Barlow, Deputy Leader, 01903 238478 Clare Mangan, Strategic Housing and Planning Manager, 01903 221358

65 Vibe Article Planning for Worthing’s Future A new planning policy framework for Worthing is now being prepared. It is called the Local Development Framework. It will help us all to shape the way we live in the town over the next ten years.

You, as residents can play an important role in deciding HOW we use our land, WHAT we build on it and WHERE we actually build! You may not be aware of this, but the planning process can affect us all in our lives. It will influence where we build new shops and offices, how we enhance our community facilities and equally importantly, how we can protect Worthing’s historic character and natural environment. The new planning system we are developing is based on the Government’s desire to make the planning system more flexible and quicker to adapt to the changing needs of the community. It will replace the current system of using a Local Plan supported by the County Council’s Structure Plan.

Two very important consultation documents have been produced that aim to establish the long term planning policy vision for Worthing – The Core Strategy and Unlocking Development Potential.

What do these documents contain? The Core Strategy contains planning policies that will help to meet Worthing’s economic, social and environmental needs over the next ten years. It will encompass the key vision and strategies for Worthing that have been detailed in our Corporate Plan and the recently completed Worthing Masterplan. We want Worthing to be a distinctive, vibrant town; with a thriving Town Centre and seafront area, presenting a distinctive retail offer, modern office accommodation, a range of quality residential opportunities and a mix of excellent leisure and cultural facilities. We want to achieve the above in a sustainable, balanced and environmentally friendly way, without jeopardising the resources needed by future generations of Worthing’s residents.

The Town Centre and seafront areas provide the best opportunity to deliver the vision of the Core Strategy. It is within these areas that regeneration and new investment will be focused, because they will provide many of the development opportunities outlined above in a sustainable and deliverable manner. This would enable the whole of the Borough to benefit from any economic prosperity. Many of the sites that could provide significant development opportunities are within the Town Centre and seafront areas. We can therefore, maximise Worthing’s ability to fulfil its potential for urban renaissance and regeneration.

The Unlocking Development Potential document identifies and assesses the actual sites and proposals that could be developed to deliver the vision set out in the Core

66 Strategy. Many of you will be familiar with the sites that are in the document, such as Teville Gate, the Stagecoach bus depot, the Guildbourne Centre and the Aquarena. The Teville Gate site itself has the potential to incorporate a high quality mix of leisure activities and residential development that could form part of an overall Station Gateway area, where better transport interchanges and links to the Town Centre would make the whole area a more pleasurable and user friendly attraction for both residents and visitors.

We have also highlighted the potential to develop the area behind the Town Hall for a Cultural and Civic Hub. The area could incorporate a number of cultural and civic buildings, such as conference and concert facilities, which would front onto a new Civic Square. This would be a strategic location that could be easily accessed from the retail centre and the Station Gateway area. It would provide a visually attractive site that could be used by visitors and residents alike.

The Worthing Leisure Centre at West Park has served the community well but it could benefit from new leisure development opportunities, which in the long term could include new swimming facilities.

The above are just three of the sites identified in the UDP document. There are many more sites Borough wide that have been identified as having development potential. They cover a wide range of possible uses, from educational and community to employment and retail.

We would like to hear your views and opinions on these two documents. We want to know if you agree or disagree with the policies in them. Have we missed anything? Have you anything to add?

You can access these consultation documents from the Worthing Borough Council web-site at www.worthing.gov.uk A brief, user-friendly information leaflet and questionnaire is available in which residents can express their views.

There are public exhibition stands on display at Worthing Town Hall, the Main Library and at Portland House in Richmond Road, where you will be able to see the consultation documents and pick up a leaflet and a questionnaire.

An “Open Day” will also be held in the Gordon Room at the Town Hall on 25 October, from 09.00-17.00. You can discuss any details in the documents with planning officers from the Strategic Housing and Planning Department. Look out for our Mobile LDF Exhibition on Saturday 21 October, when we will be touring the town in a fire engine! If you require any more information you can contact the Strategic Housing and Planning Department at Portland House by calling us on 221359. The consultation period will end on Friday 3rd November 2006.

Remember – This is your chance to have your say!

67 PUBLIC NOTICE

PLANNING AND COMPULSORY PURCHASE ACT 2004

The Town and Country Planning (Local Development)(England) Regulations 2004

Notice of Pre-Submission Public Participation (Regulation 26) Statement of Proposals Matters (Regulation 26)

The Worthing Local Development Framework – draft Core Strategy Preferred Options and Draft Unlocking Development Potential – Preferred Options.

Worthing Borough Council has prepared a Draft Core Strategy-Preferred Options and a Draft Unlocking Development Potential – Preferred Options (Site Specific Allocations), as part of the new Local Development Framework (LDF) that will begin to replace the existing policies in the Worthing Local Plan 2003.

The Core Strategy - this document sets out the vision for the borough and the key policies that will help meet Worthing’s economic, social and environmental needs over the next 20 years.

The Unlocking Development Potential Document identifies and assesses the actual sites and proposals that could be developed to deliver the vision set out in the Core Strategy.

Both of these documents have been subject to a Sustainability Appraisal to ensure that they contribute to the aims of sustainable development. This document can be viewed and commented on alongside these two documents.

Copies of these documents are available for inspection at the Council Offices at Portland House in Richmond Road and at Worthing Town Hall during normal office hours from Monday 25th September 2006 to Monday 6th November 2006. Copies of these documents are also available for inspection at local libraries during the same period.

These documents can also be viewed on Worthing Borough Council’s Web-site www.worthing.gov.uk

Comments are invited on these documents. To ensure that your comments comply with statutory regulations you are requested to submit your comments either on line using our consultation system or by completing a questionnaire. The questionnaire is available on request by calling us on 221364 or e-mail [email protected].

All comments should arrive by no later than Monday 6 November 2006. Only comments accompanied with your name and contact address can be accepted. The preparation of documents for the LDF is a public process and your representations (comments) cannot be treated as confidential. By submitting a comments you are agreeing that your details (including your name and address) will be held on the Strategic housing and planning database and (along with your comments) will be made available for public viewing (name only).

You may also accompany your comments with a request to be notified that these documents (Development Plan Documents-DPD) have been submitted to the Secretary of State for independent examination (under section 20) and of the adoption of the DPD’S.

68 PREFERRED OPTIONS

In November last year we consulted on the issues and options facing the town over the next 20 years. The responses received were considered and have helped inform the Council’s preferred policy approaches to land use planning that aim to address the issues highlighted.

The Council is now out to consultation on Preferred Options, which will run for a six-week period beginning 25th September – 6th November 2006.

So what are we consulting you on?

The Preferred Options – two very important documents have been produced for consultation setting out the Council's proposed policy directions, and highlights alternatives where appropriate.

The Core Strategy - this document identifies and assesses the actual sites and proposals that could be developed to deliver the vision set out in the Core strategy.

The Unlocking Development Potential Document (Site specific allocations) identifies and assesses the actual sites and proposals that could be developed to deliver the vision set out in the Core Strategy.

Sitting alongside these two Draft Development Plan Documents is a Sustainability Appraisal this informs you how the Council has arrived at the options put forward. This is also out for consultation.

We would like to hear your views and opinions on these two documents.

All documents can be viewed via the link below :

Consultation Documents LINK http://consultation.limehouse.co.uk/index.do?identifier=worthing

For any questions please contact the Strategic Housing & Planning Group on 01903 221364 or email [email protected]

69 Appendix 2.2 - Consultation cover letters

Our Reference: CM/ CSUDP Your Reference: Direct Line; (01903) 221364

23rd September 2006 Dear Sir/Madam

Consultation on Preferred Options – Core Strategy, Unlocking Development Potential and Sustainability Appraisal

I have the pleasure of enclosing a CD which contains Worthing Borough Council’s Core Strategy and Unlocking Development Potential Preferred Options Documents, together with the Sustainability Appraisal Document. These documents are now out to public consultation. The consultation period runs from the 25th September 2006 to 6th November 2006. As a registered consultee on Worthing’s LDF database I would be grateful for your views on the enclosed documents.

There are public exhibition stands on display during the consultation period at Worthing Town Hall, the Main Library and at Portland House in Richmond Road, where you will be able to see the consultation documents and pick up a leaflet and a questionnaire. The consultation documents are also available on the Borough’s website at www.worthing.gov.uk where you will be able to make your comments on-line. Please let us know if you wish to receive a hard copy of the above documents.

All comments should be forwarded no later than 6th November 2006 to the Strategic Housing and Planning Group at the above address. Please note that representations cannot be treated as confidential as they will be made available for public viewing.

If you require any more information, you can contact the Strategic Housing and Planning Group at Portland House by calling us on 01903 221364 or e-mail us at [email protected].

Yours faithfully,

Clare Mangan Strategic Housing & Planning Manager

70

Our Reference: CM/ CSUDP Your Reference: Direct Line; (01903) 221364

23rd September 2006 Dear Sir/Madam

Consultation on Preferred Options – Core Strategy, Unlocking Development Potential and Sustainability Appraisal

As you will be aware, Worthing Borough Council is preparing a new Local Development Framework (LDF) which will guide the future development and planning within the Borough over the next decade. We have reached the Preferred Options stage on the Core Strategy and Unlocking Development Potential Documents, with consultation on these documents starting on 25th September 2006. This is an important opportunity to make your views known but your comments need to be made over a statutory period of 6 weeks from 25th September 2006 to 6th November 2006.

There will be public exhibition stands on display during the consultation period at Worthing Town Hall, the Main Library and at Portland House in Richmond Road, where you will be able to see the consultation documents and pick up a leaflet and a questionnaire. The consultation documents are also available on the Worthing Borough Council web site at www.worthing.gov.uk where you will be able to make your comments on-line. Please let us know if you wish to receive a CD or hard copy of the above documents.

All comments should be forwarded no later than 6th November 2006 to the Strategic Housing and Planning Group at the above address. Please note that representations cannot be treated as confidential as they will be made available for public viewing. If you wish your details to remain confidential please ensure that when filling out the official representation form you only disclose details you are happy to be seen in the pubic realm.

If you require any more information, you can contact the Strategic Housing and Planning Group at Portland House by calling us on 01903 221364 or e-mail us at [email protected].

Yours faithfully,

Clare Mangan Strategic Housing & Planning Manager

71 Appendix 2.3 - Open day consultation letter

Our reference: TW/LDF/PPT520. Direct Line; (01903) 221089

2006

MAKE A DATE TO HAVE YOUR SAY IN WORTHING’S FUTURE!

A SPECIAL INVITATION FOR YOU TO ATTEND AN “OPEN DAY” TO DISCUSS THE LOCAL DEVELOPMENT FRAMEWORK- CORE STRATEGY AND UNLOCKING DEVELOPMENT POTENTIAL DOCUMENT-PREFERRED OPTIONS.

Dear Consultee,

As you should hopefully be aware the existing Local Plan system is being replaced (under new Government legislation), with what is known as a Local Development Framework for Worthing (LDF). This document will establish the planning framework for the future of Worthing. The aim is to produce shorter, better-focused and more flexible plans for an area.

A number of documents have already been produced and consulted upon as part of this process, the most recent being the Core strategy and Unlocking Development Potential - Issues and Options, which was out for consultation from 28th November 2005 until 31st January 2006.

The next stage is the preparation of Preferred Options on both documents. These documents are being prepared in light of both the Issues and Options stage and various background studies. Public Consultation on the Preferred Options will be issued in September. The documents to be discussed are;

• Core Strategy DPD – Overall vision for the future development of the town and will cover a 15-year period 2008-2015.

• Unlocking Development Potential –Site allocations.

We are intending to hold an event bringing together all those with an interest in planning for Worthing's development. The event is an opportunity to learn more about the Preferred Options and make your views known.

We intend to hold an Open Day on the 25th October 2006 between 9am –5pm, the venue for the day will be the “Gordon Room” in the Town Hall. The public consultation on Preferred Options will start on the 25th September for a period of 6 weeks. The documents to be consulted upon will be available at various venues around the Borough and available to view and respond to on the council’s website www.worthing.gov.uk . You will then have the opportunity to pop in at any time during 9-5pm on the 25th October to

72 raise any questions/issues you may have with the officers from the Strategic Housing and Planning group.

The timing of the Open Day has been arranged so that you will have the time to read and consider the documents.

In order to make this event as successful and productive as possible, it would be helpful to know whether you would be interested in attending the event. It would also be helpful if you could supply us with an e-mail contact address even if you do not intend to attend, so that we can keep you updated on the progress of the LDF and any other forthcoming events that you may be interested in.

Could you please complete the attached form and return it in the envelope provided or contact Caroline Harber on 1364 or confirm your attendance via e-mail to [email protected]

Please feel free to call me if you have any queries on 01903-221089.

Thank you for cooperation.

Yours Sincerely,

Tracy Wigzell

73 Appendix 2.4 Consultation comments form

ABC

Local Development Framework

COMMENTS FORM

The consultation period on the Preferred Options Core Strategy, the Preferred Options Unlocking Development Potential and the Sustainability Appraisal runs from 25 September 2006 to the 6 November 2006 inclusive. All comments must be received by Monday 6 November 2006.

Please use a separate form for each separate policy, paragraph, or site you wish to comment on. This form can be photocopied as many times as necessary. Further forms can be obtained from the Strategic Housing & Planning Group, by telephoning 01903 221364, or you can comment online using our on online consultation system at www.worthing.gov.uk.

Please note that comments are not confidential and will be made available for public viewing.

Section A – Which document are you making comments on ?

Please complete a separate form for each separate policy, paragraph or site you wish to comment on

Which document The Core Please Unlocking Please Sustainability Please tick tick tick do you wish to Strategy Development Appraisal

comment on ? Potential

Section B – Main contact details

Title Name

Name of Organisation (if applicable)

Address

74

Postcode

Telephone inc code

Fax

Email

If you are representing someone else, please complete his or her details below:

Title Name

Name of Agent Address

Postcode Telephone Inc Code Fax

Email Address

Section C – Support or Objection

Is your comment in Support Please Objecting Please tick tick Support or Objection?

75 Section D – What are you commenting on in regard to this document? Which Policy/Proposal are you commenting on? Please include a policy paragraph, page or site reference

Office Use only

Representation number …………………………………………………..

Section E – Reasons for your support or objection

Please state clearly the reasons you are objecting or supporting this part of the document

76

If necessary please continue on a separate sheet, clearly marked with your contact details.

77 Section F – If you would like a change to the document, what would that be?

If objecting please indicate what change to the document could resolve your objection. Please attach a map (showing the site and boundaries clearly) if proposing a change to a site or suggesting a new site.

Section G – Signature and Date

Signature

Date

Please return all completed forms to:

Strategic Housing & Planning Portland House Richmond Road Worthing West Sussex BN11 1LF

No later than Monday 6 November 2006

The council will not accept your representation if it received later than this date.

78 Appendix 2.5 - Core Strategy list of statutory consultees

Contact ContactPost ContactPhone Contact ContactOrganisation ContactAddressLine1 ContactAddressLine2 ContactPostTown surname Code Number

Colette Blackett Adur District Council Civic Centre Ham Road West Sussex BN43 6PR 01273 263202 White Young Green Owen Francis Planning Ropemaker Court 12 Lower Park Bristol BS1 5BN 0117 925 4393 Doug Cramond DC Planning 39 Twemlow Avenue Poole Dorest BH14 8AL 01202 773080 Vincent Gabbe GVA Grimley 10 Stratton Street London W1J 8JR 0870 900 89 90 Nathaniel Lichfield & Daniel Lampard Partners 14 Regents Wharf All Saints Street London N1 9RL 020 7837 4477 Steve Norris GVA Grimley 10 Stratton Street London W1J 8JR 0870 900 89 90 RPS Planning, Transport & Mongezi Ndlela Environment Irwin House 118 Southwark Street London SE1 0SW 0207 928 1400 Katy Walker ATISREAL For : Royal Mail Group 90 Chancery Lane London WC2A 1EU 020 7338 4055 White Young Green Alan Jones Planning Ropemaker Court 12 Lower Park Bristol BS1 5BN 0117 925 4393 Peter Jones Turley Associates 25 Savile Row London W1S 2ES 2078514010 Cushman and Kim Webster Wakefield 43-45 Portman Square London W1A 3BG 020 7152 5806 Planning Tim Waters Persepctives 24 Bruton Place London W1J 6NE 020 7493 6008 The Development stephanie smith Planning Partnership 1 Fitzroy Square London W1T 5HE 0207 388 9559 Gill Ashworth Boyer Planning Ltd Groveland House Church Road Surrey GU20 6BT 01276 452425 Rebecca Caines RPS Planning 1st Floor West Cottons Centre London SE1 2QG 020 79398000 Richard Maile 72 Portland Road Worthing BN11 1QG 01903 231438 Craig Noel Strutt and Parker 201 High Street Lewes BN7 2NR 01273 407045 White Young Green David Lowin Planning Academy House 36 Poland Street London W1F 7LU Barton Willmore Olivia Collett Planning Partnership Beansheaf Farmhouse Bourne Close Reading RG31 7BW The Planning Bureau Alexander Bateman Limited Homelife House 26-32 Oxford Road Bournemouth BH8 8EZ 79 Core Strategy – list of general consultees

Contact Organisation ContactAddress ContactAddress ContactAddress ContactPostTown ContactPostCode ContactPhone

The Coach Hurrell Ability Housing Association House Gresham Road Staines Middlesex TW18 2AE 01784 490910 Adams Hendry Consulting Blaxland Ltd 7 St Peter Street Winchester Hampshire SO23 8BW 01962 877414 Adur, Arun & Worthing Scott PCT The Causeway Goring-by-Sea Worthing West Sussex BN12 6BT Adur, Arun & Worthing Tahzib PCT 1 The Causeway Goring by Sea Worthing West Sussex BN12 6BT 51 Fishbourne Castle Affinity Road Chichester West Sussex PO19 3HZ 01243 523263 Alliance Environment & Fidgett Planning Ltd Wharf House Wharf Road Guidlford GU1 4RP 01483 579098 Alliance Environment & Graham Planning Ltd Wharf House Wharf Road Guildford GU1 4RP 01483 579098 Alliance Environmental Wharf House, Halliday Planning Wharf Road Guidlford Surrey GU1 4RP Amicus Horizon Housing Grosvenor Green Group House 125 High Street Croydon CR0 9XP 020 8726 8828 The Corner Huskisson Angmering Parish Council House The Square Angmering, West Sussex BN16 4EA 01903 850756 Anthony Greenwood Ass Greenwood Ltd 94 The Street West Sussex BN16 3NJ 01903 859110 Railway Rippon Architectus Ltd Capella House Approach Worthing West Sussex BN11 1UR 01903 821001 30 Steyne Margaroli Ardington Hotel Ardington Hotel Gardens Worthing West Sussex BN11 3DZ 01903 230451 Arun Civic Dower Arun District Council Centre Maltravers Road Littlehampton West Sussex BN15 5LF 01903 716133

Welland Arun District Council Maltravers Road Littlehampton West Sussex BN17 5LF Association of Retired Rowley Persons over 50 11 Bath Road Worthing West Sussex BN11 3NU 01903 208243 For : Royal Mail 90 Chancery Walker ATISREAL Group Lane London WC2A 1EU 020 7338 4055 80 36 Crescent Vickers Ayres, Bright Vickers Bishopstone Road Worthing West Sussex BN11 1RL

Hill B & W Loudspeaker Dale Road Worthing West Sussex BN11 2RX Edwards B&W Group Dale Road Worthing West Sussex BN11 2BH 27-29 Barton Willmore Glasshouse Bather Partnership 6th Floor, Venture House Street London W1R 6BW 01189 430000 Barton Willmore Planning Beansheaf Collett Partnership Farmhouse Bourne Close Calcot Reading RG31 7BW Brindley Bellway Homes Bellway House London Road Merstham, Surrey RH1 3YU 01737 644911 86-95 Marine Clinch Berkeley Hotel Parade Worthing West Sussex BN11 3QD General Aviation Awareness Bloomfield Bloomfields Council 66 College Road Maidstone, Kent ME15 6SJ 01622 693237 14a Chapel Anderson Blue Arrow Ltd Road Worthing West Sussex BN11 1BJ Oligario Blue Earth Web Solutions Globe House 17 Vale Walk Findon Valley West Sussex BN14 0BS 475 Godstone Murphy Blue Sky Planning Bourne House Road Caterham CR3 0BL 01883 621057 Downlands Lee Boots The Chemist Business Park Lyons Way Worthing West Sussex BN14 9LA The Manor North Ash Road, Unknown Bovis Homes House New Ash Green Longfield Kent DA3 8HQ 01474 876200 Groveland Ashworth Boyer Planning Ltd House Church Road Windlesham Surrey GU20 6BT 01276 452425 Unit 17, Willowbrook Ball Bradley Glass Ltd Road Worthing West Sussex BN14 8NA 01903 206106 Hobden Brighton & Hove Council Kings House Grand Avenue Hove BN3 2LS 01273 292504 Sheppard British Gas Plc Aviary Court Wade Road BASINGSTOKE RG24 8GZ 01256 308803 14 Benjamin Butcher British Horse Society Road Maindbower Crawley West Sussex RH10 7QY 1 Eversholt Unknown British Rail Property Board Street LONDON NW1 2DD British Chapman Abbott Telecommunications Warren 3 Grosvenor St LONDON W1X 9FA 0207 355 1800

81 Broadwater Residents Cardownie Action Group 17 Grove Road Worthing West Sussex BN14 9DQ 7747065608 Southwark Bangle Broadway Malyan Riverside House Bridge Road London SE1 9HA Packham Burlington Hotel Marine Parade Worthing West Sussex BN11 3QL 01903 211222 70a Brighton Spratt C G Spratt Road Worthing West Sussex BN11 2EN Diment C.B.R.E Kingsley House Wimpole Street London W1G 0RE 020 7182 2369 C.P.R.E (Adur & Worthing "Sunnybrae" Coppard District) Lotts Lane Sompting Lancing West Sussex BN15 9TX 01903 753021 Waterside House, Price Cable & Wireless Post Point 14 Waterside Park Longshot Lane, Bracknell RG12 1XL 01344 713804 230 Hatfield Benner Campaign for Real Ale Road St Albans Herts AL1 4LW 01727 867201 Campaign to Protect Rural Sompting, Coppard England (Sussex) Sunnybrae Lotts lane Lancing West Sussex BN15 9TX 01825 890975 Cedar Court, 221 Parry Castlemore Hagley Road Hayley Green Halesowen, West Midlands B63 1ED 0121 585 4444 113/119 Chambers CDHA Davigdor Road Hove East Sussex BN3 1RE 01273 234285 Foster Cellnet 1 Brunel Way SLOUGH SL1 1XL 01753 564716 Central Worting Residents Lilley Association 6 Wenban Road Worthing West Sussex BN11 1HY Chyrstal Chancellors 45 High Street Odiham Hook RG29 1LF 01256 703090 17-23 The Clinch Chatsworth Hotel Chatsworth Hotel Steyne Worthing West Sussex BN11 3DU Chichester Diocesan Suite C, Rayford Maunders Housing Association Ltd House School Road Hove East Sussex BN3 5HX 01273 234284 East Pallant Morgan Chichester District Council House Chichester West Sussex PO19 1TY 61 Brighton Peters Chloe Antiques Road Worthing West Sussex BN11 3EE Thomas Chris Thomas Ltd Collingwood 2 Bell Barn Road Stoke Bishop Bristol BS9 2DA 0117 904 7235 Churches Together in Tyler Worthing 39 Sea Lane Worthing West Sussex BN12 4QD 01903 242499 Cinema Theatre Gray Association 45 Arnold Road Bow E3 4NU 020 8981 7844

82 7 Woodland Tomkins Clapham Parish Council Close Clapham West Sussex BN13 3XR 01903 871204 1 Eastwood Broadwater Melligan Cluttons Court Road Romsey SO51 8JJ 01794 522670 Field Cluttons LLP Portman House 2 Portman Street London W1H 6DU 0207 647 7146 Chatfield Compass Travel Faraday Close Worthing West Sussex BN13 3RB 01903 690025 Units 4 & 5 Teville Harrison Component Moulders Industrials Dominion Way Worthing West Sussex BN14 8NA Co-op Goldspink Co-op Superstore Superstore Newland Street Worthing West Sussex BN11 1JU Unknown Countryside Agency 20th Floor, Portland House Stag Place London SW1E 5RS 0207 932 5865 Redwood Crawley Borough Council Town Hall The Boulevard Crawley West Sussex RH10 1UZ Cushman & wakefield 43/45 Portman Crook (Healey & Baker) Square London W1A 3BG 020 7152 5164 43-45 Portman Webster Cushman and Wakefield Square London W1A 3BG 020 7152 5806 43-45 Portman Webster Cushman and Wakefield Square London W1A 3BG 020 7152 5806 Wilson House, David Wilson Homes North Heath Ind North Heath Banfield South East Est Lane Horsham RH12 5QE 01403 271002 39 Twemlow Cramond DC Planning Avenue Poole Dorest BH14 8AL 01202 773080 39 Twemlow Cramond DC Planning Avenue Poole Dorest BH14 8AL 01202 773080 Development Planning Judson Partnership 1 Fitzroy Square London W1T 5HE 020 7388 9559 136-148 Tooley Hanley Dialogue Street London SE1 2TU 0207 357 6606 Bowyer DPDS Consulting Old Bank House 5 Devizes Road Old Town, Swindon SN1 4BJ 01793 501606 East Worthing Action 22 Archibald Gregg Group Road Worthing West Sussex BN11 2SL East Worthing Action 22 Archibald Unknown Group Road Worthing West Sussex BN11 2SL Park EDF Energy Wealden House Lewes Road East Grinstead RH19 3TB 01342 413346 Beretta Elm Grove First School Elm Grove Worthing West Sussex BN11 5LQ 01903 249387 195-205 High Steaggles English Heritage Eastgate Court Street Guildford GU1 3EH 1482252052

83 1 Waterhouse Steaggles English Heritage Square London EC1N 2ST 1482252052 English Nature (Sussex & Jones Surrey Team) Phoenix House 33 North Street Lewes BN7 2PH 01273 476595 English Nature Sussex & Edwards Surrey Team Phoenix House 33 North Street Lewes East Sussex BN7 2PH 01273 476595 2nd Floor, De Groot Enterprise Centre Greenacre Court Station Road Burgess Hill West Sussex RH15 9DS Gray Environment Agency Rio House Aztec West Almondsbury Bristol BS32 4UD 08708 506506 Sussex Area Reid Environment Agency Office Saxon House Little High Street Worthing BN11 1DH 01903 703952 Winchester Environment Agency Saxon house Little High Street Worthing West Sussex BN11 1DH 01903 703957 Environment Agency Rankin (Sussex Office) Saxon House Little High Street Worthing West Sussex BN11 1DH 10 Greenland Macleod Factory Outlets Denmoss House Street London NW1 0ND 0207 428 1913 Federation of Small 2 King Edward Thornton Businesses Teville House Avenue Worthing West Sussex BN14 8DD 01903 208031 Federation of Small Frances Businesses (Sussex) Greyfriars Farm Greyfriars Lane Storrington West Sussex RH20 4HE Frost Ferring Parish Council 1 Elm Park Ferring, Worthing West Sussex BN12 5RN 01903 249449

Bland Findon Parish Council 4 Steep Lane Findon West Sussex BN14 0UF 01903 877225 Framptons Planning Cusdin Consultants Oriel House 42 North Bar Banbury Oxfordshire OX16 0TH 01295 672310

Mahon GlaxoSmithKline (Worthing office) Worthing West Sussex BN14 8QH 01903 822000 1 Walnut Tree Crow GOSE Bridge House Close Guidlford Surrey GU1 4GA 1 Walnut Treet Paine GOSE Bridge House Close Guidlford GU1 4GA 01483 882255 1 Walnut Treet Sambrook GOSE Bridge House Close Guidlford GU1 4GA Unknown Guildcare Methold House North Street, Worthing West Sussex BN11 1DU 3rd Floor Beulah Cain Guiness Trust Court Albert Road Horley, Surry RH6 7HP 01293 874203 10 Stratton 0870 900 89 Gabbe GVA Grimley Street London W1J 8JR 90 10 Stratton 0870 900 89 Norris GVA Grimley Street London W1J 8JR 90 84 100/108 Scadgell H G Scadgell Ltd Montague Street Worthing West Sussex BN11 3HG 25 Pelham Walker Hanson Square Brighton East Sussex BN1 4ET 7 - 9 St James's Wren HBF 1st Floor Byron House Street London SW1A 1DW 0207 9601625 Unknown HD Steele & Son Ltd Burfree House Teville Road Worthing West Sussex BN11 1UB Heyday Worthing 42 Gaisford Ede Friendship Centre Road Worthing West Sussex BN14 7HW 01903 602809 High Salvington Residents Povey Association 26 Furze Road Worthing West Sussex BN13 3BH 01903 267119 Highdown Copse Fox Residents Association 5 Laurel Close West Durrington Worthing, West Sussex BN13 3PY 01903 830228 Wing 1B, Federated Minshull Highways Agency House London Road Dorking RH4 1SZ 01306 87119 Wing 1B, Federated Pratt Highways Agency House London Road Dorking Surrey RH4 1SZ 4th Floor, Wing Federated Unknown Highways Agency C House London Road Dorking RH4 1SZ Tomlins BTP Hillreed Residential MRTPI Developments Hillreed House 54 Queen Street Horsham West Sussex RH13 5AD 01403 264210 Errington Home Builders Federation 4 Orchards Way Highfield Southampton Hants SO17 1RD 023 8067 1030 Childs Horsham District Council Park House North Street Horsham West Sussex RH12 1RL 01403 215100 Rowley Horsham District Council Park North North Street Horsham West Sussex RH12 1RL Unknown House of Commons Commons Office Westminster London SW1A0AA 113-119 Morris Hyde Housing/CDHA Davigdor Road Hove East Sussex BN3 1RE 01273 234234 29 Bressenden Low Hyder Consulting Place London SW1E 5DZ 5 Laburnam Tanner Ilex Conservation Group Close Ferring Worthing West Sussex BN12 5EJ 01903 502841 Potts ITPS Two Mile House Tow Mile Ash Horsham West Sussex RH13 7LA 01403 220880 Downlands Stefanski J Sainburys PLC Business Park Lyons Way Worthing West Sussex BN14 9LA Jeremy Silverthorne 15a Warwick Silverthorne Jewellery Street Worthing West Sussex BN11 3DF Turner Jones Day 21 Tudor Street London EC4Y 0DJ 020 7039 5275

85 22 Hanover Fraser Jones Lang Lasalle Square London W1A 2BN 2nd Floor, Nicholls Jubilee Community Church Colonade House High Street Worthing West Sussex BN11 1NZ Kelsey Housing 2 Perry Hall 01689 7911 Fendt Association Kelsey House Road Orpington, Kent BR6 0JJ 100 Kelsey Housing Forsythe Association 2 Perryhall Road Orpington Kent BR6 0JJ 01689 791236 Keys Keysway Ltd Arlington Avenue Worthing West Sussex Unknown Cousins Kingston Parish Council 33 The Ridings East Preston West Sussex BN16 2TW McMenemy Kingston Parish Council Foxearth Middle Way Kingston Gorse West Sussex BN16 1RY 01903 856819 180 Oxford Gleeson Lambert Smith Hampton House Street London W1D 1NN 0207 198 2001 Lancing, West Wickens Esq. Lancing Parish Council The Parish Hall South Street Sussex BN15 8AJ 01903 753355 Unit B1, Yeoman Punter Land & Brand New Homes Gate Yeoman Way Worthing West Sussex BN13 3QZ 01903 692952 Thomas Lemo (UK) Ltd 12 North Street Worthing West Sussex BN11 1DU Policy & Research Officer Levvel Leigh House, 147 Leigh Road Wimbourne Dorset BH21 2AD 01202 639444 Spicuets Lloyds TSB Registrars Ltd 3 The Causeway Durrington Worthing West Sussex BN11 6DA Winton Lloyds TSB Registrars Ltd 3 The Causeway Durrington Worthing West Sussex BN11 6DA Wise Malcolm Judd & Partners 70 High Street Chislehurst BR7 5AQ 0208 289 1800 51-59 Montague Butcher Marks & Spencers Street Worthing West Sussex BN11 3BW 10 Strand Talmage Martin & Co Parade The Strand Goring-by-Sea West Sussex BN12 6DJ 01309 700949

Grant Martlet Homes Martlet House Southern Gate Chichester Sussex PO19 8SE 01243 788950 Masjed Assalam Islamic Rahman Cultural Centre Ivy Arch Road Worthing West Sussex BN14 8BX 1 Portland Smith McGregors Square Portland Road Worthing West Sussex BN11 1QH Simpson MGM Assurance MGM house Heene Road Worthing West Sussex BN11 2DY 01903 836013 Michael Cook Associates Brooklyn Clark Ltd Chambers 11 Goring Road Worthing West Sussex BN12 4AP 01903 248777 Jones Michael Jones & Co 8 Chapel Road Worthing West Sussex BN11 1BJ Spurr Michael Spurr Consulting Thutch Cottage The Street Kent ME9 7TL

86 Hewitt Mid Sussex District Council Oaklands Oaklands Road Haywards Heath West Sussex RH16 1SS Mobile Operator 48 St Vincent Wilson Association Street Glasgow Scotland G2 5TS 0141 270 2736 34-36 Montague Pemberton Monsoon Street Worthing West Sussex BN11 3HB Mulberry Property Investment Management 8 Liverpool Coe Ltd Ground Floor Terrace Worthing West Sussex BN11 1TA 01903 232 193 Nathaniel Lichfield & 14 Regents Lampard Partners Wharf All Saints Street London N1 9RL 020 7837 4477 Denyer National Grid Co Plc PO Box 7324 Coleshill BIRMINGHAM B46 1AR 0121 7304051 NGT House, Warwick Unknown National Grid Transco Technology Park Gallows Hill Warwick CV34 6DA National Trust (Southern Arnott Region) Polesden Lacey Dorking Surrey RH5 6BD 01372 455008 Davies Natwest Bank 27 South Street Worthing West Sussex BN11 3AR Russell Road Bailey NCP Car Park Russell Road Brighton Sussex BN1 2DX 1 Eversholt Butler Network Rail Street Euston Square London NW1 2EE 020 7904 7213 Price Network Rail The Podium 1 Eversholt Road London NW1 2DN 0207 7845 821 Nicholls Nicholls PR 316 Goring Road Goring-by-Sea Worthing West Sussex BN12 4PE Littlehampton Percival Northbrook College Road Worthing West Sussex BN12 6NU Osborn Norwich Union The Warren Worthing West Sussex BN14 9QD Orange Personal LEAMINGTON Kelly Communications Aylesford House 70/72 Clarendon SPA CV32 4PE 01926 831144 Cox Osborne Homes Wray Coppice Oaks Road Reigate, Surrey RH2 0LE 01737 223366 Palmer Palmer Business & Media 17 Thorn Road Worthing West Sussex BN11 3ND Brightmore Parexel MMS Wicker House High Street Worthing West Sussex BN11 1DJ 01903 288000 Green Oak Coldharbour Metcalfe Patching Parish Council House Lane Patching West Sussex BN13 3XE

Sockett Paul & company Riverview Court Castlegate Wetherby LS22 6LE 01937 547 880 Suite 2a, Unknown Peacock & Smith Josephs Well Hanover Walk Leeds LS3 1AB 0113 2431919 Persimmon Homes (south 100 Wickham Bedford Coast) Ltd Road Fareham Hants PO16 7HT 01329 514310 87 Waters Planning Persepctives 24 Bruton Place London W1J 6NE 020 7493 6008 Westwood Whale Powergen Westwood Way Business Park COVENTRY CV4 8LG 01203 424000 Goring Business Lovatt QS Plc Park Woods Way Goring by Sea West Sussex BN12 4QY 01903 507444 Saville Quest Adventure 5 Ardsheal Road Broadwater Worthing West Sussex BN14 7RN Hollywood R W Hilder & Co Columbia House Columbia Drive Worthing West Sussex BN13 3HD 01903 632952 18 Chancton Thomson RAG View Road Worthing West Sussex BN11 5JR Walker Raglan HA 68 Victoria Road Horley West Sussex RH6 7PZ 01293 776394 Banks Railtrack plc Railtrack House Euston Square LONDON NW1 2EE 0207 557 8901 Thatcher Rapleys LLP Maddox House 1 Maddox Street London W1S 2PZ 020 7255 8071 Red Square Developments Longbottom Ltd 33 Bruton Street London W1J 6QU Redrow House, Redrow Homes Southern Faraday Office Tarvit Ltd Park Faraday Road Basingstoke RG24 8QQ 01256 366950 31 Shepherds Aldridge Resident Mead Worthing West Sussex BN14 0HZ 43 Rackham Allen Resident Road Worthing West Sussex BN13 1LW 01903 532388 Alsawaf Resident 3 Linton House 1 Belsize Road Worthing West Sussex BN11 4RG 7074207020 5 King Edward Baker Resident Avenue Worthing West Sussex BN14 8DB Baker Resident 19 Rusper Road Worthing West Sussex BN13 1LP 18 Seamill Park Berry Resident Avenue Worthing West Sussex BN11 2PU 59 Offington Biddle Resident Avenue Worthing West Sussex BN14 9PJ Bradley Resident Rock Place Farm Rock Road Washington West Sussex RH20 3BQ 01903 893192 3 Arlington Burns Resident Avenue Worthing West Sussex BN2 4SX Church Resident 7 Valley Gardens Worthing West Sussex BN14 0JJ Clarke Resident 7 Church Walk Worthing West Sussex BN11 2LS 01903 214730 27 Bolsover Cook Resident Road Worthing West Sussex BN13 1NR 39 Downlands Curd Resident Avenue Worthing West Sussex BN14 9HD 01903 231706 41 Wenban Dhajan Resident Road Worthing West Sussex BN11 1HY 88 Flat 51, Homesearle Futcher Resident House 225 Goring Road Worthing West Sussex BN12 4PW Griffiths Resident 1 High Beeches Downview Road Worthing West Sussex BN11 4QR 01903 244579 Groves Resident 17 Welland Road Durrington BN13 3LN 11 Cambridge Hall Resident Road Worthing West Sussex BN11 1XD 1903526817 Hayes Resident Cherry Gates 24 Elm Avenue East Preston West Sussex BN16 1HL 01903 783530 Hennings Resident 50 First Avenue Worthing West Sussex BN14 9NP Hennings Resident 50 First Avenue Worthing West Sussex BN14 9NP 24 Cleveland Hills Resident Road Lower Salvington Worthing West Sussex BN13 2ET Hutchinson Resident 9 Marine Close Worthing West Sussex BN11 5DG 58 Chippers Jeffries Resident Road Tarring Worthing West Sussex BN13 1DG Jones Resident 51 Reigate Road Worthing West Sussex BN11 5NE Jupp Resident 34 Adur Avenue Worthing West Sussex BN13 3LF 19c St Botolphs Keiley Resident Road Worthing West Sussex BN11 4JP Khan Resident 21 Lennox Road Worthing West Sussex BN11 1DD Lessing Resident 4A Evelyn Road Broadwater Worthing West Sussex BN14 8AY Lester Resident 5 Church Walk Worthing West Sussex BN11 2LS 27 West Park Moon Resident Lane Worthing West Sussex BN12 4EP 14 Meadow Murphy Resident Court Meadow Road Worthing West Sussex BN11 2SJ Norman Resident 5 Exmoor Drive Worthing West Sussex BN13 2PH Norman Resident 5 Exmoor Drive Worthing West Sussex BN13 2PH Parker Resident 55 London Street Worthing West Sussex BN11 4EL 01903 230320 14 Balcombe Parker Resident Court West parade Worthing West Sussex BN11 3PL 41 South Farm Percival Resident Road Worthing West Sussex BN14 7AF 141 South Farm Percival Resident Road Worthing West Sussex BN14 7AF 48 St Lawrence Powell Resident Avenue Worthing West Sussex BN14 7JG 01903 200575 Rawkins Resident 16 Church Way West Tarring Worthing BN13 1HD 19 Acacia Rayner Resident Avenue Worthing BN13 2JB 89 Seymour Resident 46 First Avenue Worthing West Sussex BN14 9NP 01903 232729 80 Offington Shaddick Resident Lane Worthing West Sussex BN14 9RS 01903 263341 7A Tennyson Shaw Resident Road Worthing West Sussex BN11 3BY 01903 231096 3 Pevensey Sinden Resident Road Worthing West Sussex BN11 5EP Sobrido Heselton Resident 3 Halsbury Close Worthing West Sussex BN11 2JW 7 Highgrove Sparksman Resident Gardens Worthing West Sussex BN11 4SN 01903 217157 67 Orchard Stone Resident Avenue Worthing West Sussex BN14 7QB 5 Laburnum Tanner Resident Close Ferring Worthing West Sussex BN12 5EJ 01903 502841 Tanner Resident Ferring Worthing West Sussex BN12 5EJ 01903 502841 Taylor Resident 6 The Lychgate Arundel West Sussex BN18 0TN Flat 1, Homesearle Taylor Resident House 225 Goring Road Worthing West Sussex BN12 4PW 52 Gratwicke Thomas Resident Road Worthing West Sussex BN11 4BH 01903 201784 Uddin Resident 42 Goring Road Worthing West Sussex BN12 4AD 9/11 Cobden Usher Resident Flat 4 Road Worthing West Sussex BN11 4BD Flat 12, Bradley Walters Resident House Heene Road Worthing West Sussex BN11 4PF 01903 213747 72 Richmond Woollard Resident Flat 2 Road Worthing West Sussex BN11 4AF 07812 572444 Richards Retired 2 Beach House Brighton Road Worthing West Sussex Bn11 2EJ 01903 214519 10 Freshfields Foregard RF Financial Services Drive Lancing Worthing West Sussex BN15 9LN 01903 751913 17/19 Buckingham Cheal Roffey Homes Road Worthing West Sussex BN11 1TH 01903 202133 Roger Green Sound & 77 Rowlands Green Vision Road Worthing West Sussex BN11 3JN Littlehampton Matthews Rose Willmot Y.C Road Durrington West Sussex BN13 1RB 01903 529922

90 Royal Comm on Historic Recording 24 Brooklands Everson Monuments of England Section Avenue CAMBRIDGE CB2 2BU Caines RPS Planning 1st Floor West Cottons Centre Cottons Lane London SE1 2QG 020 79398000 RPS Planning, Transport & 118 Southwark Ndlela Environment Irwin House Street London SE1 0SW 0207 928 1400 Sapphire Primary Care Walsgrave 012476 Green Developments Sapphire Court Triangle Coventry CU2 2TX 432709 Jones Saville Jones Architects 74 Victoria Road Worthing West Sussex BN11 1UN Saywell Saywell International Aviation House` Woods Way Goring-by-Sea West Sussex BN12 4QY Unknown Scottish Power Hawbank House College Milton EAST KILBRIDE G74 5EG 0141 568 2000 SE England Regional 1 Walnut Tree Bevan Assembly Bridge House Close GUILDFORD GU1 4GA 01483 882310 SE Regional Transport 375 Kensington Unknown Authority Charles House High Street London W14 8QH Sheppard Second Site Property Aviary Court Wade Road Basingstoke RG24 8GZ 01256 308703 Asset Park Seeboard plc Management Russell Way CRAWLEY RH10 1UL 01293 565333 Griffin SEEDA Cross Lanes Guidlford Surrey GU1 1YA 01483 470197 Hudson SEEDA Headquarters Cross Lanes Guidlford Surrey GU1 1YA 1483484200 Gwillam SEERA Berkeley House Cross Lane Guidlford Surrey GU1 1UN 01483 555200 Beard Servite Houses Toddington Lane Littlehampton West Sussex BN17 7PP 01903 734339 Wood Servite Houses Toddington Lane Littlehampton West Sussex BN17 7PP 01903 738376 41 Clarence Hennigan Showmens Guild of GB Guild House Street Staines Middlesex TW18 4SY 01784 455120 102-108 Brighton Zoutewelle SJ Masters Road Worthing West Sussex BN11 2EN South Broadwater C/O 120 Nicholls Residents Association Northcourt Road Worthing West Sussex BN14 7DU 01903 520382 Victorian South Downs Joint The Victorian Business Centre, Small Committee Barn Ford Lane Ford, Nr Arundel West Sussex BN18 0EF 01243 558708 Station Road, Derham South Downs Society 2 Swan Court Pulborough West Sussex Pulborough RH20 1RL 01798 875073 Pounder Regional Assembly Berkeley House Cross Lanes Guidlford Surrey GU1 1UN 01483 555200 Unknown South East Water 3 Church Road Haywards Heath West Sussex RH16 3NY 26-28 Go-Ahead Addiscombe Borgars Southern House Road Croydon CR9 5GA 020 8929 8675

91 Unit 7, The Green Southern Horizon Pavilions Brighton Road Pease Pottage, Crawley RH11 9BD 08450 700 961 Hills Southern Housing Group 9 Denne Parade Horsham West Sussex RH12 1JW 01403 269131 Douglas Southern Water Southern House Sparrowgrove OTTERBOURNE HAMPSHIRE SO21 2SW 01962 716153 Kneale Southern Water Southern House Yeoman Road Worthing West Sussex BN13 3NX 01903 272229 Solbra Southern Water Southern House Yeoman Road Worthing West Sussex BN13 3NX 01903 272637 Williams Southern Water Southern House Yeoman Road Worthing West Sussex BN13 3NX 52 Richmond Haulkham Spofforths Road Worthing West Sussex BN11 1PR 51a Church Anson Sport England Street Caversham Reading RG4 8AX 0779 934 8202 1st Floor, Tudor Powell Spring Marketing Buildings 7 Ogginton Lane Worthing West Sussex BN14 9RY Spring Marketing 17-19 Goring Stannard Communications Ltd Caravelle House Road Worthing West Sussex BN12 4AP 0845 309 1122 Spring Urban 221 Hagley Hagley Green, White Regeneration Cedar Court Road Halesowen West Midlands B63 1ED 0121 585 4422 Dyer Stagecoach (South) Bus Station Chichester West Sussex PO19 2DQ 01243 536161 2nd Floor, Lewis Startup Co Greenacre Court Station Road Burgess Hill West Sussex RH15 9DS 01444 259259 Southdownview Steele Steeles of Worthing Way Worthing West Sussex BN14 8NL 01903 237527 8 Westville Unknown Stewart & Roth Avenue Ickley Moor West Yorkshire LS29 9AH 01943 604561 6 Liverpool Holder Stiles Harold Williams 1st Floor Terrace Worthing West Sussex BN11 1TA Baker Strutt & Parker 201 High Street Lewes BN7 2NR 01273 407027 Noel Strutt and Parker 201 High Street Lewes BN7 2NR 01273 407045 Surrey Sussex Strategic 18-20 Massetts Unknown Health Authority York House Road Horley Surrey RH6 7DE 01293 778899 Victorian Barn, Sussex Downs Victorian Beaton Conservation Board Business Centre Ford Lane Ford, Arundel West Sussex BN18 0EF 01243 558708 Victorian Barn, Sussex Downs Joint Victorian Small Committee Business Centre, Ford Lane, Ford Arundel West Sussex BN18 0EF Cadman Sussex Enterprise Greenacre Court Station Road Burgess Hill, West Sussex RH15 9DS 01444 259142 Cadman Sussex Enterprise Greenacre Court Station Road Burgess Hill RH15 9DS 01444 259259 Cadman Sussex Enterprise Greenacre Court Station Road Burgess Hill RH15 9Ds 01444 259259 92 Froud Sussex Enterprise Greenacre Court Station Road Burgess Hill, West Sussex RH15 9DS 01444 259142 Sussex Learning & Skills Ball Council Princes House 53 Queens Road Brighton East Sussex BN1 3XB Sussex Ornithological Hobson Society 23 Hillside Road Storrington West Sussex RH20 3LZ 21 Chatsworth Rowe Sussex Police Road Worthing West Sussex BN11 1NA Hyatt Sussex Wildlife Trust Woods Mill Henfield West Sussex BN5 9SD 01273 497552 Watson Sussex Wildlife Trust Woods Mill Henfield West Sussex BN5 9SD 01273 497552 39-41 Surrey Beth Sustrans Street Brighton East Sussex BN1 3PB 01273 766656 39-41 Surrey Coote Sustrans Street Brighton BN1 3PB Tarring Residents Thorpe Association C/O Town Hall Chapel Road Worthing West Sussex BN11 1LF Ashworth Tesco New Road Durrington Worthing West Sussex BN13 3PB Scanlan Tetlow King Planning 32 High Street West Malling Kent ME19 6QR 01732 870988 1 Kew Bridge Unknown Thames Water Utilities Ltd Thames Water Road Brentoford Middlesex TW8 0EF Historic Shaw The Architecture Centre Dockyard Chatham Kent ME4 4TZ 01634 401166 Holden The Argus & The Sentinel 35 Chapel Road Worthing West Sussex BN11 1EG Euro House, 3 Cotterell The Aspaleia Project Teville Place Worthing West Sussex BN11 1UQ 14 Benjamin Butcher The British Horse Society Road Maidenbower Crawley, West Sussex RH10 7QY 01293 886446 The British Wind Energy Renewable Dodds Association Energy House 1Aztec Row Berners Road London N1 0PW 020 7689 1960 Planning The British Wind Energy Advisor Association 1 Aztec Row Berners Road London N1 0PW 020 7689 1960 Ball The Brunswick Thorn Road Worthing West Sussex BN11 3ND Packham The Burlington Hotel Marine Parade Worthing West Sussex BN11 3QL New Centuary Watts The Co-Operative Society Po Box 53 House Manchester M60 4ES Delcroix The Countryside Agency Sterling House 7 Ashford Road Maidstone Kent ME14 5BJ 01622 765 222 The Development Planning smith Partnership 1 Fitzroy Square London W1T 5HE 0207 388 9559 The Worthing 22 Marine Stennet The Dome Trust Dome Parade Worthing West Sussex BN11 3PT

93 50 Charmandean Fadoju The Elim Church Road Worthing West Sussex BN14 9NA Sussex Area Winchester The Environment Agency Office Saxon House Little High Street Worthing BN11 1DH The Horizon Housing Grosvenor Green Group House 125 High Street Croydon CR0 9XP 020 8726 8828 The Planning Bureau 26-32 Oxford Bateman Limited Homelife House Road Bournemouth BH8 8EZ The Planning Bureau 26-32 Oxford Thompson Limited Homelife House Road Bournmouth, Dorset BH8 8EZ 01202 291455 Rm 325, Eagle Temple Quay 2 The Square, Huntbach The Planning Inspectorate Wing House Temple Quay Bristol BS1 6PN The Village Ennis The Property Doctor Estate Agency Salvington Hill Worthing West Sussex BN13 3BE 3 Windermere Malone The Worthing Society Crescent Worthing BN12 6Jy 22 Charing Freeman Theatres Trust Cross Road London WC2 0QL 020 7836 8591 Sykes THT South 61 Ship Street Brighton East Sussex BN1 1AE 17 Liverpool Miller Tod Miller Thomas Gardens Worthing West Sussex BN11 1RY 01903 217887 Meredith Transco South East Ldz 2 Leesons Hill ORPINGTON BR5 2TN Hobbs Tribal MJP 70 High Street Chiselhurst Kent BR7 5AQ 02082 891800 Billings Turley Associates 25 Saville Row London W1S 2ES 020 7851 4010 Jones Turley Associates 25 Saville Row London W12 2ES 0207 851 4010 Jones Turley Associates 25 Savile Row London W1S 2ES 2078514010 9 Westbrook Glover Two Below Zero Court Crescent Road Worthing West Sussex BN11 1RG 0845 450 3693 Gunning- Stevenson Waitrose High Street Worthing West Sussex BN11 1LL West Sussex County Cousins Council The Grange Tower House Chichester West Sussex PO19 1RH 01243 756612 West Sussex Economic Smith Partnership 4 The Chambers Chapel Street Chichester West Sussex PO19 1DL West Sussex Fire & Barraclough Rescue Service Ardsheal Road Worthing West Sussex BN14 7RN 04903 228411 Blundell West Sussex Gazette Unicorn House Eastgate Square Chichester West Sussex PO19 1JN West Sussex Learning Southfields Liverpool Tame Partnership House Gardens Worthing West Sussex BN11 1RY 94 Westbury Homes Hull (Holdings) Ltd Bartley House Station Road Hook, Hamps RG27 9PE 01256 744000 60 East St Helen Butterworth Westwaddy ADP The Malthouse Street Abingdon OX14 5EB 01235 523139 White Young Green Ropemaker Francis Planning Court 12 Lower Park Bristol BS1 5BN 0117 925 4393 White Young Green Ropemaker Jones Planning Court 12 Lower Park Bristol BS1 5BN 0117 925 4393 White Young Green Lowin Planning Academy House 36 Poland Street London W1F 7LU JK House, PO Roebuck Way, Pope Wilkinson BOX 20 Manton Wood Worksop Nottinghamshire S80 3YY Nabb Women's Aid PO Box 4127 Worthing West Sussex BN11 1AF Leamington on Bicknell Wood Frampton Aylesford House 70/72 Clarendon Spa CV32 4PE 01926 831144 33/35 Montague Elliott Woolworths Street Worthing West Sussex BN11 3BJ Dove Lodge, 49 Thomas Workability West Sussex Beach Road Littlehampton West Sussex BN17 5JG Homefield, Worthing & Southlands Worthing Gallagher NHS Trust Hospital Lyndhurst Road Worthing West Sussex BN11 2DH 01903 285196 Worthing & Southlands Worrthing Smith NHS Trust Hospital Lyndhurst Road Worthing West Sussex BN11 2DH 01903 285103 Worthing Access & Mobility 28 Hillside Fisher Group Avenue Worthing West Sussex BN14 9QS 01903 233472 Worthing Astrological 101 Ardingly Boots Society Drive Goring by Sea Worthing West Sussex BN12 4TW 01903 505346 Barlow Worthing Borough Council Town Hall Chapel Road Worthing West Sussex BN11 1HA Roberts Worthing Borough Council 6 Shelley Road Worthing West Sussex BN11 1HA 01903 535356 Smytherman Worthing Borough Council Town Hall Chapel Road Worthing West Sussex BN11 1HA Thorpe Worthing Borough Council The Town Hall Worthing West Sussex BN11 1HA Worthing Branch 54 Edmonton Gatford Disabilities Network Road Durrington West Sussex BN13 2TB Worthing Branch 54 Edmonton Unknown Disabilities Network Road Durrington Worthing West Sussex BN13 2TB Worthing Chamber of 7 Richmond Tilley Commerce Road Worthing West Sussex BN11 1PN 01903 203484 Worthing Chamber of 7 Richmond Skerratt Trade and Commerce Road Worthing West Sussex BN11 1PN 95 Worthing Churches Chasteauneuf Homeless 5 Byron Road Worthing West Sussex BN11 3HN Worthing Churches Tyler Together 39 Sea Lane Goring Worthing West Sussex BN12 4QD Worthing Citizens Advice Chapman Bureau 11 North Street Worthing West Sussex BN11 1DU 01903 532662 Worthing Community Arts Hutchinson Council 9 Marine Close Worthing West Sussex BN11 5DG Worthing Community Claxton Partnership Town Hall Bognor Regis West Sussex PO21 1LD Worthing Community Unknown partnership Town Hall Clarence Road Bognor Regis West Sussex PO21 1LD Worthing Council for Colonnade 01903 Carette Volunatary Service House Warwick Street Worthing West Sussex BN11 3DH 528620/619 Worthing Council of 16 Ashwood Richardson Community Associations Close Worthing West Sussex BN11 2AF Worthing Council of 16 Ashwood Unknown Community Associations Close Worthing West Sussex BN11 2AF Worthing Disability 9 Centre Court Unknown Network Road Worthing West Sussex BN14 7AH Palmer Worthing First 17 Thorn Road Worthing West Sussex BN11 3ND 01903 520990 Worthing Chatsworth Buss Herald/Guardian/Advertiser Cannon House Road Worthing West Sussex BN11 1NA Evans Worthing Homes Limited Davison House North Street Worthing West Sussex BN11 1ER 11 Columbia Burgh Worthing Islamic Society Drive Worthing West Sussex BN13 2TH 01903 693608 Worthing Liberal Democrat Smytherman Group 7 Willow House Goring Chase The Strand Worthing BN12 6NS 01903 507073 8-10 Durrington Sola Worthing MIND Lane Worthing West Sussex BN13 2QB Brooklyn Etter Worthing Plus Chambers 11 Goring Road Worthing West Sussex BN12 4AP Lilley Worthing Residents Ass 6 Wemban Road Worthing West Sussex BN11 1HY Malone Worthing Society C/O 3 Ilex Way Worthing West Sussex BN12 4UZ 01903 246486 Worthing Society for the 75 Richmond Baker Blind Road Worthing West Sussex BN11 4AQ Worthing Squares Dance Lovelady Group Green Gables 33 Harvery Road Goring by Sea West Sussex BN12 4DS 01903 505328 Worthing Town Centre 7 Richmond Clarke Initiative Road Worthing West Sussex BN11 1PN 01903 203252 96 Cooper WSCC The Grange Tower Street Chichester West Sussex PO19 1RH Crank WSCC The Grange Tower Street Chichester West Sussex PO19 1RH Transport & The Grange, Downy WSCC Planning Group Tower Street Chichester West Sussex PO19 1RH Kendall WSCC Room 101 County Hall Chichester West Sussex PO19 1RH Wells WSCC The Grange Tower Road Chichester West Sussex PO19 1RH Winch WSCC The Grange Tower Street Chichester West Sussex PO19 1RH 01243 642105 Robinson- The Place Youth Viney Youth Council Café 24 Marine Place Worthing West Sussex BN11 3DN 07736 007570 Andrews 3 Rees Close Durrington Worthing West Sussex Unknown Arrowsmith Unknown Unknown Unknown Carisbrooke Attree 10 Eriskay Court Drive Durrington West Sussex BN13 3RH Ball Unknown Unknown Unknown Unknown Ball Unknown Unknown Unknown Ashburnham Barber 3 Penhurst Court Close Durrington West Sussex Unknown 14 Sompting Barlow Avenue Worthing West Sussex BN14 8HN 14 Sompting Barlow Avenue Worthing West Sussex BN14 8HN 39 Downlands Battson Avenue Worthing West Sussex BN14 9HD 0845 456 0177 55 St Thomas Beal Road Worthing West Sussex Unknown Beal 32 Twitten Way Worthing West Sussex BN14 7JX 11 Terringes Beckley Avenue Worthing West Sussex BN13 1HX Roundstone Bilotti Harley Bungalow Lane Angmering Littlehampton BN16 4AT Roundstone Bilotti New House Lane Angmering West Sussex BN16 4AT BinksFSE Peng FRSH MIOSH FIIE 10 Selkirk Close Worthing West Sussex BN13 1PR 01903 241245 Boaut 67 Ashacre Lane Worthing West Sussex BN13 2DH 7 Cumberland Carpenter Avenue Worthing West Sussex BN12 6JX 31 Sunningdale Carter Road Worthing West Sussex Unknown 97 59 Mulberry Cheesman Lane Goring by Sea Worthing West Sussex BN12 4RA 59 Mulberry Chesseman Lane Goring by Sea Worthing West Sussex BN12 4RA 3A Abbotts Chittenden Close Worthing West Sussex BN11 1JB 01903 200717 Clarke 9 Alder Close Durrington Worthing West Sussex Unknown 12 Chestnut Connolly Walk Worthing West Sussex BN13 3QL 12 Chestnut Connolly Walk Durrington Worthing West Sussex Unknown 12 Chestnut Conolly Walk Durrington Worthing West Sussex BN13 3QL 21 Highclere Cooper Way Worthing West Sussex Unknown Dorin Beauly Waltham, St Lawrence Readng RG10 0JP 0118 934 9334 22 Chesham Field Close Goring by Sea Worthing West Sussex Unknown 27 Gainsborough Francis Avenue Worthing West Sussex BN14 8QR 27 Gainsborough Francis Avenue Worthing West Sussex BN14 8QR 31 Winchester Francis Flat 1 Road Worthing West Sussex BN11 4DH 16 Winterbourne Hall Close Durrington Worthing West Sussex Unknown 40 Greenland Hammond Road Durrington Worthing West Sussex BN13 2RW 40 Greenland Hammond Road Durrington Worthing West Sussex BN13 2RW 47 Half Moon Hammond Corner Cottage Lane Worthing West Sussex BN13 2EP 47 Half Moon Hammond Corner Cottage Lane Worthing West Sussex BN13 2EP Hammond 1 Laurel Close Durrington Worthing West Sussex BN13 3PY Hammond 1 Laurel Close Highdown Copse Worthing West Sussex BN13 3PY Hammond 1 Laurel Close Highdown Copse Worthing West Sussex BN13 3PY Hammond 1 Laurel Close Highdown Copse Worthing West Sussex BN13 3PY 47 Half Moon Hammond Corner Cottage Lane Worthing West Sussex BN13 2EP 98 Hammond 1 Laurel Close Highdown Copse Worthing West Sussex BN13 3PY 35 Squadron Hughes Drive Durrington Worthing West Sussex Unknown 115 Offington Ivey Lane Worthing West Sussex Unknown 161 George V Johnstone Avenue Worthing West Sussex Unknown 41 Cleveland Knappitt Road Worthing West Sussex BN13 2ES Langley 27 Birkdale Road Worthing West Sussex Unknown 4 Whylands Louering Avenue Worthing West Sussex BN13 3HG 4 Whylands Lovering Avenue Worthing West Sussex BN13 3HG 01903 600961 4 Whylands Lovering Avenue Worthing West Sussex BN13 3HG 01903 600961 4 Whylands Lovering Avenue Worthing West Sussex BN13 3HG 01903 600961 46 Upper High MacDonald Street Worthing West Sussex Unknown 72 Portland Maile Road Worthing BN11 1QG 01903 231438 72 Portland Maile Road Worthing BN11 1QG 01903 231438 8 withdean malyon avenue goring by sea worthing bn12 4xd 01903 530446 Martin Trouts Oak Greenhurst Lane Thakeham West Sussex RH20 3HA 37 Eastcourt Nathan Road Worthing West Sussex BN14 7DA 01903 605799 44 Whitebeam Newman Road Worthing West Sussex Unknown Piatt 6 Brooklands Shoreham West Sussex Unknown 28 Orchard Prentice Avenue Worthing West Sussex BN14 7PY 80 George V Price Avenue Worthing West Sussex BN11 5RN 01903 249042 Pullen 27 Birkdale Road Worthing West Sussex Unknown 1 Woodmancote Randall Road Worthing West Sussex BN14 7HT 01903 200569

99 1 Woodmancote Randall Road Worthing West Sussex BN14 7HT 01903 200569 19 Acacia Raynor Avenue Worthing West Sussex BN13 2JB 10 Ontario Rivett Gardens Worthing West Sussex BN13 2RZ Russell Sandown 2 Selhurst Close East Preston Littlehampton BN16 2SR 01903 785282 Russell 2 Selhurst Close East Preston Littlehampton West Sussex BN16 2SR 01903 785282 2 Gatcombe Samain Close Durrington Worthing West Sussex Unknown 2 Gatcombe Samain Close Durrington Worthing West Sussex Unknown 67 Greenland Samuelson Road Worthing West Sussex Unknown 51 Alinora Sankey Avenue Goring By Sea Worthing BN12 4LY 01903 243569 Seierland 6 Rees Close Worthing West Sussex Unknown 16 Salvington Spear Hill Worthing West Sussex Unknown 29 Fernhurst Stacy Drive Worthing BN12 5AU Stafford 17 Falmer Close Goring by Sea Worthing West Sussex BN12 4TB 01903 243180 18 Raleigh Stephenson Crescent Worthing West Sussex BN12 6EF 12 Squadron Stevens Drive Durrington Worthing West Sussex Unknown 129 Ardingly Thomas Drive Goring by Sea Worthing West Sussex BN12 4TW 01903 620520 129 Ardingly Thomas Drive Goring by Sea Worthing West Sussex BN12 4TW 01903 620520 Took 36 Robson Road Goring by Sea Worthing West Sussex Unknown 36 Bridgnorth Underdown Close Durrington Worthing West Sussex Unknown 31 Winchester Unknown.... Flat 1 Road Worthing West Sussex BN11 4DH Wallinger 1 Lodda Close Durrington Worthing West Sussex Unknown No address Weeks supplied Worthing N/A 9 Swallows Whittington Green Drive Worthing West Sussex BN13 2TS 100 Appendix 2.6 – List of respondents to Core Strategy

ContactOrganisation FirstName LastName Town PhoneNumber

Amicus Horizon Housing Group Amanda Green Croydon 020 8726 8828 Barton Willmore Planning Partnership Olivia Collett Reading

Boyer Planning Ltd Gill Ashworth Surrey 01276 452425

British Horse Society Patricia Butcher West Sussex

Cushman and Wakefield Kim Webster London 020 7152 5806

DC Planning Doug Cramond Dorest 01202 773080

Environment Agency Amy Reid Worthing 01903 703952

Ferring Parish Council R W Frost West Sussex 01903 249449

GOSE David Paine Guidlford 01483 882255

HBF Bartholomew Wren London 0207 9601625

Highways Agency Margaret Pratt Surrey

Kingston Parish Council V Cousins West Sussex

Nathaniel Lichfield & Partners Daniel Lampard London 020 7837 4477

Planning Persepctives Tim Waters London 020 7493 6008

Resident L Sobrido Heselton West Sussex

Resident Angela Rawkins Worthing

101 Resident S.A. Groves Durrington

Resident Andrew Rayner Worthing

Resident Vivian John Seymour West Sussex 01903 232729

Retired Barry Richards West Sussex 01903 214519

RPS Planning Rebecca Caines London 020 79398000

SEEDA Jane Griffin Surrey 01483 470197

SEERA Mike Gwillam Surrey 01483 555200

Servite Houses Steven Beard West Sussex 01903 734339 South Broadwater Residents Association Tim Nicholls West Sussex 01903 520382 South Downs Joint Committee Martin Small West Sussex 01243 558708

Southern Water Susan Solbra West Sussex 01903 272637

Sport England Mick Anson Reading 0779 934 8202

Strutt and Parker Craig Noel Lewes 01273 407045

Sussex Enterprise Mark Froud West Sussex 01444 259142

Sussex Wildlife Trust Janyis Watson West Sussex 01273 497552

Sustrans John Coote Brighton

The British Horse Society Patricia Butcher West Sussex 01293 886446

The Co-Operative Society Emily Watts Manchester

102 The Development Planning Partnership stephanie smith London 0207 388 9559

The Planning Bureau Limited Alexander Bateman Bournemouth

The Worthing Society Tony Malone Worthing

Theatres Trust Rose Freeman London 020 7836 8591

Turley Associates Peter Jones London 2078514010

West Sussex County Council Chris Cousins West Sussex 01243 756612

White Young Green Planning David Lowin London Worthing Access & Mobility Group Norah Fisher West Sussex 01903 233472

Worthing Astrological Society G L Boots West Sussex 01903 505346 Worthing Liberal Democrat Group Bob Smytherman Worthing 01903 507073

Worthing Residents Ass V Lilley West Sussex Worthing Town Centre Initiative Sharon Clarke West Sussex 01903 203252

Richard Maile Worthing 01903 231438

Richard Maile Worthing 01903 231438

A Hammond West Sussex

Andrew Weeks Worthing

Adele Hammond West Sussex

A J Stacy Worthing

103 Alex Ball Unknown

Alistair Simon Beal West Sussex

Amanda Samain West Sussex

Amelia Hammond West Sussex

Annunziata Nancy Bilotti West Sussex

Ashley Martin West Sussex

C Carter West Sussex

Catherine Barlow West Sussex

Charlie Lovering West Sussex 01903 600961

Cheryl Lovering West Sussex 01903 600961

Chris Field West Sussex

Clare Ball Unknown

Colin Knappitt West Sussex

D Seierland West Sussex

Daniel Hammond West Sussex

Denham Thomas West Sussex 01903 620520

Dorian Hammond West Sussex

Elaine Russell West Sussex 01903 785282

104 Emily Hughes West Sussex

Emily Johnstone West Sussex

Emma Stevens West Sussex

Fin MacDonald West Sussex

G Spear West Sussex

Gill Chittenden West Sussex 01903 200717

Heike Beal West Sussex

Helen Hammond West Sussex

Ian Cheesman West Sussex

Ian Samain West Sussex

J Cooper West Sussex

Jacqueline Beckley West Sussex

Jemma Louering West Sussex

Joanna Chesseman West Sussex

John Randall West Sussex 01903 200569

John Russell Littlehampton 01903 785282

Julie Ivey West Sussex

L Langley West Sussex

105 Lisa Francis West Sussex

M Carpenter West Sussex

M Wallinger West Sussex

Maryanne Hall West Sussex

Jenny Attree West Sussex

L S Stephenson West Sussex

R Rivett West Sussex

D A Connolly West Sussex

J Connolly West Sussex

P Francis West Sussex

P Hammond West Sussex

B Raynor West Sussex

Jane Whittington West Sussex

M.M. Hammond West Sussex

Pamela Conolly West Sussex

R A Francis West Sussex

R A Prentice West Sussex

Susan Boaut West Sussex

106 B.A Hammond West Sussex

Natasha Clarke West Sussex

P Newman West Sussex

Peter Stafford West Sussex 01903 243180

Petula Randall West Sussex 01903 200569

Pia Samuelson West Sussex

P Sankey Worthing 01903 243569 unknown Unknown.... West Sussex

E Hammond West Sussex

Richard Battson West Sussex 0845 456 0177

Ros Piatt West Sussex

Ruth Nathan West Sussex 01903 605799

S Pullen West Sussex

Simon Lovering West Sussex 01903 600961

T Andrews West Sussex

Teresa Arrowsmith Unknown

Tina Bilotti Littlehampton

Tina Underdown West Sussex

107 Took West Sussex

Victoria Barlow West Sussex

Yvette Thomas West Sussex 01903 620520

Zoe Barber West Sussex

Appendix 2.7 List of respondents – Sustainability Appraisal

Name Organization Phone

Mr G L Boots Worthing Astrological Society 01903 505346 Mr John Coote Sustrans Mr Chris Cousins West Sussex County Council 01243 756612 Mr Alistair Hume Hillreed Developments Limited

Colin Knappitt

Mrs Margaret Pratt Highways Agency

Ms Amy Reid Environment Agency 01903 703952

108 Appendix 2.8 – Results of Core Strategy consultation

Representor : 102 Mrs Sharon Clarke (Worthing Town Centre Initiative)

ID / Type Heading Response / Representation Officer's Recommendation Other Spatial Vision The focus of regeneration in the Town Centre is definitely the way forward, the public Support noted Document transport links are already in place so will help to reduce the number of Car visits. Item The Seafront is the draw for visitors and the improvements here with the increased quality and quantity of the retail offer will in turn bring economic benefits to the Worthing.

Preferred Preferred I would like to see here the aspiration not only to maintain our role as a regional Support and aspirations to move Option TC 1 retail centre but to move up the retail hierarchy. Worthing up the retail hierarchy are noted.

Recommend a change to supporting text which acknowledges aspirations to move up the south east regional retail hierarchy.

Recommend a change to supporting text which acknowledges aspirations to move up the south east regional retail hierarchy.

Preferred Preferred I would like to see mention here of protecting and enhancing the heritage and Representation noted. Protecting and Option TC 2 character through the north / south developments enhancing the built environment is Complementing covered by the principles established the relationship under Preferred Policy ENV 1. A between the requirement for further detailed Town Centre guidance under this spatial policy is not and Seafront therefore required.

109 Preferred Preferred There needs to be some guidance on what is classed as nuisance and what is Representation noted. Supporting Option TC 3 acceptable for a Town Centre location to ensure the objections of a few do not spoil paragraph 6.12 states that the limited Creating A the enjoyment of many. and unbalanced concentration of night Safe Evening clubs and late night drinking Economy for establishments lead to crime and the Town community safety issues. It is accepted Centre that this may be a generalisation, however the detailing of what is classed as nuisance uses is not the remit of a Spatial Core Strategy, hence the policy requirement for sensitive planning controls. Officer recommendation add "and licensing" after "Planning".

Preferred Preferred This is key for a cohesive quality environment. I would like to see a comment about Support noted and the issue of Option TC 4 sustainability of the public realm because in high traffic areas improvements can sustainability is an underlying principle soon need maintenance and repair of the Core Strategy.

Preferred Preferred I fully support this recommendation Support noted. Option TC 6

Preferred Preferred I support this but I feel there should be something included about allowing new Support noted, and the evaluation of Option TC 7 facilities to be evaluated as well. new provision along the seafront will be assessed via the planning application process. Preferred Preferred I think identifying the areas for quality office / business accommodation helps to Support noted. Option TC 8 create communities of interest within the town

Preferred Preferred This statement needs to have a comment about adequate Car Parking for those Support noted, the issue of sustainable Option TC 9 individuals that access the town centre by Car. travel and prioritised car parking is covered by Preferred policies TP1 and TP2.

110 Preferred Preferred The creative sector is very important to Worthing and in itself can become a visitor Support is noted Option EMP 3 attraction, I fully support this option as I feel the locations will support the links between Town Centre and Seafront and also improve the public realm in these areas.

Preferred Preferred It is good to see the focus on the quality of accommodation. Response is noted Option EMP 4

Preferred Preferred Glad to see the comment about protecting the existing retail businesses along with Support noted. Option R 1 providing new.

Preferred Preferred A lot of the bulky goods retailers are now developing a Town Centre offer so we Comments noted. Option R 3 need to ensure the developments can attract these retailers

Representor : 356 Mr Barry Richards (Retired)

ID / Type Heading Response / Representation Officer's Recommendation Chapter 1 Introduction I would like to comment on the two documents produced by the Council. The introduction of the new planning system requires Local Authorities to bring forward reviews of outdated Local Plans in accordance with the approved Local Development Scheme. It is not an option to simply rely on a Local Plan adopted in 2003.

111 - The Core Strategy A key element of the vision in the Core Strategy is that the ensuing proposals are deliverable and realistic. Through the work done on the Masterplan and the evidence base prepared as part of the LDF work, it is considered that the underlying vision and objectives are realistic and deliverable.

- Unlocking Development Potential

The documents are ‘weighty’ and cover a wide range of topics. I would like to have had more time to digest them but as we have only been given a few weeks to reply I have had to be brief and have concentrated my criticisms and comments as follows:-

- General

- One Site-specific area

The site-specific area is the “Eastern Gateway” which is where I have lived for 14 years, have some knowledge of, and whose future is critical to the success of the town as a tourist area

GENERAL

I must first admit to being a little perplexed by the planning process in Worthing as we seem to be bombarded with planning documents on a regular basis with no clear observable continuity between plans. This means that what appeared to have been decided and approved following a lengthy consultation process in an earlier plan has now, within a relatively short time, either disappeared from the latest plan or worse still been overridden.

112

e.g. one part of the Eastern Gateway area was designated in the local 2003 plan for leisure use only but this designation appears to be in danger of being disregarded in the latest plan. Where a change of use is proposed should this not be subject to the normal planning approval process or can the process be circumvented by simply issuing a new plan

I also feel that the Council should not be embarking on flights of fancy while more mundane matters are neglected e.g. we should not be spending time and money planning grandiose schemes involving land extensions into the sea when we have still not decided on the location of the new swimming pool or the future of the Aquarena Site which has been disgracefully neglected over a good many years.

We pay our council tax for the provision, maintenance and enhancement of core services and facilities and until this is done we should not be day-dreaming about the long term future. I have quoted this one example from the site which is of particular interest to me but I am sure that there are other examples elsewhere in the documents.

Representor : 364 Councillor Bob Smytherman (Worthing Liberal Democrat Group)

ID / Type Heading Response / Representation Officer's Recommendation

113 Preferred Preferred Where possible developer contributions should be sort to provide funding for late Support noted. Issues related to a safe Option TC 3 night transport i.e.: Reinstate the Night Bus service economy and community safety are Creating A covered in Preferred Policy COM4 and Safe Evening emerging detail in Planning Obligations Economy for Supplementary Planning Document. the Town Centre Preferred Preferred The Council should seek to create financial capacity within the theatres budget to be Support noted, however reference to Option TC 6 used to enhance the remaining facilities the Council's financial capacity is not a spatial planning issue and therefore cannot be included in policy. Preferred Preferred The seafront should include provision for off-cycling from Splash Point to the border Support noted. Provision of alternative Option TC 7 with Ferring and satiable modes of travel are covered by Preferred Policy TP2. Preferred Preferred Phase 2,3 and 4 of the Seafront cycle routes should be provided off-road. Support noted. Provision of alternative Option TC 9 and satiable modes of travel are covered by Preferred Policy TP2. The detailing of cycle route provision does not fall within the remit of the Core Strategy. Preferred Preferred Continue with the current Business use at the Garcia Trading Estate and resist the Representation noted however, the Option EMP 1 loss of any business units detailed consideration of planning current proposals is not a spatial planning issue. The Core strategy is advocating flexibility of land uses in some of the trading areas where the need for upgrading and diversification is considered appropriate..

114 Preferred Preferred Adopt a similar policy to Bournemouth Borough Council to resist the loss of any Preferred Policy EMP 4 allows for some Option EMP 4 further hotel bed space loss of visitor accommodation, subject to meeting tests of viability including the assessment of alternative leisure/tourism uses.

The emphasis is on improving the quality of the visitor offer. This could mean some bedspace loss, but quality would be higher.

EMP 4 is considered to provide the correct balance in response to the change in Worthing’s visitor economy and the additional need to diversify the tourism/visitor offer.

115 Preferred Preferred Follow the examples of Richmond Council by providing on-road parking at higher This could be considered when the Option TP 1 cost to those vehicles that pollute more than others Parking Strategy is developed. No change to the preferred option is needed Preferred Preferred Green Travel Plans should be included as Planning conditions for all applications Policy TP 2 provides sufficient Option TP 2 where appropriate emphasis on the implementation of green travel plans for new development

Preferred Preferred Consideration should be given to road user pricing. Road user pricing is outside of the Core Option TP 3 Strategy's remit. The introduction of road pricing schemes will need the consent and cooperation on the County Council and national government.

Policy TP 3 is still applicable for traffic management.

Preferred Preferred The Council need to lobby Government for the reintroduction of regulated bus Changes to de-regulate bus services Option TP 4 services to enable local people decide when and where services are provided(similar have to be done at Parliamentary level. to London) The Core Strategy cannot therefore recommend introducing de-regulated bus services.

Preferred Preferred Provide links to ease congestion on the A27 where possible Comment noted. One of the Option TP 5 justifications for the EWAR proposals is the congestion relief implications it would have on the A27. Preferred Preferred We need a greater supply of 3/4 bedroom family homes supplied by the social Support noted. It is essential that the Option H 5 rented sector policy is flexible as local circumstances and demands do change. Preferred Preferred Levels of Affordable Housing should be a minimum of 40% on ALL large scale An assessment of the impact of a range Option H 6 developments of affordable housing thresholds and percentages on the viability of development is underway and will inform the appropriate level of affordable housing to be sought.

Preferred Preferred We need to work closely with neighbouring authorities to identify suitable and Support noted Option H 7 sustainable sites

116 Preferred Preferred Locally accountable decision making Support noted. Option HP 1

Preferred Preferred We would support residential education facilities at the West Durrington site along Support noted. Option ED 1 with adequate infrastructure

117 Appendix Appendix 2 We need to increase the level of all types of affordable housing especially social and Comments noted but they relate more Housing Land key worker. to the preferred options on housing. Supply The preferred approach outlines how the Core Strategy will address the housing requirements and the expectations regarding the delivery of affordable housing.The comments on affordable housing are covered in the response to H6.

We should provide more than our neighbouring authorities NOT less.

We need affordable housing spread widely across the town including new developments on the seafront

118

Representor : 357 Multiplex

Agent : 355 Mr Peter Jones (Turley Associates)

ID / Type Heading Response / Representation Officer's Recommendation Chapter 4 Spatial Vision Support noted

Preferred Preferred This policy should set the town centre vision by stating where the centre should be in Support noted and officers would Option TC 1 10-15 years time. We suggest that the vision for the centre is to expand its retail and concur that the word "maintain" be business offer to enable the town to rank within the UK's Top 50 town centres by replaced with the word "enhance". 2015. We also suggest amending Policy TC1 to read, "to support and promote a wider mix of uses within the town centre which meet local and visitor need and enhance" ( rather than "maintains") "its sub-regional role". The strategy needs to have a higher target than currently reflected in the wording.

Preferred Preferred Under "Retail Growth" (paragraph 6.59), the assumption on which the 40,000 sq m Comments noted. The estimated Option R 1 forecast was made was that Worthing would only maintain its share of the market. A forecast is to 2017 and the Council higher capacity could be justified on the grounds that, with a major department store recognises that the further capacity for example, Worthing's market share will increase. Account would need to be taken work may be required. Officers consider in such a situation of the implications for other centres were a change in market there to be enough flexibility with the shares to be planned for. Core Strategy and future LDF documents to respond to market share and sustainable retail growth.

Preferred Preferred The expansion of the primary shopping area is the only reasonable option for Support noted. Option R 1 creating the critical mass to attract major new retailers and anchor stores in the town centre.

119 Preferred Preferred There is ambiguity in the current strategy which states that "retail growth outside the Objection noted and it is accepted that Option R 3 town centre or other centre locations will be significantly limited, restricting bulky the current preferred policy may goods retailing only to existing out-of-centre parks". The wording should read " contradict the restricting existing and any new out-of-centre parks to bulky goods retailing only". As currently worded it suggests that bulky goods should only be developed out-of- centre. The strategy needs to encourage bulky goods in the town centre and other centres.

town centre regeneration aspirations in relation to retail growth and PPS6 in relation to accommodating retail need within existing centres.

.

Recommendation:

In order to protect the town centre's role the policy should be revisited to resist

120 further out of centre retailing where evidence base from the Retail Capacity Study concludes retail need can be met within the town centre. Given the spatial vision to direct investment into the town centre which includes encouraging traditional out-of centre retailers to invest in the town centre consideration should be given as to what value the inclusion of Preferred Policy R3 has, when government guidance clearly establishes the tests that will need to be applied by retail development proposed in locations less accessible by a choice of transport modes.

Recommendation: Officer to explore the consequence of deleting Policy R3.

Preferred Preferred Delete duplicate paragraphs. Footnotes (i) and (ii) duplicate the definitions in PPS6 Objection noted. Option R 3 and are not needed. Recommendation: Officers to review the extent to which duplication occurs and the usefulness or otherwise of including the footnotes.

Preferred Preferred This option should be reworded to state "to introduce infrastructure that will redirect TP 3 could add text to include shoppers Option TP 3 non-essential through traffic away from the town centre, thereby restricting traffic and visitors going into the town centre to essential users such as residents, visitors and shoppers, commuters and businesses".

Appendix Appendix 1 TC1: The target could include monitoring development to reach the target of 40,000 The target could detail the figures set Monitoring and sq m of new retailing in the town centre out in the DTZ retail study. Implementation

Appendix Appendix 1 R1: A definite figure of increase in floorspace should be considered for the target, As R1 relates solely to the Primary Monitoring and such as meeting the 40,000 sq m proposal. Shopping Area, the target of 40,000 sq Implementation m is not considered to be appropriate.

121 Appendix Appendix 1 TC5: There appears to be a discrepancy between the figure of 40 per cent Agreed. The indicator for TC5 needs to Monitoring and mentioned here and 30 per cent mentioned in Preferred Option H6. be consistent with H6. Implementation

Representor : 110 Mr Martin Small (South Downs Joint Committee)

ID / Type Heading Response / Representation Officer's Recommendation Preferred Preferred The South Downs Joint Committee supports Policy EMP1 as the sites identified are Support noted Option EMP 1 not within and do not impinge on the Sussex Downs AONB or the South Downs National Park (subject to Ministerial confirmation).

Preferred Preferred The Joint Committee supports Policy R3 as will effectively help protect the Sussex Support noted. Option R 3 Downs AONB/South Downs National Park (subject to Ministerial confirmation).

Preferred Preferred The South Downs Joint Committee supports the principle of Policy ENV1 and Conservation areas are covered in Option ENV 1 particularly the requirement for high quality design. However, the Joint Committee Government guidance that already objects to the lack of any reference within the policy to Conservation Areas and exists and therefore does not need listed buildings, which are particularly important in the urban (and rural) environment. detailed inclusion into the Core Strategy. Preferred Preferred The South Downs Joint Committee supports the principle of Policy ENV2, but Comments noted, however the Core Option ENV 2 objects to the lack of any reference within the policy to the Sussex Downs AONB or Strategy must avoid duplicating any reference at all to the South Downs Management Plan, Integrated Landscape guidance provided by national and Character Assessment, Worthing-Shoreham Urban Fringe Landscape Study or regional publications. It will however be South Downs National Park (subject to Ministerial confirmation). appropriate to refer to local landscape designations and this will be reviewed in light of work currently being undertaken on Landscape Character Assessments.

122 Preferred Preferred The South Downs Joint Committee supports Policy ENV3. Support is noted Option ENV 3

Preferred Preferred The South Downs Joint Committee supports the principle of Policy ENV4, Comments noted. Option ENV 4 particularly the caveat regarding the negative effects on the environment in respect of small-scale developments for wind and solar power and the requirement for new development to be of the Eco Homes "very good" standard (although the Joint Committee believes that the Government is planning to replace the Eco Homes standard with the Code for Sustainable Buildings).

However, the Joint Committee objects to the lack of presumption against large-scale There is no mention in the Core renewable energy schemes in the Sussex Downs AONB/South Downs National Park Strategy of not allowing large scale (subject to Ministerial confirmation); the lack of requirement for mitigation as regards renewable energy schemes in the adverse impacts on nature conservation interests and a lack of requirement for new AONB and South Downs National Park. development to enhance biodiversity. In addition, whilst the principle of requiring Worthing does not have significant larger new development to include measures to increase the amount of energy used areas within them and the construction from on-site renewable sources is supported, current thinking is that sufficient on-site of large scale wind farms etc.was not renewable energy provision should be provided to achieve at least a 10% reduction considered a viable policy option in the scheme's predicted carbon dioxide emissions (the revised LB Merton policy)

Preferred Preferred The South Downs Joint Committee supports the principle of Policy TP2, particularly Policy TP 2 does advocate the need for Option TP 2 its statement that developer contributions will be used to fund new infrastructure and developers to make access provision its requirement that major new commercial and residential developments will be via Section 106 agreements and the encouraged to incorporate measures intended to reduce car usage. However, the requirements of the County Council Joint Committee objects to the preferred option because it fails to require major new developments to make provision for the access needs they generate.

Preferred Preferred The South Downs Joint Committee objects to Preferred Option TP4 as it fails to TP 4 does not contain any reference to Option TP 4 include criteria relating to the visual and immediate environmental impact of a park a Park and Ride location. If a suitable and ride site and its failure to presume against such a facility in or adjacent to the site is found there will inevitably be the Sussex Downs AONB/South Downs National Park (subject to Ministerial proper consultation and environmental confirmation). procedures carried out.

123 No change in TP 4 needed

Preferred Preferred The Joint Committee supports Policy H6. Support noted Option H 6

Preferred Preferred The Joint Committee supports Policy COM1. The representation supports Policy Option COM 1 COM1, and the support is duly welcomed. No change. Preferred Preferred The South Downs Joint Committee objects to Policy COM2 and its supporting text The representation would appear to Option COM 2 because of its view of the South Downs as a constraint on the provision of new open object most specifically to the wording recreation space and its corresponding failure to acknowledge the potential of the of the supporting text, rather than the South Downs as a recreational resource, and because of its failure to encourage principle of safeguarding and sustainable access routes from the town to the Downs. enhancing Open Recreation Space. The objection would look to relate to Para. 8.41 which suggests the South Downs acts as a constraint on the provision of new open recreation space, and also fails to acknowledge the recreational potential of the Downs. Though the PPG17 study does not include the South Downs/AONB as open recreation space (instead it is defined as natural/semi-natural open space), it is noted that supporting text should recognise the Downs as a recreational opportunity rather than a constraint . Sustainable access routes are discussed under Policy TR2, while green corridors are included under the definition open recreation space, and are as such considered within Policy COM2.

Representor : 238 Mrs V Cousins 124 (Kingston Parish Council)

ID / Type Heading Response / Representation Officer's Recommendation Chapter 2 Issues Facing Re 2.9 re development pressure on strategic gaps and pressure on the urban fringe Comments regarding the strategic gaps the Borough are noted.

protection of the coast and its long-term role.

Kingston Parish Council would like to record its strong support for the protection of Strategic Gaps to ensure that the separate identity and character of all settlements will be maintained and even enhanced to prevent their perceived or actual coalescence.

In particular Kingston Parish Council would like to register its concerns for any encroachment into the strategic gap between Worthing and Ferring as this would also have repercussion for the perception of Kingston and its surrounding settlement structure.

Representor : 365 Tony Malone (The Worthing Society)

ID / Type Heading Response / Representation Officer's Recommendation Chapter 1 Introduction (This note is applicable to all parts of the document(s):- Comments regarding typographical errors noted.

125 Any grammar/spelling & typographical errors noticed during the reading of the strategy documents are noted within our response. The following, however, are applicable throughout the documents:-

- Spell 'centre' not 'center'

- 'comprised' or 'comprises' - never 'comprised of ' or 'comprises of''.

Chapter 2 Issues Facing 2.8 This paragraph is not strictly true. Although maintaining and enhancing the Comments regarding the public the Borough natural and built environment should be very important to the residents they are, in perception of environmental issues are fact, largely apathetic. The Borough should strive to interest, involve and educate noted. them on this issue, perhaps in partnership with local interest groups such as The Worthing Society.

Chapter 2 Issues Facing 2.9 One additional bullet point:- The pressure placed on infrastructure is the Borough already noted in the issues sections. It is not considered necessary to add this specific bullet point as it is already covered.

- Intense pressure on housing and general infrastructure from the unemployed (already resident in the Borough plus those being 'imported' from other areas).

Chapter 4 Spatial Vision 4.7 The phrase "improving access to health facilities" is meaningless with the current The provision of health facilities is much serious threat to local hospitals. Better to remove the phrase. wider that simply hospital provision. It is an issue for Worthing and one which needs to be taken into account.

126 Preferred Preferred 6.9 'declined' should read 'decline'. Mis-spelling noted and to be corrected. Option TC 2 Complementing the relationship between the Town Centre and Seafront

Preferred Preferred 'initiates' should read 'initiatives' Error noted and to be corrected. Option TC 4

Preferred Preferred 6.17 'Civic facilities' rather than 'Civic uses'. Observations noted "Civic uses" to be Option TC 6 replaced with "Civic Facilities".

6.18 There are disturbing rumours concerning the future of the Town Hall and The Connaught. These fine buildings are pivotal to the character of Worthing and must be safeguarded.

Preferred Preferred Preferred Option TC6: A Cultural & Civic Town Centre & Seafront Observations noted. The protection of Option TC 6 Listed Buildings is covered by National Planning Policy. Protecting buildings of local distinctiveness and character to be addressed in a revision to Preferred Policy ENV1.

We suggest that you add:-

The preservation of the Listed Town Hall plus The Connaught Theatre is paramount. They are a fundamental part of the character of Worthing.

Preferred Preferred "Contribute to maintaining the area's character (i.e. because this is just as important Comments noted Option ENV 1 in the town centre and seafront as "elsewhere").

127 Preferred Preferred (final para) We disagree with the contents of this paragraph. The Borough should Comments noted. Option ENV 4 show a more positive attitude towards solar/wind power.

However the policy does not oppose wind and solar power, it merely states that it must not produce negative effects on the landscape.

Preferred Preferred (2nd para) "..car/sharing/car clubs " just won't work, people will not do it. A frequent PPG 13 advocates the introduction of Option TP 2 and reliable bus service serving all areas of the Borough is the best hope. car sharing schemes and Green Travel Plans. TP 2 complies with this guidance

Preferred Preferred Mixing affordable homes with e.g. new builds of luxury properties on the same site is It is important to provide a range of Option H 6 not practical. People who can afford a luxury home will not choose to buy one if their housing to meet the needs of the neighbour is in an "affordable home". community and to ensure that such communities are sustainable. It is therefore not appropriate to plan for single tenure residential development on larger sites and it is possible to combine a wide range of size and tenures on a single site.

Preferred Preferred "To retain, and where possible enhance the provision of existing indoor sports Observations regarding Aquarena site Option COM 1 facilities". This is exactly what we would like to see done on the old Aquarena site!! are noted. This representation is covered in further detail under Representation 112 in the UDP document.

Preferred Preferred We would like to see a positive statement regarding the absolute necessity to retain Observations noted. However as a land Option HP 1 all facilities at Worthing Hospital, most especially the A & E Department, the loss of use spatial document, such a statement which WOULD result in hundreds of unnecessary deaths every year. as suggested is outside the remit of the development plan.

128

Representor : 33 The West Durrington Consortium (The West Durrington Consortium)

Agent : 10 Mr Doug Cramond (DC Planning)

ID / Type Heading Response / Representation Officer's Recommendation Chapter 1 Introduction The first sentence under the Core Strategy ‘key issues’ is absolutely right – ‘the Support noted provision of housing is a major issue in Worthing’ (para 2.2). The West Durrington site is a hub for this provision with its approximate capacity of some 1,200 dwellings with appropriate support facilities. The authority really must focus on delivery here and the progress made so far in the planning system, along with unique features such as one body having the sole interest in the land, needs to be utilised to the full to move towards development on this site. Permission and development is not, of course, reliant on the LDF process given the current Local Plan status but, nevertheless, the LDF documents should give full recognition to the range of merits of this site.

The Consortium supports the key diagram (page 21) with its inclusion of the West Durrington site and the town centre as the two areas for ‘major development’

Preferred Preferred The Consortium agrees with the components and principle of Preferred Option H1 : Comments noted. Wording of H1 needs Option H 1 Housing Provision with its clear inclusion of West Durrington as a principal element to be amended to more accurately of the town’s housing supply. However the Consortium objects to the lack of reflects the various components of specificity – to aid clarity and certainty, this key housing policy should set out the housing supply. anticipated levels of supply from each land supply source. Part of this should include making it clear that the West Durrington allocation will bring forward ‘about 1,200 dwellings’.

129 Preferred Preferred The Consortium is content to supply 30% affordable homes on the West Durrington An assessment of the impact of a range Option H 6 development but would wish to object to the scaling of affordable provision by site of affordable housing thresholds and size found within Preferred Option H6: Affordable Housing. The same target should percentages on the viability of apply across large and small-scale sites. development is underway and will inform the appropriate level of affordable housing to be sought.

The delivery programme for housing at West Durrington (Monitoring and Implementation page 10) underlines the need for continued priority to be placed on the timely determination of current and future applications for the West Durrington site. To minimise the need for review the local planning authority will have to guard against unnecessary delays arising from other authorities or parties and balance issues in favour of delivery.

Representor : 378 Capella Holdings

Agent : 377 Gill Ashworth (Boyer Planning Ltd)

ID / Type Heading Response / Representation Officer's Recommendation Preferred Preferred Observation noted and a clear cross Option TC 8 referencing to the emerging allocations to which this policy relates within the Unlocking Development Potential DPD will be included.

130

Representor : 113 Ms Susan Solbra (Southern Water)

ID / Type Heading Response / Representation Officer's Recommendation Preferred Preferred Development in areas at risk of flooding - support Comments noted. Option ENV 3

Southern Water supports the authority’s intention to limit development in areas at Introductory text to be reviewed where high risk of flooding, and require mitigating measures where development in such appropriate to reflect comments. areas cannot be avoided.

In periods of flooding, surface water can inundate the public sewerage system, The Council is currently undertaking a thereby exceeding its capacity. The extra pressure can cause flows from the main Strategic Flood Risk Assessment, sewer to surcharge up tributary sewers. As a result, properties may become flooded (SFRA) to help inform the Core by foul water, even relatively remote from the flooded site. It is therefore important to Strategy Submission and Site minimise the risk of flooding. Allocations to come forward through the Unlocking Development Potential Document.. Where appropriate Planning applications to be accompanied by FRA and detailed mitigation measures are explored with advice from bodies such as EA?

Sustainable Drainage Systems - objection Officers accept SUDs are not appropriate in every location, especially tightly restricted urban areas such as Worthing.

131 It is important that new developments incorporate suitable arrangements for surface Officers to give Consideration to water drainage. Excess surface water should not be drained to foul sewers, as this expanding the policy approach to will increase the risk of foul water flooding. Preferred Option ENV3 promotes recognise that alternative and new Sustainable Drainage Systems (SuDS) to manage surface water run-off from more innovative drainage systems will developed areas. need to be explored within the context of where new development is proposed.

Southern Water is supportive of the objectives of SuDS. However, such systems Consideration will be given to amending require long term maintenance and rely on facilities which are not adoptable by the text in the introductory sections and sewerage undertakers. The developer should therefore ensure that arrangements ENV 3 exist for the long term maintenance of SUDS, so that their effectiveness is maintained in perpetuity. Good management will avoid flooding and subsequent inundation of the foul sewerage system.

Furthermore, the design of SuDS must be appropriate for the location. Factors that need to be considered include topography, run-off rates and ground conditions in relation to the size, type and density of development.

Proposed amendment:

In order to improve the clarity of Preferred Option ENV3 we propose firmer wording and a new paragraph on sustainable drainage systems:

New development should will be discouraged in areas of high flood risk. If development in such areas is considered essential it should must incorporate significant measures to mitigate the effects of flooding such as Sustainable Drainage Systems.

132 Appropriate Sustainable Drainage Systems will be encouraged to manage surface water run-off from built up areas. Proposals will need to include maintenance arrangements to ensure effective drainage throughout the lifetime of the development.

Development will be considered….. Preferred Preferred Preferred Option ENV4: Sustainable development Comments noted Option ENV 4

Page 46 Text will be re-examined

Partial support, partial objection Much of the comments are very detailed,

Protection of the quality of water resources - support the Core Strategy needs to be strategic and if areas are covered which merely regional and national guidance they should not be included in a Core Strategy.

Southern Water supports the second paragraph of Preferred Option ENV4, which protects the quality of water resources.

Pollutants from built up areas could potentially contaminate groundwater sources by run-off or seepage. Development should therefore not be permitted in groundwater source protection zones unless the Environment Agency is satisfied that the risk is acceptable.

133 We would like to see a reference to potential yield of water resources, as well as quality, in line with policy RES10 of the adopted Local Plan (2003).

Water efficiency - objection

The emerging South East Plan promotes the BREEAM method to assess the environmental performance of new development. This is reflected in the Preferred Option, where a BREEAM standard of at least ‘very good’ is promoted.

Water use is one aspect of environmental performance. Southern Water promotes efficient use of water as part of a strategy to manage the demand for as well as the supply of water. This strategy has been developed in collaboration with the Environment Agency and helps to minimise the volume of water abstracted from the environment. Managing demand involves encouraging installation of water conservation measures such as low flow taps, showers, low flush toilets and water butts.

Under the BREEAM method it is possible to achieve a high environmental rating without implementing water efficiency measures. We would therefore encourage the authority to promote a specific standard relating to water efficiency. BRE’s Ecohomes assessment makes six credits available on internal and external water use. We propose that at least four out of six credits should be achieved in new homes. A similar standard would be appropriate for commercial development.

134 The purpose of the Core Strategy is to provide strategic and overarching policies. It may therefore be inappropriate to outline specific standards in this document. However, we would recommend a reference to specific standards, which can be provided in more detailed development plan documents (DPDs). In the absence of a DPD of development control policies (Worthing’s LDS, September 2006), we would propose that specific standards should be provided in Area Action Plans and Development Briefs.

Proposed amendment:

Add a sentence to the fourth paragraph of Preferred Option ENV4:

New building development, both residential and commercial will be expected to reach the BREEAM standard classification of at least ‘very good’ in order to achieve the efficient and sustainable management of energy, water, waste and pollutants. A minimum standard will be developed for water efficiency to ensure implementation. This will be specified in Area Action Plans and Development Briefs.

OMISSION OF POLICY

Efficient Use Of Infrastructure

Prudent use of resources is a key element of sustainable development. We welcome the Core Strategy’s consideration of water efficiency in preferred option ENV4, but we have not identified a policy that promotes efficient use of infrastructure. This is also important to support sustainable development.

Southern Water has identified three ways in which the planning authority can assist in achieving efficient use of water and wastewater infrastructure.

135 Firstly, a co-ordinated whole-site approach to large and/or mixed ownership sites will promote sustainable sewerage and water supply networks, and prevent the proliferation of smaller, less efficient networks.

Secondly, separation of surface water to separate sewers or drainage systems provides more efficient use of the foul sewer, and reduces the risk of foul water flooding.

Thirdly, on-site and off-site sewers serving new developments of ten or more dwellings should be constructed to adoptable standards, to ensure that they operate effectively in the long term.

We therefore propose an overarching policy promoting efficient use of infrastructure to support more detailed policies in subsequent Development Plan Documents.

Proposed amendment:

Insert the following sentence to ENV1 or ENV4:

Development proposals must ensure that infrastructure is used efficiently.

OMISSION OF POLICY

Protection of Amenity

As far as we can ascertain, no policy in the Core Strategy protects the amenity of residents. From Southern Water’s perspective, consideration of amenity is important in relation to proposals for sensitive development adjacent to wastewater disposal and treatment facilities.

136 Southern Water endeavours to operate its wastewater facilities in accordance with best practice. However, unpleasant odours inevitably arise from time to time as a result of the treatment processes that occur. For this reason, sensitive development such as housing must be adequately separated from wastewater disposal and treatment facilities, to safeguard amenity. The need to separate sensitive development from existing potentially polluting land-uses is recognised in PPS23, Appendix A.

We therefore take the view that the Core Strategy should contain a policy to protect the amenity of residents, to support more detailed policies in subsequent Development Plan Documents. These policies should permit development adjacent to wastewater treatment works only if the distance between the works and the development is sufficient to allow adequate odour dispersion. It may be appropriate to integrate this issue into preferred option ENV4 on Sustainable Development.

Proposed amendment:

Insert the following sentence to ENV4:

The amenity of occupants of new development must be protected. Proposals near to existing pollution generating activities will need to demonstrate that amenity will not be adversely affected.

Alternatively, a new policy could be inserted, along the lines of policy RES7 of the adopted Local Plan (September 2003):

Development which is incompatible alongside pollution generating activities will not be permitted near to such uses where it is likely to result in the need for additional mitigating measures to control the pollution generating activity.

137 Preferred Preferred We support preferred option H3 in as far as development will only be permitted if the Support regarding the objectives of H3 Option H 3 proposals provide appropriate infrastructure. However, the policy only applies to are noted. The objection relates to the previously developed land. omission of a policy approach regarding the provision of infrastructure. This will need to be reviewed in conjunction with the representations on the environment and sustainable development and We support H3 but consider that a more comprehensive policy is required to ensure whether a Worthing specific policy that all new development is co-ordinated with the provision of necessary approach is merited. If such an infrastructure (see separate representation). This policy should apply to both approach simply duplicates national greenfield and brownfield land. planning guidance and requirements, inclusion within the Core Strategy would not be appropriate.

OMISSION OF POLICY

Provision of utility infrastructure and phasing of development with such provision

We have not identified a preferred option in Worthing’s Core Strategy that promotes provision of water and wastewater infrastructure, or co-ordination of development with such provision (but please see our representation to preferred option H3).

New and improved water and wastewater infrastructure may be needed to meet the demand from new development, or to meet stricter environmental standards set by the Environment Agency. This includes extension to treatment works or new assets, for example pumping stations. As planning authorities are responsible for approving planning applications for the development of infrastructure, a supportive planning policy framework is imperative at all levels – regional, county and local – to facilitate timely delivery of water and wastewater capacity.

138 Southern Water is committed to meeting the demand arising from new development, as identified in adopted development plans. However, if development is allowed to proceed before the infrastructure necessary to serve it is available, both new and existing customers may experience unsatisfactory levels of service. The planning authority has an important role to play in terms of ensuring that new development is co-ordinated with the rate at which necessary infrastructure can be provided.

We therefore propose a policy which supports, in principle, provision of new utility infrastructure, and co-ordination of development with such provision. This is essential to facilitate delivery of investment by Southern Water, and to maintain a high level of service to new and existing customers.

Consideration of the provision of infrastructure and services, and co-ordination of development with such provision, is consistent with PPS1. Paragraph 23 states that planning authorities should “ensure that infrastructure and services are provided to support new and existing economic development and housing”. Paragraph 27 states that the provision of essential infrastructure must be taken into account when bringing forward land for development.

Proposed amendment:

Insert a new policy:

Provision of utility infrastructure

New and improved utility infrastructure will be encouraged and permitted in order to meet the identified needs of the community.

New development will be permitted only if sufficient capacity is either available, or can be provided in time to serve it.

139

Representor : 381 Fairview New Homes Ltd

Agent : 379 Rebecca Caines (RPS Planning)

ID / Type Heading Response / Representation Officer's Recommendation Preferred Preferred FNH consider that residential development should in certain circumstances be Policy EMP 1 does advocate flexibility Option EMP 1 promoted on allocated employment sites that are rundown, vacant and/or poorly in some of the employment areas. located.

In accordance with guidance set out in PPG 3 (at that time) an Employment Land Review was undertaken in 2005 and concluded the need to retain all employment allocations. However, it is accepted that redevelopment and upgrading of employment sites will be a component in meeting modern business requirements and continued supply of adequate floorspace. Policy EMP1 therefore provides the degree to which flexibility in meeting this objective will be applied, focusing on those employment locations where protection will take precedent.

140 A future Supplementary Planning Document will clarify the detailed criteria to be used when assessing a potential loss of employment space.(this just repeats what is in policy)

Preferred Preferred Whilst it is right and proper that energy and sustainable issues are considered, they Comments noted. Option ENV 4 should not stifle regeneration and development. Such initiatives are a cost to the developer and the viability of delivering housing schemes must be a priority. FNH Officers do not accept that are of the view that this should be assessed on a site by site basis and should not be requirements placed on new applied to all residential developments. development would stifle regeneration objectives, but on the contrary would make a significant contribution towards national and local sustainability objectives.

141 The Department for Local Communities and Local Government (DCLG) has recently published 'Planning and Climate Change' Consultation Dec 2006, which sets out how spatial planning should contribute towards reducing emissions and stabilising climate change. Along with this the DCLG has also published a package of measures. This includes the "Code for Sustainable Homes" "Building a Greener Future” and the "Code for Sustainable Homes". All recently published advice will need be absorbed where appropriate by the emerging Core Strategy and will establish the Council's expectations with regards to sustainable development measures and the environmental performance of development to accord with principles established by existing and emerging government guidance.

Recommendation: A review of the Sustainable Development Preferred Policies within the Core Strategy in light of the above will be undertaken to ensure policies taken forward are consistent with national guidance and the emerging South East Plan.

142 The preferred advocates the use of renewable energy/energy efficiency for larger developments. For residential this is over 10 units.

Preferred Preferred FNH are of the opinion that all residential development sites should conform with Support noted Option H 2 national guidance in that densities of 30 dwellings or more should be promoted.

Preferred Preferred The thresholds could have a detrimental effect on the viability of development and An assessment of the impact of a range Option H 6 may prohibit, if applied inflexibly without having regard to the merits of each case, of affordable housing thresholds and housing development in the area. FNH therefore request that due consideration is percentages on the viability of given in the policy to the need to have regard to the specific circumstances of each development is underway and will site including economic viability, when negotiating the provision of affordable inform the appropriate level of housing. affordable housing to be sought.

Fairview consider that any specific requirement for affordable housing should be indicative and should be open to negotiation. PPG3 states that Local Planning Authorities should work with developers to achieve realistic assumptions on levels of public subsidy for affordable housing, having regard to site costs and therefore the amount of affordable housing that can be provided viably.

The policy should therefore make it clear that each case will be treated on its merits, having regard to such criteria and the Council's objective for providing affordable housing based on an up to date Housing Needs Assessment.

Preferred Preferred FNH object to the requirement that major new residential development will be The objection is noted, and it is Option COM 5 required to contribute towards the provision of open recreation space typologies recommended that the policy text be within the Borough. It cannot be demonstrated that large-scale development will altered to more accurately reflect actually lead to an increase in the demand for recreation facilities. Our client guidance of circular 05/05, only considers that this contribution is considered unreasonable and unnecessary. requiring a contribution where it can be demonstrated that such a contribution would be reasonable, necessary and related to the scale of development.

143 FNH request that a sentence be added to this policy to state that contributions to such development will only be sought where it can be demonstrated that this is reasonable, necessary and related to the scale of development.

Representor : 26 Mrs Margaret Pratt (Highways Agency)

ID / Type Heading Response / Representation Officer's Recommendation Chapter 4 Spatial Vision The HA is supportive of Worthing Borough Council's objectives of reducing Support noted congestion and promoting sustainable transport. The HA would suggest that existing transport issues, as well as the potential traffic and transport implications of the proposed developments, should be considered as a proactive input to the sustainable planning process. We would also expect to see emerging policy mechanisms that would minimise demand at source, take account of air quality issues and require the mitigation of local or wider trunk road impacts throughout all stages of development planning, implementation and operation. This may require, for example, joint working between the developers of various sites to provide, as a last resort, funding towards infrastructure.

Preferred Preferred The HA supports mixed use developments which are located in urban areas where Support Welcomed. Option TC 1 there is the potential for a wider choice of transport modes. Policies which balance the provision of homes and employment, either through the strategic co-location of development sites or through the identification of sites with the potential for mixed development are aligned with the principles of PPG13.

144 Preferred Preferred The HA supports mixed use developments which are located in urban areas where Support noted. Option TC 2 there is the potential for a wider choice of transport modes. Policies which balance Complementing the provision of homes and employment, either through the strategic co-location of the relationship development sites or through the identification of sites with the potential for mixed between the development are aligned with the principles of PPG13. Town Centre and Seafront

Preferred Preferred The HA supports mixed use developments which are located in urban areas where Support noted. Option TC 5 there is the potential for a wider choice of transport modes. Policies which balance the provision of homes and employment, either through the strategic co-location of development sites or through the identification of sites with the potential for mixed development are aligned with the principles of PPG13.

Preferred Preferred The HA note that B1 land use generates a relatively high trip demand. The HA Support noted. Option TC 8 therefore supports the location of such developments in locations with a choice of transport modes.

Preferred Preferred In principle the HA is supportive of initiatives which would improve public transport Support noted. Option TC 9 provision in the Borough and thereby create the potential to reduce development impact on the trunk road network.

Preferred Preferred In principle the HA supports development in central locations. This would align with Support noted Option EMP 1 PPS12 9paragraph 4.24) Tests of Soundness 4 and 7.

Preferred Preferred The HA is supportive of mixed use developments in central locations. Where Support and comments noted Option EMP 2 developments are likely to have significant transport implications in order to fully align with PPS12 Tests of Soundness 4 and 7, we would require that Transport Assessments should be prepared, which include a Travel Plan. The requirement for a Travel Plan should apply to all types of development, including residential sites. Sustainable measures that are offered through these plans should be secured via appropriate planning mechanisms and travel plans should specifically require the consideration of targets, monitoring, incentives for compliance and a funding stream to maximise their potential for success.

145 Preferred Preferred The HA support the development of live/work units as a method of reducing the need The comment is noted Option EMP 3 to travel.

Preferred Preferred The HA would support the development of carefully sited community facilities that Support noted. Option R 2 may have the potential to reduce the need to travel to larger urban areas and therefore to align with PPG13.

Preferred Preferred On sustainable transport grounds the HA supports this Option. The HA would expect Support noted. Option R 3 that local planning authorities will assess the impact on the trunk road network of out of town development. We would therefore like to see emerging policies that minimise demand at source and require the mitigation of trunk road impacts throughout all stages of development planning, implementation and operation. This is particularly relevant to out of centre developments, as alternative transport choices tend to be limited, meaning that levels of reliance on the private car can be much higher than in urban centres.

Preferred Preferred In principle the HA support the use of developer contributions to fund sustainable Support noted, reference to Option TP 2 transport initiatives. We would suggest the policy is widened to include a reference improvements in public transport in the to measures such as public transport improvements, in addition to the infrastructure introductory text and also the Policy text improvements. to be considered.

The HA supports the promotion of Travel Plans, with appropriate monitoring, enforcement, incentive and funding mechanisms to maximise their likelihood of success and therefore align with PPG13.

Preferred Preferred The HA supports the incorporation of demand management into the Core Strategy. The HA's comments are noted. Option TP 3 However, we would not support a strategy which sought to provide costly new However, the impact on the trunk roads infrastructure measures without first identifying and implementing alternative of diverting traffic away from the Town sustainable options in line with the objectives of PPG13. These may be achieved Centre will be assessed in the future. through options such as demand management and traffic management Any infrastructure work will be done in mechanisms. tandem with other mechanisms to reduce car traffic.

146 We do have concerns about the soundness of the option as worded, as it could Transport modelling work will be carried imply reducing town centre traffic at the expense of the trunk road, rather than out to assess the impacts of future reducing traffic overall. We require the mitigation of trunk road impacts throughout all development on the existing strategic stages of development planning, implementation and operation in accordance with road networks and implications of Circular DTLR 4/2001. capacity for the town.

Preferred Preferred While the HA in principle supports the concept of Park and Ride, we would need to TP 4 does not contain any reference to Option TP 4 consider any impacts on the trunk road network. Generally Park and Ride sites a Park and Ride location. If a suitable should be located where they can intercept existing traffic and not where they would site is found there will inevitably be generate additional trips. A transport assessment would be required for any further consultation and subject to proposed site. environment assessments . There will also be consultation with the Highways Agency to assess the transport impacts on the trunk roads. TP 4 does not need re-wording

Future transport modelling work will be carried out to assess the transport effects of a Park and Ride site

147 Preferred Preferred The HA's chief concern in the Core Strategy is the potential impact of the proposed The construction of EWAR would not Option TP 5 East Worthing Access Road. We would be looking for the proposed Road to provide necessarily lead to more traffic using relief for the A27 through Worthing. In view of the congestion on the trunk road, we the A27. A recent consultant's report would have serious concerns if the construction of EWAR resulted in more traffic has indicated that the probable route for using the A27. EWAR would reduce A27 traffic flows going westwards. Further work on EWAR is likely in the future that would provide more data on traffic forecasts for the A27. EWAR is unlikely to be constructed in isolation. It would form part of a package that includes other transport measures and future economic generation. Policy TP 5 therefore is still applicable

148 From our point of view further details are required in relation to the potential to change trip distribution on the trunk road network. Until this information has been provided it is possible that this policy might fail PPS12 (paragraph 4.24) Tests of soundness 4 and 7.

Preferred Preferred The HA is supportive of locating development on previously developed land within Support noted Option H 3 centralised locations.

Preferred Preferred The HA would support the development of carefully sited community facilities, which The representation is supportive of the Option COM 3 have the potential to reduce trips by private car. principles of Policy COM3, and this is duly welcomed. No change.

Appendix Appendix 1 The HA supports the use of indicators, targets and monitoring as a measure to Support noted. Targets will be reviewed Monitoring and ensure that goals are achieved. However, we consider that more specific targets to ensure that, where possible, they are Implementation would be needed in order to fully align with PPS12 Test of Soundness 8. realistic and measurable.

Appendix Appendix 2 The HA note the target completion dates for the site allocations. The HA believes Comments noted. Assessment of the Housing Land that it is vital that development does not take place at a faster rate than the provision required transport infrastructure to Supply of any related infrastructure requirements, as this could lead to impact occurring on deliver the key sites is underway and the trunk road network. will inform the Submission Draft Core Strategy.

The HA would be supportive of the provision of early guidance to developers, preferably at pre-application stage, to allow the required infrastructure to be provided within an appropriate timeframe.

Representor : 359 Hugh Cave (City and Provincial plc) 149

Agent : 358 Mrs Kim Webster (Cushman and Wakefield)

ID / Type Heading Response / Representation Officer's Recommendation

150 Preferred Preferred The policy should be sufficiently flexible in order to take into account the viability of Objection noted. However the Preferred Option TC 4 the site and the proposed development, particularly brownfield sites. Policy wording is not considered inflexible and the detailing of how this spatial policy will be applied will be set out in emerging Planning Obligations Supplementary Planning Document (SPD) which will establish the framework for negotiation for the more detailed planning application process. Recommendation: Additional wording to be included which gives reference to the emerging SPD.

151 Appropriate contributions in accordance with circular 05/05 should be negotiated through the course of the planning applications i.e. they should be directly relevant to the development proposed.

As it stands the policy is considered to be unsound with regards to test ix as set out in paragraph 4.24 of PPS12 which states:

"the plan is reasonably flexible to enable it to deal with changing circumstances"

Add "in accordance with government guidance on planning obligations" to the beginning of Policy TC4 .

Preferred Preferred The aim of the policy is supported however there are instances where existing In accordance with guidance in PPG3 Option EMP 1 employment sites or the use seriously affects the surrounding amenity, through (at that time) an Employment Land disturbance to neighbours, visual intrusion or an adverse impact in the character of Review was undertaken in 2005 and an area. In addition the site may be unsuitable for industrial redevelopment because concluded the need to retain all of the size, shape, location or lack of vehicular access; or there is no realistic employment allocations. However, it is prospect of the land being used for industrial and warehousing purposes in the accepted that redevelopment and future. upgrading of employment sites will be a component in meeting modern business requirements and continued supply of adequate floorspace.

Therefore the policy needs to be sufficiently flexible to consider alternative uses on Policy EMP 1 provides the degree to employment sites when the above occurs. which flexibility in meeting this objective will be applied, focusing on those employment locations where protection will take precedent.

152 As it stands the policy is considered to be unsound with regards to text ix as set out A future Supplementary Planning in paragraph 4.24 of PPS12 which states: Document will clarify the detailed criteria to be used when assessing a potential loss of employment space. .(this just repeats what is in policy)

"the plan is reasonably flexible to enable it to deal with changing circumstances".

1. replace may with will in the second paragraph

2. Add at the end of the first sentence in paragraph two "if:

(i) the existing use seriously affects amenity, through disturbance to neighbours, visual intrusion or an adverse impact in the character of an area; or

(ii) the site is unsuitable for industrial redevelopment because of the size, shape, location or lack of vehicular access; or

(iii) there is no realistic prospect of the land being used for industrial and warehousing purposes in the future."

3. Make the second sentence a new paragraph

Preferred Preferred The aim of the policy is supported, however, the policy should be sufficiently flexible Comments noted. Option ENV 4 in order to take into account the viability of the site and the proposed development particularly brownfield sites.

153 BREEAM for commercial development and BREEAM for residential development The Department for Local Communities known as EcoHomes looks at the site conditions as well as construction and energy and Local Government (DCLG) has usage. Therefore a site could be achieving close to maximum points on all aspects recently published 'Planning and apart from the site conditions and proximity to existing community uses and could Climate Change' Consultation Dec still fail to achieve EcoHomes very good overall. Therefore very good should be the 2006, which sets out how spatial target rather than the minimum target and unless it can be demonstrated that very planning should contribute towards good can not be achieved. reducing emissions and stabilising climate change. Along with this the DCLG has also published a package of measures. This includes the "Code for Sustainable Homes" "Building a Greener Future” and the "Code for Sustainable Homes". All recently published advice will need be absorbed where appropriate by the emerging Core Strategy and will establish the Council's expectations with regards to sustainable development measures and the environmental performance of development to accord with principles established by existing and emerging government guidance.

In addition there may be design reasons why certain renewable technologies can not Recommendation: A review of the be incorporated into the development, and not all technologies are appropriate in Sustainable Development Preferred certain locations. Therefore there needs to be flexibility to allow for feasibility studies Policies within the Core Strategy in light to be submitted to prove the case for or against specific renewable energies. of the above will be undertaken to ensure policies taken forward are consistent with national guidance and the emerging South East Plan.

As it stands the policy is considered to be unsound with regards to text ix as set out in paragraph 4.24 of PPS12 which states:

154

"the plan is reasonably flexible to enable it to deal with changing circumstances".

1. Remove "at least" from the 4th paragraph

2. Add "unless otherwise agreed with the local planning authority" to the end of the 4th paragraph

3. Remove the 5th paragraph entirely

4. Add "unless otherwise agreed with the local planning authority" to the end of 6th paragraph.

Preferred Preferred The policy should be sufficiently flexible in order to take into account the viability of All new developments are assessed Option TP 2 the site and the proposed development, particularly brownfield sites. and negotiated individually with respect to developer contributions, in consultation with the County Council and WBC. It is unlikely that any major development would not impact on the local transport infrastructure, therefore the phrase 'where applicable' would not be suitable for TP 2

Appropriate contributions in accordance with circular 05/05 should be negotiated through the course of the planning applications, i.e. they should be directly relevant to the development proposed.

As it stands the policy is considered to be unsound with regards to text ix as set out in paragraph 4.24 of PPS12 which states:

"the plan is reasonably flexible to enable it to deal with changing circumstances".

155

1. In the 1st paragraph replace "use developer contribution from new developments to" with "where applicable developer contributions from new development will be used to"

2. In the 2nd paragraph replace "Use major new commercial and residential development to encourage the setting up of" with "Where applicable major new commercial and residential development will be encouraged to set up"

Preferred Preferred The policy should be sufficiently flexible in order to take into account the viability of All new developments are assessed Option TP 3 the site and the proposed development, particularly brownfield sites. and negotiated individually with respect to developer contributions, in consultation with the County Council and WBC. It is unlikely that any major development would not impact on the local transport infrastructure, therefore the phrase 'where applicable' would not be suitable for TP 3

Appropriate contributions in accordance with circular 05/05 should be negotiated through the course of the planning applications i.e. they should be directly relevant to the development proposed.

As it stands the policy is considered to be unsound with regards to test ix as set out in paragraph 4.24 of PPS12 which states:

"the plan is reasonably flexible to enable it to deal with changing circumstances"

156 1. Replace "use developer contribution to" with "where applicable developer contributions will be used to"

Preferred Preferred The aim of the policy is supported to make the best use of land. However the The policy approach needs to be Option H 2 minimum target should be 30 dwellings per hectare as is indicated in PPG3. reviewed in the light of PPS3 with reference to 30 dwellings per hectare as a minimum target. It is considered however, that in sustainable locations the target should be higher than 30 dph.

As it stands the policy is considered to be unsound with regards to test vii and ix as set out in paragraph 4.24 of PPS12 which state:

(vii) the strategies/policies/allocations represent the most appropriate in all the circumstances, having considered the relevant alternatives, and they are founded on a robust and credible evidence base:

(ix) the plan is reasonably flexible to enable it to deal with changing circumstances.

1. remove the word "minimum" from the first bullet point

2. replace "35" with "30" in the first bullet point.

157 Preferred Preferred The mix of a site is very much dependent on the type of development and also the Whilst market forces need to be taken Option H 5 characteristics of the site and whether it lends itself to a predominantly flatted or into account, it is essential that the housing development. This is also influenced by the sites geographical location and Core Strategy ensure that a range of its surrounding area. However the market has a very strong role to play and size and tenures is provided to meet accordingly this needs to be factored in and the policy made sufficiently flexible to be community needs, this must be the able to respond to market forces. main driver in assessing proposals. This should be informed by the housing supply and demand information. It is the role of the Core Strategy to set out the main spatial objective and simply because SPD is to be prepared in the future to inform the implementation of a policy, does not render the Core Strategy policy unsound.

158 There is no reference to an SPD regarding housing mix in the LDS therefore details of what the document may include needs to be published in order that a full response can be made.

As it stands the policy is considered to be unsound with regards to test vii and ix as set out in paragraph 4.24 of PPS12 which state:

(vii) the strategies/policies/allocations represent the most appropriate in all the circumstances, having considered the relevant alternatives, and they are founded on a robust and credible evidence base:

(ix) the plan is reasonably flexible to enable it to deal with changing circumstances.

Preferred Preferred It is acknowledged that affordable housing need to be provided however the An assessment of the impact of a range Option H 6 threshold is too low. Circular 06/98 recommends a threshold of 25 units. Emerging of affordable housing thresholds and PPS3 states that "the indicative national minimum threshold is 15 dwellings, but local percentages on the viability of planning authorities may set a different threshold or series of thresholds where this development is underway and will can be justified". There is no justification in the core strategy for the deviation from inform the appropriate level of the emerging policy. affordable housing to be sought.

As it stands the policy is considered to be unsound with regards to test iv, vii and ix as set out in paragraph 4.24 of PPS12 which state:

159 (iv) it is a spatial plan which is consistent with national planning policy and in general conformity with the regional spatial strategy for the region or, in London, the spatial development strategy and it has properly had regard to any other relevant plans, policies and strategies relating to the area or to adjoining areas;

(vii) the strategies/policies/allocations represent the most appropriate in all the circumstances, having considered the relevant alternatives, and they are founded on a robust and credible evidence base:

(ix) the plan is reasonably flexible to enable it to deal with changing circumstances.

1. delete the first sentence

2. the first two bullet points should be deleted.

Preferred Preferred The policy should be sufficiently flexible in order to take into account the viability of The representation objects to the policy Option COM 5 the site and the proposed development, particularly brownfield sites. at present, considering unsound in relation to test ix, para. 4.24 of PPS12. It is recognised that greater flexibility will be required, and it is recommended that the policy text be altered in order to more accurately reflect guidance set out in circular 05/05.

Appropriate contributions in accordance with circular 05/05 should be negotiated through the course of the planning applications i.e. they should be directly relevant to the development proposed.

160 As it stands the policy is considered to be unsound with regards to test ix as set out in paragraph 4.24 of PPS12 which states:

"the plan is reasonably flexible to enable it to deal with changing circumstances"

1. add "where applicable" to the beginning of the 1st paragraph

2. replace "a" with "an appropriate" in the 1st sentence of the 2nd paragraph and in the 3rd paragraph.

Preferred Preferred The policy should be sufficiently flexible in order to take into account the viability of The objection is noted, however, the Option HP 2 the site and the proposed development, particularly brownfield sites. Core Strategy approach is not considered the correct document in which to set out the detailed negotiation of planning obligations. The Councils application of such policy will be set out Appropriate contributions in accordance with circular 05/05 should be negotiated in a Supplementary Planning through the course of the planning applications i.e. they should be directly relevant to Document. the development proposed.

Circular 05/05 states that developers should not be expected to pay for facilities that are needed solely in order to resolve existing deficiencies, nor should attempts be made to extract excessive contributions to infrastructure costs from developers.

As it stands the policy is considered to be unsound with regards to test iv and ix as set out in paragraph 4.24 of PPS12 which states:

161 (iv) it is a spatial plan which is consistent with national planning policy and in general conformity with the regional spatial strategy for the region or, in London, the spatial development strategy and it has properly had regard to any other relevant plans, policies and strategies relating to the area or to adjoining areas;

(ix) the plan is reasonably flexible to enable it to deal with changing circumstances"

1. Delete "where major new residential development is situated in areas where there is an identified deficiency in health and social care provision, or"

2. Replace "where this" with "In relevant cases where"

3. Replace "a" with "an appropriate" Preferred Preferred Not all residential development necessitates the need for a financial contribution Officers note that the preferred policy Option ED 2 towards education, the mix of the proposed development is a determinate factor. states” where major new residential Therefore the policy should be sufficiently flexible in order to take into account the development is proposed which would viability of the site and the proposed development, particularly brownfield sites. place additional strain…” I accordance with Circular 05/05.

Appropriate contributions in accordance with circular 05/05 should be negotiated through the course of the planning applications i.e. they should be directly relevant to the development proposed.

As it stands the policy is considered to be unsound with regards to test ix as set out in paragraph 4.24 of PPS12 which states:

162 "the plan is reasonably flexible to enable it to deal with changing circumstances"

Add replace "a" with "an appropriate".

Representor : 302 Mr R W Frost (Ferring Parish Council)

ID / Type Heading Response / Representation Officer's Recommendation

163 Preferred Preferred ENV2 does not go quite far enough in protecting the Goring Gap. It is so narrow that Officers consider Policy ENV 2 provides Option ENV 2 any building whatsoever would undermine its integrity. Its role in maintaining the the correct weight is given to the separate identities of Goring and Ferring should be emphasised. function and role of Strategic Gaps at this time, … A landscape character assessment is being carried out on the Strategic gaps to assess their existing function and future role within the context of the Borough. The Core Strategy approach will be modified once the outcome of the assessment has been analysed.

164 Amend to say 'The Western Gap will remain free from all development and will be protected as well as enhanced as an area to retain its character and separate the identities of Goring and Ferring'.

Representor : 392 Mr Andrew Weeks

ID / Type Heading Response / Representation Officer's Recommendation Preferred Preferred Worthing would greatly benefit from additional trees to improve the large suburban Comments noted Option ENV 4 areas, both old and new, which are ultimately going to increase. Working in partnership with developers, trees need to be planted now rather than later prior to the start of development. For example:- Adur Avenue would be greatly improved by additional trees, if the developers had been obliged to plant more trees the avenue would look glorious, deter vandalism and be inviting to all. So often in the past very few trees are put in, obviously not enough! There is much talk about how many trees are going to be removed but if developers were obliged to talk in larger numbers of additional trees the community would see this as a positive contribution and we would see trees lined road/avenues contributing to biodiversity, standard of environment etc. Sped deterrents could be included where necessary, possibly taking the form of road width restriction. This would provide more area to plant trees.

Policy ENV 1is considered to advocate the need to demonstrate high standards of landscape design.

Representor : 393 Mr Bartholomew Wren (HBF) 165

ID / Type Heading Response / Representation Officer's Recommendation Chapter 4 Spatial Vision HBF concerned that the Core Strategy is unsound as in most cases the document At the Issues and Options stage, a merely sets out the council's preferred policy option without stating why it was range of options was identified and chosen over alternative options. The wording in paragraph 4.12 of PPS12 refers to consulted on. The SEA highlights these this requirement and is being interpreted as a range of options. options and why a preferred option was selected. It is not considered that the Core Strategy is unsound simply because a single preferred option has been selected.

Chapter 4 Spatial Vision It is the HBF's view that the policy is too short term considering that the Core It is agreed that the Core Strategy Strategy will not in any case be adopted until next year at the earliest. The scope of timescale should be extended to 2026 the plan should be looking well beyond 2018, and at least to 2020, if not 2026 which to comply with the timescale of the would allow an appropriate coordination with the timescale of the RSS. Draft PPS3 South East Plan. requires core strategies to have time horizons of at least 15 years. An end date of 2018 does not comply with this requirement. The HBF suggest that the intended timescale and longer term scope of the plan is revised to take account of these requirements.

Preferred Preferred The HBF suggests that the policy should outline the flexible approach to be adopted In accordance with PPG 3 (at that Option EMP 1 for disused employment sites outside of the restricted areas, where the loss of B time), an Employment Land Review class employment uses may be acceptable. The HBF suggest that the policy was undertaken in 2005 concluded the wording includes words to the effect that other existing employment sites outside of need to retain all employment the ones listed in the policy are able to be developed for housing if suitable allocations. However, it is accepted that circumstances arise. For example within a specified period of time, and no suitable redevelopment and upgrading of employment use can be found to occupy the site, and/or the site is considered employment sites will be a component unsatisfactory for employment use. In which case Worthing Council would be open in meeting modern business to applications for housing as well as mixed-use developments on site, providing the requirements and continued supply of location is suitable for a change of use. adequate floorspace.

166 EMP1 provides the degree to which flexibility in meeting this objective will be applied, focusing on those employment locations where protection will take precedent.

Preferred Preferred The HBF supports the need for development to be sustainable, however, consider Comments are noted, it is not however Option ENV 4 the requirement of the policy for residential development to be built to BREEAM considered appropriate to provide Core standards of "very good" as inappropriate. The matter of detailed requirements for Strategy approach and policy which energy conservation is more properly a topic for consideration under Building looks at the Borough’s overall Regulations. We make a similar argument in relation to the requirement of the contribution to Sustainable preferred option for 10% renewable energy use on sites over 10 units. Firstly the Development. policy needs to consider renewable energy options as well as potentially considering the inclusion of on-site renewables on a site by site basis. the HBF are concerned that the policy will view new housing in isolation from their surrounding communities and existing housing in terms of energy requirements. The use of community based renewable energy schemes may in cases be the most appropriate and economical way forward, for example a larger community wind turbine(s). If this policy is implemented, there should be the potential for developers where appropriate to make commuted payments towards community schemes, which have the potential to benefit existing housing as well as new build homes.

167 Your DPD policy can aspire to the widely held principle of achieving energy The Department for Local Communities efficiency in development, but fundamentally the HBF believe that the supply of and Local Government (DCLG) has renewable energy is an issue for the energy industry to grapple with, in preference to recently published 'Planning and provision enforced through the planning process. Climate Change' Consultation Dec 2006, which sets out how spatial planning should contribute towards reducing emissions and stabilising climate change. Along with this the DCLG has also published a package of measures. This includes the "Code for Sustainable Homes" "Building a Greener Future” and the "Code for Sustainable Homes". All recently published advice will need be absorbed where appropriate by the emerging Core Strategy and will establish the Council's expectations with regards to sustainable development measures and the environmental performance of development to accord with principles established by existing and emerging government guidance.

Recommendation: A review of the Sustainable Development Preferred Policies within the Core Strategy in light of the above will be undertaken to ensure policies taken forward are consistent with national guidance and the emerging South East Plan

168 . Good design and safe and sustainable construction requirements are included in other areas of the Core Strategy

The Breeam standard of very good will remain. Developers in other responses have accepted it.

The setting up of community renewable energy schemes is outside of this policy, which is aimed at new development.

Policy ENV 4 is also not just about residential development, it includes commercial development as well. it cannot leave this issue to the energy industry

Preferred Preferred Para 8.12 - what is meant by a "sustainable location"? What is the definition of the Consideration of additional text to Option H 2 above term? Does sustainable mean urban, urban and close to major transport clarify what is meant by sustainable. connections, a location where dwellings per hectare are 40+ for example? The HBF would like further clarification on this point in the policy. No location is either perfectly sustainable or unsustainable.

169 Preferred Preferred The HBF suggest that an up to date housing market assessment is also used as a Support is noted. Option H 5 strong tool to determine the necessity to have a policy on dwelling mix. The HBF approve of the fact that the policy is not prescriptive in terms of dwelling size and location. We would like to remind Worthing Council that it is important to let house builders have most influence in determining dwelling mix on sites at any given time, as they understand market demands better than anyone else.

Preferred Preferred The HBF consider that the requirement of the preferred option to seek contributions An assessment of the impact of a range Option H 6 to affordable housing on all sites of 6 dwellings or more is currently unreasonable, as of affordable housing thresholds and it does not demonstrate the evidence as to why affordable housing contributions are percentages on the viability of being sought on sites below the minimum threshold size as outlined in PPS3. The development is underway and will policy should adopt PPS3 requirements until the alternative can be justified through inform the appropriate level of the production of evidence. However, the principle of a sliding scale for affordable affordable housing to be sought. housing contributions in principle, is something the HBF approve of.

170 It is important that affordable provision is determined on a site by site basis. Determined along with other development contributions and in relation to available state subsidy. As well as taking account of the above factors, surrounding housing mix and location are also important determinants and should have weighting in the development control process. It is important that the viability of housing development in its entirety is given sufficient consideration when determining the outcome of this policy.

Preferred Preferred The HBF would like to say that developer contributions should be considered as part The requirement for developer Option COM 5 of the whole package of requirements, which are made upon development, including contributions to remain in line with the affordable housing provision. Worthing Council need to remain mindful of preserving tests of soundness outlined in Circular the viability of development and securing housing delivery when determining a 05/05 is duly noted. package of development contributions in any given case. It is vital that any planning obligation is subject to the five tests of soundness as outlined in Circular 05/2005.

Preferred Preferred The HBF would like to say that developer contributions should be considered as part Objection noted. Officers note that the Option ED 2 of the whole package of requirements, which are made upon development, including preferred policy states” where major affordable housing provision. Worthing Council need to remain mindful of preserving new residential development is the viability of development and securing housing delivery when determining a proposed which would place additional package of development contributions in any given case. It is vital that any planning strain…” in accordance with Circular obligation is subject to the five tests of soundness as outlined in Circular 05/2005. 05/05.

171

Representor : 61 Mr Vivian John Seymour (Resident)

ID / Type Heading Response / Representation Officer's Recommendation Chapter 1 Introduction What a delight to see Worthing at least trying to give itself a lift. Your own research Support noted makes it clear that many people believe the town has 'lost its way'. How very true - it is a town with some potential but which, thanks to successive navel staring councils, has stagnated. It is good to see the town, given some degree of care and attention by its officials could become a decent place to be. Go on! Just for once set yourselves some real and challenging targets!

Representor : 394 Mr P Sankey

ID / Type Heading Response / Representation Officer's Recommendation Preferred Preferred Preservation of Western Gap. This green area is almost unique along the whole of Comments noted. Option ENV 2 the south coast and makes Worthing very special.

172 Full marks to the Council for this information on future plans. A landscape character assessment is being carried out on the Strategic gaps to assess their existing function and future role within the context of the Borough. The Core Strategy approach will be modified once the outcome of the assessment has been analysed.

Representor : 265 Mr G L Boots (Worthing Astrological Society)

ID / Type Heading Response / Representation Officer's Recommendation Preferred Preferred Need for additional paragraph. In keeping with the Worthing Borough Council Local Policy ENV 1 does specify the Option ENV 1 Plan 2003 Policy RES 8 and maintaining the spirit of paragraph 2.45, also Policy application of high standards of RES 2. Also, the need to avoid excessive lighting is already addressed in Policies architecture,urban and landscape RES 2 and RES 8 and their explanatory text. design.

Suggested additional wording; The appropriate use of light would also be part of this consideration, appropriate text may be considered for inclusion.

External Lighting

173 All new developments to use only the right amount of light when and where it is needed. Thus reducing energy cost and consumption of limited fossil fuels and improving the appearance of the environment.

The addition of the above paragraph will impact upon the Sustainability Appraisal and this consultee also comments on this document.

Preferred Preferred Need for additional wording; The policy is considered adequate for Option ENV 4 the sustainable and efficient management of resources in new development

New building development; both residential and commercial will be expected to reach the BREEAM standard classification of at least 'VERY GOOD' in order to achieve the efficient and sustainable management of energy, water, waste and pollutants as an aspect of receiving planning permission.

Representor : 56 Mr V Lilley (Worthing Residents Ass)

ID / Type Heading Response / Representation Officer's Recommendation

174 Preferred Preferred The preferred option for very large number of people is to be able to shop in a centre Representation noted. It is accepted Option R 1 offering a wide range of shops, restaurants etc in a safe and dry environment. Hence that innovative and imaginative urban the growth of out of town shopping centres/malls and the decline of traditional town design from all new development centres. proposals will have an impenitent role to play in the success of reversing the decline of high-street retailing and wider town centre regeneration.

With the growing awareness of the need to reverse this decline, both national and regional/local governments are looking for new approaches. In many towns and cities there is little or no opportunity to regenerate large derelict areas, e.g. Docklands, etc. One possible solution which could well attract funding from both central and regional levels is the development of smaller sites in and around the core retail area, the retail areas and the links between them being covered with glazed roofing. Thus, for example Montague and Warwick Streets could be covered in with linkage and routeways to other areas, e.g. along South Street and Chapel Road having roofed pavements.

These areas would be likely to create security and other issues which need to be addressed. If successful this could offer a blueprint for other declining town/city centres and, as such could be well attractive to funds - possibly under the banner 'The Worthing Solution' or 'The Worthing Initiative'. Needless to say consultation with major and individual retailers and potential retailers in Worthing would not come amiss prior to developing a funding proposal.

175 Preferred Preferred The planning concept that people living near good public transport facilities will give The need to use alternative and more Option TP 1 up their cars is, at best, in most cases outside the centre of major cities, risible. sustainable modes of transport other There are few, if any, local public transport facilities which could be said to be of than the car is set out under such a quality as to encourage the majority of people to use them. People require Government Guidance- PPG 13. Policy vehicles for business, commuting on routes with little or no direct transport links, TP 1 is advocating more effective family needs etc, and will not give them up. management of parking resources.Any reduction in parking spaces would be accompanied by effective compensatory measures. Policy TP 1 is in line with Government Guidance and is a suitable policy.

Preferred Preferred While domestic dwelling/housing needs are touched on throughout the document The concerns regarding the traffic Option H 2 there would appear to be no recognition that housing developments of any size impact are noted. The key focus for the generate increased numbers of vehicles, and hence impact on road usage and Core Strategy is on the town centre and parking - the larger the development, the bigger the impact being the norm. The seafront, as it is here where the main town centre of Worthing is already reaching a critical level in these areas such that development opportunities will arise any significant additional demand will lead to a counter-productive situation when and where sites can contribute to a both the commercial and retail activity affected and the town centre will continue on range of uses and facilities. Further its downward spiral irrespective of any proposed initiatives to reverse the decline. work is underway regarding the impact of the key sites on the transport infrastructure and will inform the Submission Draft of the Core Strategy.

176 With roads and public transport largely outside the Council's control, there would The potential of areas in sustainable appear to be clear requirement for the Council to produce a policy that new housing locations to contribute to the supply of developments of any size above a stated limit (e.g. possibly turning a house into housing is already highlighted in Policy flats) should be focussed around the under-developed transport hubs of East & West H2. Worthing, Durrington on Sea and Goring Stations, thus providing transport facilities and spreading the pressure on traffic density more evenly throughout the town. The town centre could then avoid the melt down scenario of traffic gridlock and inaccessibility for emergency vehicles caused by nose to tail parking on both sides of the streets; as well as giving it the opportunity to grow and thrive by making it more accessible and attractive to people from both within and outside the town. Without such a policy developers will always go for the softest and most profitable (to them) option.

Representor : 147 Mr Mick Anson (Sport England)

ID / Type Heading Response / Representation Officer's Recommendation Preferred Preferred Sport England considers that this policy is too narrow in its definition of what Objection noted. Option TC 4 contributes to the public realm. Sport England would like to see the phrase "public art initiate" changed to "cultural initiate" as this could then include sport and

recreation as a means of providing an area of civic space. It is Sport England's opinion that the omission of such text within the vision and core objectives would Recommendation: Change "public art suggest that the Core Strategy is unsound in relation to its conformity with the Draft initiates" to cultural art initiates". And RSS. supporting text in paragraph 6.14 to be amended to broaden out the definition of public realm.

Preferred Preferred Sport England supports this policy but considers that it would be strengthened by Support welcomed. Option TC 6 identifying potential means of resourcing improvements such as developer contributions This should be stated in the policy

177 The appropriate reference to seeking developer contributions and resourcing improvements is set out in the "Providing for Community"chapter and Preferred Policies COM3 and COM5.

Preferred Preferred Sport England would wish to see the word "recreation" included in the policy. Whilst Objection noted. Option TC 7 the supporting text refers to recreation, the policy itself only refers to leisure which in the supporting text appears only to refer to shops, restaurants and the theatre. Recommendation: Reference to "recreation" to be incorporated within revised policy.

Preferred Preferred Sport England supports this policy which would encourage walking and cycling as a Support noted. Option TC 9 healthy means of transport.

Preferred Preferred Sport England considers that an intrinsic part of good design is taking account of This point is covered in the Transport Option ENV 1 existing and future sustainable travel patterns particularly walking and cycling. section Policy TP 2 Developments should be designed to encourage sustainable travel which allows people to build activity into their daily lives. Sport England would like to see an additional clause in the policy requiring the design of developments to take account of existing and future sustainable travel patterns.

178 Preferred Preferred Sport England generally supports this policy however the policy should be The representation is supportive of the Option COM 1 strengthened by clarification of how an assessment for the need for a facility should principle of this policy, though argues be determined. Reference should be made to the need for an up to date built that its robustness should be increased facilities strategy. The policy should require a demonstration that an evidence based through outlining just how an assessment of the provision of facilities in the catchments shows that there is a assessment of facility need will be surplus of provision and that the loss would not be detrimental to future provision. At made. Sport England state the policy present the policy could be construed as meaning that a facility that is underused should require a demonstration that an signifies that a facility is no longer needed when in fact it could be due to poor evidence based assessment of facilities investment and poor quality facility. in the catchments shows there to be a surplus of provision, and that the loss of a facility will not be detrimental to future provision. It is recognised that an assessment of need will be necessary, and the recently undertaken PPS17 study will provide the basis for this assessment. It may be necessary to change text of policy from 'justified' to 'demonstrated'.

179 Preferred Preferred Sport England objects to this policy which indicates that proposals which result in the The wording of the policy does look to Option COM 2 loss of outdoor recreation space will be acceptable provided that some safeguard all forms of existing outdoor improvements are made to the retained recreation space. The policy should reflect recreation space in the first instance, Government guidance in PPG17 which states that it may be possible to improve an and the supporting text outlines that area of open space by allowing a reduction if it would lead to an overall any loss of open recreation space will improvement. have to be justified, and will only be allowed where it brings about significant qualitative improvements. It is acknowledged that the text of the policy could be altered to outline that this is the case, more accurately reflecting PPG17 guidance.

Preferred Preferred Sport England objects to this policy as it will only require contributions towards open The representation objects to the policy Option COM 5 space from major developments. All developments create a demand for recreation stating that all development, not just provision. Neither the policy nor the supporting text give any guidance as to what is major development, can create a considered to be major development which will apparently be left to interpretation demand for recreation provision. The and probably dispute by developers. It is essential that all developments contribute a representation also stresses the proportionate level of community infrastructure commensurate with their impact. requirement for development to Sport England also objects to the limitation of the contribution towards open space contribute a proportionate level of only. Given that the Council has stated that it has carried out an assessment of community infrastructure commeasure recreation provision covering a number of types of facilities, it is considered that with their impact. developer contributions should be capable of contributing towards built facilities as well as open space. The policy also requires contributions towards community facilities but it is not clear whether this would include built sports facilities. Given that there are separate policies in this chapter for community facilities and built sports facilities, Sport England has assumed that the Strategy considers them to be different entities.

180

It is necessary to state that the requirement for development contributions to remain appropriate to development in terms of scale and impact as per Circular 05/05 is recognised. The detailed rationale as to how such contributions are to be assessed will be set out in the separate Planning Obligations LDD. We are currently assessing whether it may be appropriate to seek planning obligations towards indoor sports facilities, and again further detail will be provided within the separate Planning Obligations LDD.

For information, the representation correctly assumes that the Core Strategy considers community facilities and sports facilities to be different entities.

Representor : 341 Mrs Norah Fisher (Worthing Access & Mobility Group)

ID / Type Heading Response / Representation Officer's Recommendation

181 Preferred Preferred Generally, we do consider that this policy is too complicated and could be re-worded Comments noted. The policy does Option ENV 4 in a more simplified manner. In particular, we are concerned that there has been no cover complicated issues and is provision for disabled people identified in the wording. In Addition, there is no target considered suitable for purpose mentioned for the number of life time homes that the council would like to see.

Lifetime homes is in the Housing section of the Core Strategy

Section Transport The Group were disappointed to see that no mention was made of the needs and Policy TP 1 deals with parking issues. aspirations of people with disabilities when attempting to use the various transport The development of a Parking Strategy options. We feel that there should be encouragement for developers to improve will include disabled parking provision. facilities for people with disabilities when relevant sites are being improved or New development will also provide developed for example the Station Gateway Site. Disabled parking is extremely disabled parking bays. It is considered important, and does not appear to be reduced. This particular policy should make that reference to people with disabilities mention of these issues and disabled parking provision should be encouraged. requires acknowledgement within the preferred approach.

Representor : 391 McCarthy and Stone (McCarthy and Stone)

Agent : 390 Mr Alexander Bateman (The Planning Bureau Limited)

ID / Type Heading Response / Representation Officer's Recommendation Chapter 1 Introduction 'This older population is likely to decline'. Comments regarding the need to meet the requirements of the elderly population is noted The preferred 182 It can be indicated from the most up-to-date census information that the population of elderly people in Worthing is indeed declining. In 2001, there were approximately 25,000 people aged 65 and over, this figure has substantially dropped to nearer 24,500 in 2004. However, I would not use this as the only source of information to make a generalising statement about the number of elderly people in the future.

The number of elderly people in the UK has grown and is likely to increase further. There has been a percentage increase from 13% to 16% since 1971 in the over 65 category, and in the over 85 there has been an increase from 7% to 12%. This should be taken into account when predicting population changes, as this will not only affect the housing need but also services that need to be offered in the Borough.

A key area which would force the number of elderly people in the Borough is housing. If there is not adequate housing for elderly people available in the Borough, they will have to move somewhere else. This troubles me, as it seems that the provision of affordable housing is becoming too important for other housing requirements to be involved in preferred options and this will cause severe problems in social economics. The Core Strategy is aiming towards equality for all, and encourages people from all backgrounds to live in the Borough. However, if housing for the elderly is not available, they will leave and there will not be an even society in Worthing Borough.

I don't expect to change the attitude towards Affordable Housing, as we are all too aware of its requirement across the UK, but I do feel that there are times when this is given too high of a pedestal to allow other housing needs to be addressed.

183 Preferred Preferred I am a little confused over this policy as I am under the impression that it contradicts Innovative and modern design can add Option ENV 1 itself. There is request to 'Provide an innovative and modern design' but this is to and respect the aesthetic followed by asking to 'Add to and respect the varied aesthetic appearance'. I find this appearance of the area. Modern design a little difficult to follow as I would expect a breakdown of the Borough indicating its is not just about the physical history and environment, yet there is also a need for modern development. In appearance of a development. It can retrospect of this preferred option, I believe that there should be a rethink of the include materials, energy efficiency terminology used and the aim of it. systems and other environmental benefits.

A detailed breakdown of the Borough’s history and environment would not be appropriate for inclusion within the spatial framework of the Core Strategy

Preferred Preferred There are now Parking Standards designed into the Core Strategy, but this I do not Worthing Borough Council does have Option TP 1 expect as it is becoming apparent that it is preferable to put this in a SPD or a DPD. adopted Parking Standards which are At this stage I just wish to highlight the importance of giving guidance for Parking used for planning purposes. There air Standards for a range of land uses. It is becoming an increasing problem that an adopted standard for sheltered Council's are not giving adequate guidance to all land uses and this results in accommodation. disagreements and even Planning Permission refusals over the provision of car parking.

By using data available on the district it can be seen that there are a high number of cars in the Borough. The figures indicate that there is an above average ownership in the Borough and this should be considered when creating the Parking Standards guidance.

184

I would like to take this opportunity to request that Sheltered Housing is given its own Parking Standard as I am sure that you are aware of its importance and different characteristics form other land developments.

Preferred Preferred Using a 'sliding scale' is a good way of indicating what is expected of a development Support noted. It is considered that the Option H 6 and not necessarily putting all developments in the same boat. However, the policy has sufficient flexibility to reflect preferred option indicates that all developments that fit the proposed scales will have different site circumstances. to provide Affordable Housing. I would expect some levels of flexibility, as there are some land uses which are more sustainable i.e. higher density, which are being penalised for doing so. For example, Sheltered Housing is built at 30 units and above to make it a viable option, which also makes it liable for Affordable Housing contributions, yet it makes better use of the site than regular housing developments.

Preferred Preferred Throughout the Core Strategy there are references made towards Planning The need for Preferred Option COM5 to Option COM 5 Obligations towards projects across the Borough. At this stage I just wish to raise the reflect the guidance of Circular 05/05 is guidance form circular 05/2005 which indicates that: duly noted.

''planning obligation must be:

i. Relevant to planning;

ii. Necessary to make the proposed development acceptable in planning terms;

iii. Directly related to development;

iv. Fairly and reasonably related in scale and kind to the proposed development; and

v. Reasonable in all other respects'.

185

Source: ODPM Circular 05/2005

I just feel that it should be necessary at this point, to indicate that the planning obligations sought should be relevant to the development and for the provision of things that the development has an impact on. At this stage I just wish to highlight the requirement of planning obligations from particular developers.

Representor : 387 Sainsbury's Supermarkets Ltd (Sainsbury's Supermarkets Ltd)

Agent : 386 Mr David Lowin (White Young Green Planning)

ID / Type Heading Response / Representation Officer's Recommendation Preferred Preferred Policy R3 seeks to resist out of centre development, only allowing restricted bulky Objection noted and it is accepted that Option R 3 goods retailing out of centre parks. the current preferred policy may contradict the

This policy is considered to go beyond the requirements of PPS6. town centre regeneration aspirations in relation to retail growth and PPS6 in relation to accommodating retail need within existing centres.

186 Whilst it is recognised that retail development needs to be located appropriately, Recommendation: having regard to the sequential approach, in some cases the location of further retail floorspace at existing out of centre locations maybe appropriate.

It is recommended that Policy R3 be reworded to advise that proposals for retail In order to protect the town centre's role floorpsace will in terms of location be considered in the light of the sequential the policy should be revisited to resist approach as set in PPS6.

further out of centre retailing where evidence base from the Retail Capacity Study concludes retail need can be met within the town centre. Given the spatial vision to direct investment into the town centre which includes encouraging traditional out-of centre retailers to invest in the town centre consideration should be given as to what value the inclusion of Preferred Policy R3 has, when government guidance clearly establishes the tests that will need to be applied by retail development proposed in locations less accessible by a choice of transport modes.

Recommendation: Officer to explore the consequence of deleting Policy R3.

187 Representor : 254 Ms Rose Freeman (Theatres Trust)

ID / Type Heading Response / Representation Officer's Recommendation Chapter 3 Impact of We especially support Priority Four at 3.26 on page 14 to Provide Worthing with Paragraph 3.26 refers to the priorities of Other Policies improved leisure, recreational and cultural facilities and activities and the objective at the Corporate Plan. It is not for the and Strategies 3.28 which has identified there is a need for improved cultural and arts facilities, the Core Strategy to alter the wording of a essence of which is also reflected in the Spatial Objectives on page 18. However, separate document, however, the you may wish to make this clear by inserting the words 'and cultural' after the word comments can be forwarded in order leisure in the paragraph 'Providing for the community'. that they can be taken into account in future reviews of the Corporate Plan.

Section Spatial We especially support Priority Four at 3.26 on page 14 to Provide Worthing with Suggested amendment can be Objectives improved leisure, recreational and cultural facilities and activities and the objective at incorporated. 3.28 which has identified there is a need for improved cultural and arts facilities, the essence of which is also reflected in the Spatial Objectives on page 18. However, you may wish to make this clear by inserting the words 'and cultural' after the word leisure in the paragraph 'Providing for the community'.

Preferred Preferred We support Preferred Option TC1 Providing for mixed use development - Protecting Support noted and for clarity mixed Option TC 1 areas of the town centre which are characterised by the niche or independent town uses could include recreational and centre offer they provide - presumably this includes your theatres. cultural uses such as theatres.

Preferred Preferred We support Preferred Option TC2 which seeks to integrate the seafront attractions Support noted. Option TC 2 with town centre activities, and Preferred Option TC3 to safeguard the potential of a Complementing vibrant evening economy. The three theatres make a major contribution to the vitality the relationship of town centres, especially the evening economy, and are significant elements of the between the town's cultural infrastructure. Audiences coming to an event will enliven the Town Centre surrounding area in the evening and provide regular custom for local bars and and Seafront restaurants outside normal working and shopping hours.

188 Preferred Preferred We support Preferred Option TC2 which seeks to integrate the seafront attractions Support noted. Option TC 3 with town centre activities, and Preferred Option TC3 to safeguard the potential of a Creating A vibrant evening economy. The three theatres make a major contribution to the vitality Safe Evening of town centres, especially the evening economy, and are significant elements of the Economy for town's cultural infrastructure. Audiences coming to an event will enliven the the Town surrounding area in the evening and provide regular custom for local bars and Centre restaurants outside normal working and shopping hours.

Preferred Preferred We support Preferred Option TC6 to enhance cultural and civic activities towards Support noted. Option TC 6 providing an attractive and vibrant town centre and seafront, and agree (6.47) that a strong cultural sector is key in the creation of a vibrant town. As a tourist destination we are pleased to see that Worthing recognises the importance of its cultural assets for visitors as well as providing the necessities for its residents.

Preferred Preferred We support Preferred Option ENV1 and whilst applauding the use of new design, Comments noted Option ENV 1 this should be sympathetic to the surrounding architecture. We would recommend the recent publication Heritage Works, a developers tool kit published by English Heritage, which provides guidance on how new design can be integrated with heritage assets.

189 Preferred Preferred With regard to Preferred Option TP1 on Parking, as you know, the economics of Worthing Borough Council does not Option TP 1 theatre are reliant on audiences being able to get to the venue by public transport control parking charges in the town and by car, being able to park their cars and bikes, and being able to get home centre. Policy TP1 loos to address the safely after a show. Controlled Parking Zones around theatres that extend to 11pm appropriative level of parking in both at night have serious implications for their economic viability. We would strongly urge the short and longer term and cannot any planning policies concerned with parking provision to consider the presence of advocate free car parking for individual theatres in the locality. Theatres are unlike other forms of the night time economy – groups they attract families, young people, disabled patrons, and older people who can be discouraged to attend theatres if the costs of travelling and parking at the theatre make the price tag of the evening out too high. Where restrictive regimes do occur we would urge the planning authority to allow for special conditions that can provide free parking to theatre patrons.

Preferred Preferred We support Preferred Option COM3 on Community Facilities but to ensure clarity we The representation is supportive of the Option COM 3 suggest that the word ‘Cultural’ is added to the title and in the text to read community principle of COM3, though requests that and cultural facilities so it is clear that theatres and other cultural attractions are the policy text be altered to include included. cultural facilities. For the purposes of the Core Strategy, cultural facilities are not included under the definition of 'community facilities'. The importance of cultural/civic facilities to Worthing as a town is recognised, and their enhancement is encouraged elsewhere in the Core Strategy under Policy TC6 as being central to the promotion of an attractive, active and vibrant Town Centre and Seafront.

190 Preferred Preferred We note that developer contributions are only mentioned on the Preferred Options The representation is supportive of the Option COM 5 for Sustainable Travel and Traffic Management on page 48. Preferred Option COM5 principle of COM3, though requests that on Community Infrastructure mentions ‘a financial contribution’. It is important that the policy text be altered to include the need for developer contributions for cultural activities is identified and we feel cultural facilities. For the purposes of further explanation is required on this topic, although you may want to broaden this the Core Strategy, cultural facilities are out in the form of a supplementary planning document. Investing time and resources not included under the definition of in such a document will set down clearly what is required of the developer and other 'community facilities'. The importance of funding partners. We recommend Securing Community Benefits through the cultural/civic facilities to Worthing as a Planning Process available at PlanningResource.co.uk. town is recognised, and their enhancement is encouraged elsewhere in the Core Strategy under Policy TC6 as being central to the promotion of an attractive, active and vibrant Town Centre and Seafront.

Representor : 95 Mr Mike Gwillam (SEERA)

ID / Type Heading Response / Representation Officer's Recommendation Document Core Strategy In accordance with Policy T3 of the South East Plan, the Core Strategy would benefit Preferred from a clear reference to and policy support for the enhancement and/or Options management of the regional transport spokes that relate to the borough, especially with regard to the level of regional connectivity for the major settlements and connectivity between sub-regions. This should be considered for all modes of transport.

191 Preferred Preferred This policy refers to 'retail growth' outside the town centre. The borough Council may Observations noted. Option R 3 prefer to substitute this for 'retail development'

Preferred Preferred The Borough Council must ensure that this policy is in line with regional guidance on Comment noted Option ENV 2 strategic gaps.

Preferred Preferred Policy ENV3 states that areas of low flood risk will not need mitigation measures. Comment noted Option ENV 3 The Borough Council may wish to amend this to suggest that flood risk mitigation measures for example using SuDs or surface water drainage measure may be needed in such area to prevent an increase in flood risk elsewhere, in line with Policy NRM3 of the Draft South East Plan.

Preferred Preferred The Assembly welcomes the references to the reduction of noise and light pollution Comments are noted. Option ENV 4 in this policy. We feel, however, that this could be strengthened by a commitment not only to minimise pollution but to actively seek improvements in water and air quality in line with NRM7 of the draft South East Plan.

The Assembly also supports the reference to reducing the negative effects of Recommendation: A review of the development on biodiversity, The Local authority may wish to refer to ways in which Sustainable Development Preferred development can be used to enhance biodiversity in line with Policy NRM4 of the Policies within the Core Strategy in light draft South East Plan. of the above will be undertaken to ensure policies taken forward are consistent with national guidance and the emerging South East Plan

The Local Authority might also consider making references to sustainable construction in line with Policy CC4 of the draft South East Plan.

Preferred Preferred The Assembly welcomes the inclusion of this policy. The submitted Core strategy No change of policy required Option TP 1 should fully reflect Policy T7 of the draft South East Plan in relation to levels of car and cycle parking.

192 Section Affordable The Assembly welcomes the reference to the definition of affordable housing as set Support noted. It is not considered that Housing out in PPS3 in the supporting text for this document. It may, however, also be useful the definition of affordable housing to include the definitions as 'housing for social rent, shared ownership, low cost should be amended as this is as set out home ownership, and sub market rent' and to include reference to the housing in PPS3. Given the urban character of remaining affordable as set out in the supporting text to policy H4 of the draft South the Borough it is not appropriate to refer East plan. These definitions may help to ensure clarity in this matter. to rural affordable homes.

Policy H4 of the draft South East plan specifies that in rural areas LDDs should promote small scale affordable housing sites within or well related to settlements. Policy H6 of the core strategy could be strengthened by making reference to rural affordable housing.

Preferred Preferred The Assembly welcomes reference to Gypsies and Travellers. The Local authority Support noted Option H 7 may wish to include reference to the protection of existing gypsy and traveller sites, as well as the provision of new ones, if applicable.

Preferred Preferred This policy mentions that there will be future guidance on the balanced approach to For clarification, future guidance will be Option COM 2 open recreation space. The name and date of publication for this guidance may be provided in a Supplementary Planning useful to include in the supporting text, as would the inclusion of reference to 'green Document, scheduled to go out to infrastructure' in line with Policy NRM4 of the draft South East plan. consultation in April.

193 Preferred Preferred The Assembly welcomes the inclusion of this policy. It would be useful if the policy The representation is supportive of the Option COM 5 could refer not only to the contributions of developers to infrastructure, but also to principles of this policy, though the maintenance and enhancement, in line with Policy CC5 of the draft south east observes that the policy text should plan. It would be helpful in the submission document if the range of infrastructure consider more specifically the listed and defined reflects the definition of infrastructure set out in the south east maintenance and enhancement of plan. existing infrastructure. Though the preferred option text does mention the enhancement of community facilities, it may be appropriate to more specifically mention 'enhancement and maintenance' in any re-wording of the policy.

Preferred Preferred The Assembly welcomes the reference to the provision of health facilities in relation Comments noted and officers to review Option HP 2 to the demands created by new developments. As the introduction to the Worthing the extent to which referencing to Core Strategy, the Assembly would also welcome the inclusion of reference to specific age groups (85) is a locally supporting people aged over 85 in Worthing, the Assembly would also welcome the distinctive issue for Worthing. inclusion of reference to supporting an ageing population, in line with Policy CC11 of Reference to specialist forms of the Draft South East Plan. There could be reference to forms of housing to meet housing is considered to be more specialised needs in the policy through, for example, references to extra care appropriately covered by Preferred housing. Policies on housing provision. Officer to review.

Representor : 389 Persimmon Homes (Persimmon Homes)

Agent : 388 Olivia Collett (Barton Willmore Planning Partnership)

194 ID / Type Heading Response / Representation Officer's Recommendation Chapter 1 Introduction Paragraph 12 of draft PPS3 requires Local Planning Authorities to set out the level of The comments are noted and it is housing provision for the Plan period in accordance with the Regional Spatial recommended that the timescale for the Strategy, in this case the emerging South East Plan which covers the 20 year period Core Strategy be amended, extending from 2006 to 2026. to 2026 rather than 2018.

Under this guidance, Local Development Frameworks are required to allocate sufficient land and buildings for housing or mixed use development to deliver the first five years of the housing trajectory, taking into account a windfall allowance only where it is not possible to allocate sufficient land.

In addition, for the following 10 years of the housing trajectory, further land must be allocated wherever possible. Where it is not possible to allocate specific land, broad areas of land for future growth should be indicated.

As regards the timescale, even assuming adoption of the Core Strategy can be achieved in 2008, there is a need for site allocations and hence the governing Core Strategy to provide for development needs for a total of 15 years. This will take the Plan period up to 2023 when at present specific sites are identified to 2014/15. Given that the South East Plan goes to 2026 and other authorities in the region are taking a pragmatic view and planning to 2026, Worthing should do the same.

Chapter 2 Issues Facing The Council recognises the main issues facing the Borough as: It is considered that the main issues the Borough have been correctly identified, with the appropriate emphasis given. The suggested additional text is not 1. Social; considered necessary.

195 2. Economic; and

3. Environmental.

Social

Although the issue of housing is highlighted as the main social issue, there is a need to further emphasise the need for more housing in the Borough both in terms of meeting Government targets and meeting local needs. This will be reinforced further if the South East Plan (SEP) housing numbers are increased for the Borough which in our view is inevitable given that the Council’s own assessment of supply already exceeds the draft SEP proposals.

Economic

The key issue identified for the economy is ‘maintaining a healthy, vibrant and diverse economy’. Mixed use developments can provide employment land in sustainable locations and should be considered as an option for increasing the economic opportunities for the population of Worthing.

Environmental

There is acknowledgement within the Core Strategy that there is development pressure on the strategic gaps and pressure on the urban fringe. There is no guarantee as to the deliverability of the identified residential development sites within a given timescale and this provides an additional reason for reviewing strategic gaps as part of a longer term framework to 2026.

196 Chapter 3 Impact of The South East Plan has been submitted to Government. As part of the consultation These comments are noted and will be Other Policies on the draft document the housing figures have been challenged and it is likely that taken into account in finalising Policy and Strategies there will be a significant uplift in housing numbers in the Region. Yvette Cooper in H1 regarding the overall housing her Ministerial Foreword to draft PPS3 states that ‘for too long, the housing market provision for the Borough. has not responded sufficiently to housing demand’ and that this is ‘our opportunity to respond to the challenges of the housing market, and improve the planning system to ensure the nation delivers the homes and communities where the next generation will feel proud to live.’ The Minister also emphasises the need for Plans to look further into the future and allow more land to be brought forward for housing where it is needed and appropriate.

The final Core Strategy therefore needs to be sufficiently flexible in order to accommodate an uplift in housing numbers if necessary and provide a strategy to 2026.

Chapter 5 Key Diagram Strategic Gap designation between Worthing and Ferring should be removed and A landscape assessment of the replaced by a designation of Safeguarded Land within which the long term Strategic Gaps is underway. Once development needs of the Borough (for housing, employment, community uses and complete, this will inform the open space) can be met. The Key Diagram should therefore be revised to reflect this designation and boundaries of the amendment. strategic gaps.

Section Economy The Core Strategy directs where development sites will be located giving due weight The Core Strategy does not rule out to development within the existing built up area boundary. The spatial strategy any sites for development. It provides limited opportunity for Greenfield development, with the objectives being encourages flexibility when needed in focused on Previously Development land and regeneration opportunities. The order to promote Worthing as a viable preferred spatial strategy takes account of Sustainability, Deliverability and delivery economic town of the spatial vision

Preferred Preferred The starting point for considering the appropriateness of “strategic gap” designation Comments noted Option ENV 2 is national policy in PPS7 - “Sustainable development in rural areas”. Paragraph 24 states that carefully drafted criteria - based policies in LDD’s, utilising tools such as landscape character assessment, should provide sufficient protection without the need for rigid local designations that may unduly restrict acceptable sustainable development. Therefore:

197

“Local landscape designations should only be maintained or, exceptionally excluded A clearer view of the development where it can clearly be shown that criteria-based planning policies, cannot provide potential in the Strategic Gaps will be the necessary protection.” (paragraph 2.5) formulated after work has been carried out to assess the topography and overall character of the gaps with respect to their potential future roles. it is possible that there are topographical and geological reasons why development is not possible in the gaps. This will be discovered when the landscape assessment work has been completed.

The South East Regional Assembly has recognised this advice in formulating draft A landscape character assessment is policy in the South East Plan. Notwithstanding our view that Strategic Gap policy has being carried out on the Strategic gaps outlived its usefulness and should not form part of the Regional Plan, the proposed to assess their existing function and Worthing-Ferring Strategic Gap fails the test for identification which is set out in the future role within the context of the Assembly’s proposals. Borough. The Core Strategy approach will be modified once the outcome of the assessment has been analysed.

Policy CC10b of the draft South East Plan states:

“Where there is a need to prevent the coalescence of settlements in order to retain their separate identity, local authorities may identify the location and boundaries of strategic gaps in a Local Development Document (or joint LDD where the gap crosses more than one local authority) if the following criteria are met:

1. The gap will prevent the coalescence of settlements each with a resident population greater than 10,000 persons

198 2. The gap must be no greater in size than is necessary, and in all cases no greater than five miles at its widest point.”

Thus in order to justify a Strategic Gap designation, gaps should only be identified between settlements each with a population of 10,000. As at 2001 Census, the population of Ferring was only 4,361 therefore failing this test and providing no justification for a Strategic Gap between Worthing and Ferring.

A further important consideration is that PPS7 also requires local planning authorities to rigorously consider the justification for retaining existing local landscape designations as part of reviewing their area-wide development plans and LDDs. In this regard attention is drawn to the Arun Local Plan Inspector’s report in which the Inspector concluded that when gaps were reviewed:

“...... Council’s will need to reappraise some longstanding policies almost “sacred cows” concerning the separation of certain settlements ...... consideration of the first gap that I suggest reviewing...... is the Worthing to Ferring Strategic Gap...... I believe that the two areas that make up this Gap could be examined to see whether a suitable mix of urban uses, including extensive open space, could be achieved here whilst still respecting the identity of the existing communities.” (paragraph 113.5)

Against this background the Council’s draft Core Strategy has singularly failed to carry out the necessary and appropriate review of the western gap. The Core Strategy should therefore be modified to remove gap designation from the subject land and to include a policy which identifies it as “Safeguarded Land” to provide for the development needs of the Borough. Such needs will include housing, employment, recreation and leisure and community uses. A detailed planning framework for the land will need to be provided through a development brief which should take the form of a supplementary development document prepared jointly with Arun District Council.

199 We therefore object to Preferred Option ENV2: Strategic Gaps and conclude that none of the land between Worthing and Ferring should be accorded Strategic Gap status.

Preferred Preferred Paragraph 7.33 states that the initial target for energy produced from renewable Comments are noted. Option ENV 4 sources for residential development will be set at 10%. There is a need for this to be applied sensibly, taking into account other methods of reducing carbon emissions such as seeking high standards of energy efficiency in building design. Policy ENV 4 does advocate reviewing the percentage of renewable energy sources over the Core Strategy period

Preferred Preferred Preferred Option TP5 which is the proposal for the East Worthing Access Road Policy TP 5 does not mention a 'review' Option TP 5 states that the Council are prepared to consider this option in the medium to longer of the role of strategic gaps. It mentions term as part of a ‘review’ of the role of the Strategic Gap in terms of economic, a 'flexible approach' and consideration regeneration, housing, community/social uses. In commenting on this proposal it is, of the future role of the strategic gap in on the face of it, somewhat perverse of the Council to propose a review of this Gap terms of its future possible economic which complies with RSS gap criteria in that it separates two settlements (Worthing regeneration. and Lancing) each having a population greater than 10,000. We will wish to comment further on this proposal if it is carried forward in the submission document.

It should be noted however, that a landscape character assessment is being carried out on the Strategic Gaps to assess their existing function and future role within the context of the Borough. The Core Strategy approach will be modified once the outcome of the assessment has been analysed.

200 Preferred Preferred Paragraph 8.7 states that a minimum of 4,000 dwellings will be provided up until Further amendments will be needed to Option H 1 2026 to ensure a flexible approach in case the South East Plan housing ensure that there is sufficient flexibility requirements change. Appendix 2 of the Strategy indicates that from 2006-2018 the should the figures in the South East Council already anticipates delivery of 5203 dwellings (net) at a rate of 433 dpa net. Plan be increased. In addition, revisions This clearly illustrates the unrealistically low provision (4000 dwellings net) in the may be necessary to the timescales for Draft South East Plan. The final South East Plan will need to increase the the delivery of the key sites, following requirement for Worthing both in order to contribute to meeting overall regional further work on the infrastructure needs to 2026 and in order to recognise existing levels of commitment. requirements. The review of the strategic gaps is underway and will inform the future designation and boundaries.

Turning to consider housing demand evidence from the Government’s official 2003- based projections shows that households are expected to increase by 5,000 during the period 2006 to 2016 and by 11,000 in the overall period 2006-2026. Thus the total identified housing capacity within the Plan period to 2018 will just about match the projected household increase but there will be a substantial shortfall thereafter. This provides a further indication that housing provision within the Core Strategy is wholly inadequate.

It is against this background that a review of the Strategic Gap between Worthing and Ferring is needed now. The provision of safeguarded land will also provide a reserve should any of the existing site allocations become undeliverable over the Plan period.

Preferred Preferred If the housing figures in the South East Plan are increased the target of 75% of new It is not considered that the target Option H 3 development on Previously Developed Land will need to be revised downwards in should be revised. If the South East order to reflect the need for some greenfield land to be developed. Plan figures are increased, the main emphasis should still be on the reuse of previously developed land.

201

Representor : 398 Miss Gill Chittenden

ID / Type Heading Response / Representation Officer's Recommendation Preferred Preferred What is the 'Local Authority Parking Enforcement' due next year ? Car Parking in the Policy TP1 is still considered Option TP 1 town centre in already unpopular due to the disastrous decisions to give the public appropriate as it establishes both a car park contract to NCP - a death knoll for any town. If a town is to thrive people short and long term approach to the must have easy car access to shops and leisure facilities. Park and Ride is a good providing the appropriate level of idea but not for these bulk shoppers at supermarkets, garden centres and DIY parking within the town centre, stores.

Please do not consider a reduction in public car parking, I already know of so many people who will not visit Worthing due to the exorbitant car parking charges. As for the alterations planned for the town hall car park (UDP5) one wonders where the town hall staff and visitors would park, not to mention the visitors to Sunday concerts at the assembly hall, Sunday 12th November, the car park was bursting.

Representor : 202 Mr Alistair Hume (Hillreed Developments Limited)

Agent : 385 Mr Craig Noel (Strutt and Parker)

ID / Type Heading Response / Representation Officer's Recommendation

202 Preferred Preferred The Core Strategy refers to the policy protection to be given to existing visitor Comments noted. Option EMP 4 accommodation, in the light of pressures for traditional hotel and guest house accommodation within the Borough for conversion to other uses. The Core Strategy acknowledges that much visitor accommodation has been lost in this way. However, the Preferred Options do not make positive statements about the desirability of providing new visitor accommodation within the Borough, of a form more likely to secure patronage and remain viable. It is considered that there is a market for budget hotel provision within the Borough, albeit that budget hotel operators would not normally focus on seafront or close to seafront locations. Budget hotels can be important in achieving regeneration objectives as they provide an important resource for the business community as well as recreational visitors. Sites on the edge of the town centre may be suitable, but also sites well related to the main highway infrastructure.

It is considered that the soundness of the Core Strategy would be improved by However, market forces that dictate recognising that there is a role for new visitor accommodation in helping to underpin whether new budget hotels can be the visitor economy, rather than simply policies to protect the existing sustained within the current and accommodation. Preferred Option EMP4: Visitor Economy should therefore changing climate. EMP4 clearly encourage the provision of new visitor accommodation in the form of appropriately recognises upgrading and should be located budget hotel accommodation. The following Policy wording is proposed: reviewed to includes the words “and new” after the word “encourage” in the first sentence of the preferred policy text.

'the provision of new visitor accommodation within the Borough should be encouraged where it is likely to prove viable. This type of accommodation can have significant regeneration benefits. Sites at the edge of town centre or those closely associated with the major transport routes may be suitable'.

Preferred Preferred The comparative description of the two Strategic Gaps within the Borough, their Comments noted. Option ENV 2 differing visual characteristics and associated planning issues, is supported.

203 The flexible approach towards the Eastern Gap as described here is supported. No Officers acknowledge error in change to the Preferred Options drafting is proposed. However, we would comment Paragraph 7.12 which incorrectly refers that the possible use of land within the Eastern Gap for Nature Conservation and to SPG. recreational facilities is most likely to emerge as part of the transport improvements and regenerative development identified towards the latter part of the plan period.

A landscape character assessment is being carried out on the Strategic gaps to assess their existing function and future role within the context of the Borough. The Core Strategy approach will be modified once the outcome of the assessment has been analysed..

Preferred Preferred The need for a working partnership with Adur District Council in relation to any Comment noted. Further consideration Option ENV 2 proposals to the Eastern Strategic Gap is thoroughly supported. However, we do not of ENV 2 may be required after agree that proposals for this area should landscape assessment work has been carried out in the gaps.

'only be taken forward through...Supplementary Planning Guidance'.

Any such proposals are likely to be far reaching, requiring significant levels of co- ordination between stakeholders, and should be incorporated within a firmer policy framework. An Area Action Plan would be the better policy tool. It is considered that the soundness of the Core Strategy would be improved by acknowledging that any future proposals for the Eastern Strategic Gap should be enshrined within a principle tier of policy, rather than Supplementary Planning Guidance.

204 Preferred Preferred Here the text states that 'much of the Strategic Gap between Worthing and Adur is at Although it is accepted that only a small Option ENV 3 risk of flooding'. This statement is challenged as a matter of fact. Only a very small area of the overall gap is prone to flood area of the Eastern Gap lies between the Worthing urban area and the boundary risk between Worthing and the Adur with Adur District, and of this area, none of it is known to be within an area of flood boundary the area between Worthing risk. The soundness of the Plan would be maintained by changing the reference to and the Adur boundary does contain the Strategic Gap between Worthing and Sompting, and by referring to 'some of the areas of flood risk that could be land' being within the flood risk area, rather than 'much' of it, as by no means the relevant when future development is majority of the land in the Gap is constrained in this way. considered

Preferred Preferred Page 49, Para 7.47 The recent consultant's report on the Option TP 5 viability of EWAR did indicate the objections of the Highways Agency to having a junction too near to Lyon's Farm ( based on the original EWAR route). They have indicated that they would be happier with the alternative, more easterly route. This route, although set outside of the Worthing boundary will still have traffic impacts for Worthing.

The last sentence here refers to the Highways Agency's position in connection with the relationship between the original EWAR route and the Lyons farm junction. It is considered that the Highways Agency are concerned primarily with the spacing between the original EWAR junction with the A27 and Lyons Farm junction, rather than to the creation of any further road access near Lyons Farm as stated. The soundness of the Preferred Options can be improved by amending this to more accurately reflect the Highway's Agency's position.

Page 49, Para 7.48

205 The text here suggests that the new routes for EWAR would 'bisect the existing Strategic Gap between Worthing and Adur'. As discussed in response to paragraph 7.17 (see representation 288), the reference here should be to the Strategic Gap between Worthing and Sompting, in this case because it is the former EWAR route that bisects land in Worthing Borough between Worthing and Adur. The prospect of a more easterly route would take that route entirely outside any land in the Borough within the Strategic Gap (although the route would still need to cross land within the Borough at Decoy Farm which lies outside the Strategic Gap).

Preferred Preferred Page 49, Para 7.49 The recent consultant's report on the Option TP 5 viability of EWAR did indicate the objections of the Highways Agency to having a junction too near to Lyon's Farm ( based on the original EWAR route). They have indicated that they would be happier with the alternative, more easterly route. This route, although set outside of the Worthing boundary will still have traffic impacts for Worthing.

The proposal to consider EWAR in the medium to longer-term as a piece of strategic infrastructure as part of a more flexible approach to the Eastern Strategic Gap, is strongly supported.

Page 49, Para. 7.50

The relationship between the EWAR proposals, the economic regeneration of the coastal sub-region and potential housing and employment uses as well as recreation and community uses is supported. There may be a typographical error here in referring to the 'sub-coastal region' rather than the coastal sub-region.

206

Page 49, Para. 7.51

The reference to the potential for greater public access to the Eastern Strategic Gap is acknowledged and supported. For consistency however, it may be better to follow Para. 7.48 and refer to a more easterly route for EWAR rather than 'a more central alignment'. This would improve the soundness of the Plan in terms of internal consistency.

Page 50, Para. 7.52

The importance of EWAR as part of a potential package of measures is noted and supported.

Preferred Preferred The Preferred Option is strongly supported as it gives clear policy guidance on the Comments noted Option TP 5 new approach adopted towards EWAR given the problems over viability and effectiveness of the original route. There is one aspect however of the first group of criteria which is questioned, though this is largely a matter of semantics. The text of the Policy options states 'as part of the EWAR, there will be a need for a greater public access to the Strategic Gap'. It is considered that this need for greater public access derives from a wish to make more of the Strategic Gap as a natural asset. In other words, it is not the proposals for EWAR per se that create the need for greater public access, rather that the prospect of a realigned EWAR is likely to facilitate improved public access. The soundness of the Plan could be improved be recognising this relationship more clearly.

207 Preferred Preferred The Preferred Policy Option is supported as drafted, but the soundness of the Plan Support noted Option ED 1 may be improved by acknowledging that sites for new educational provision which cannot at present be identified, are likely to be required during the Plan period, some as a result of the changes that the Core Strategy anticipates. All the sites that will emerge during the Plan period may not therefore benefit from Site Specific Land Allocations for educational purposes, but any technical land use or Policy conflict that may emerge on such non-allocated sites should be assessed against the overall approach in the Core Strategy to seek to meet educational needs as an important priority within the Borough.

Appendix Appendix 1 In connection with Preferred Option ENV2: Strategic Gaps and the indicator 'area of The targets in respect of ENV2 will be Monitoring and strategic gap land lost', we question whether it is consistent, for the duration of the dependent on the outcome of the Implementation Plan period, to specify the target as 'maintain current rates' given the flexibility that assessment of the strategic gaps, Policy ENV2 introduces in particular in connection with the Eastern Gap, in the taking into account any changes in medium to longer term. It is considered that the soundness of the Plan could be boundaries and designation. improved by introducing the words 'subject to flexibility in the latter part of the plan period' after 'maintain current rates' in the Target column.

Representor : 52 Mrs L Sobrido Heselton (Resident)

ID / Type Heading Response / Representation Officer's Recommendation

208 Chapter 4 Spatial Vision Whilst the core strategy and the rest of the proposals made interesting reading, even Comments are noted. The focus of the with the help of helpful advisers, it was very difficult to decide if the plans are suitable Core Strategy on the town centre and for our Town or not. Worthing needs to develop some form of personal identity at the seafront should ensure a distinctive moment the perception of the public and visitors alike, is that Worthing is a small identity for Worthing. coastal town with huge problems due to age imbalance.

On the one hand we have the largest concentration of over 80's and on the other hand we have a large number of young people that riot at night in the town centre.

Any development and housing must address that imbalance if we want out town to survive and improve.

Guidlbourne Centre, Bowling car park, Teville Gate, they are the examples of things that need help and must be avoided in the future.

We need something more definite to be able to give an educated opinion but it was nice to be given the opportunity to look at what could be in the future.

Representor : 335 Mr Mark Froud (Sussex Enterprise)

209 ID / Type Heading Response / Representation Officer's Recommendation Preferred Preferred Sussex Enterprise supports sustainable, mixed use developments that provide the Support noted. Option TC 1 type of properties to meet the needs of a healthy and balanced economy and community.

Preferred Preferred We support this option and would like to see the inclusion of 'business activities' in Support noted and reference to Option TC 2 the list of activities sited carefully to create a strong north south linkage. "business activities" is considered Complementing covered by the wording "B1 uses" the relationship within the preferred policy wording. between the Town Centre and Seafront

Preferred Preferred We endorse development of the seafront with mixed use year round sustainable Support noted. Option TC 7 attractions and leisure uses to increase the tourist offer of the town. Once again, the inclusion of businesses (e.g. cafes, tourist shops etc) would help support the vision and should be mentioned with this option.

Preferred Preferred We support the upgrading of business/office premises within the town centre and the Support noted. Option TC 8 designation of Business Improvement Areas.

Preferred Preferred In principle we agree with discouraging through traffic and long distance traffic from Support noted. The balance which Option TC 9 accessing the town centre. However, we are concerned this may be detrimental to needs to be addressed between the local traders e.g. retailers etc who rely on passing traffic for their custom. Local different economic needs is to be dealt traders should be directly consulted on this proposal to ascertain whether it would be with by preferred policies on detrimental to these businesses. sustainable travel.

210 Preferred Preferred One of the biggest problems affecting businesses in Sussex is the chronic shortage Support noted. The Core Strategy Option EMP 1 of suitable sites and premises. Investment in commercial and industrial buildings provides to spatial framework to over the last five years has been lower in Sussex than the average for the South encourage a sufficient supply of East. Our Annual Economic Review 2005 states that two in five Sussex businesses appropriate sites to accommodate say inadequate existing premises and a lack of new premises constrain their growth future economic growth. This is further to some extent. supplemented by the site allocations document ‘Unlocking Development Potential’

It is crucial that land designated for employment is safeguarded and there should also be an increased allocation of land for commercial development for economic sustainability. If this does not happen, businesses may be forced to relocate outside the area or hold back production. We, therefore, welcome the protection of existing employment sites and provision of new employment sites.

Preferred Preferred One of the biggest problems affecting businesses in Sussex is the chronic shortage Support noted. Option EMP 2 of suitable sites and premises. Investment in commercial and industrial buildings over the last five years has been lower in Sussex than the average for the South East. Our Annual Economic Review 2005 states that two in five Sussex businesses say inadequate existing premises and a lack of new premises constrain their growth to some extent.

It is crucial that land designated for employment is safeguarded and there should The Core Strategy provides to spatial also be an increased allocation of land for commercial development for economic framework to encourage a sufficient sustainability. If this does not happen, businesses may be forced to relocate outside supply of appropriate sites to the area or hold back production. We, therefore, welcome the protection of existing accommodate future economic growth. employment sites and provision of new employment sites. This is further supplemented by the site allocations document ‘Unlocking Development Potential’ .

211 Preferred Preferred We support the proposal to protect the existing stock of visitor accommodation for Comment noted Option EMP 4 tourists and business visitors. The regeneration proposals seek to increase tourist and business visitor numbers for which additional visitor accommodation would be required. We are, therefore, concerned that the proposed loss of bed spaces to facilitate an improvement to the quality of the remaining accommodation, may result in a net loss of visitor accommodation.

Preferred Preferred We support the proposal to focus on developing the town centre as the retail hub Support noted. Option R 1 and limit retail growth outside the town centre. We would not support a strategy which advocates out of town development due to the effects on existing infrastructure and economic activity within town centres. However, with the onus placed on the town centre as the retail core, it is imperative that it is easily accessible to visitors, customers, workers etc.

Preferred Preferred We endorse the policy to prevent the coalescence of settlements and maintain the Comments noted Option ENV 2 Borough's separate identity and look at transport improvements within the eastern gap to address road congestion.

Preferred Preferred This option states that 'new development should be discouraged in areas of high Policy ENV 3 does however stipulate Option ENV 3 flood risk. If development in such areas is considered essential, it should incorporate that any development in a high risk flood risk. If development in such areas is considered essential it should incorporate flood area must be essential. This significant measures to mitigate the effects of flooding such as sustainable drainage would be open to stringent assessment systems'. We strongly believe that new developments should not be allowed in areas as to what is considered essential, of high flood risk unless they are : under the provision of PPS25.

a) essential to sustain the local community and economy and there has been a rigorous assessment of all other options, and

212 b) they incorporate significant measures to mitigate the effects of flooding.

It is important that the option proposes to mitigate not only the effects of flooding on residential properties but equally important is commercial premises. Without adequate flood prevention, the local economy would be adversely affected and it may take many years for it to fully recover.

Preferred Preferred The Core Strategy states that 'targets to increase the proportion of energy from Comment noted. Option ENV 4 renewable sources in new development will be introduced' Option ENV4 endorses these targets and proposed that 'residential development of over ten units will be However, it will take time for new expected to use 10% of energy from renewable sources and commercial proposals technology to enable all development to will use 20%. These percentages will be reviewed during the Core Strategy period to produce 20% of energy from renewable cater for advances in technology and improving developer knowledge' Local sources. There is also a cost Authorities could take this a step further and set a consistent target for both implication for new development residential and commercial premises to be expected to use at least 20% from producing such a percentage. Houses renewable sources. need to be affordable to cope with future demand

Preferred Preferred In principle, we support the proposals for a car parking strategy for the Town Centre, Policy TP1 will help to provide a Option TP 1 including the application of maximum car parking standards for new commercial and sustainable balance between long and residential developments. Our concern is that town centre businesses may suffer short term parking in the Town Centre. recruitment and retention problems, as employees cannot easily access their place A Parking Strategy would involve public of work. It would be highly detrimental to the town's regeneration plans and consultation economic sustainability. It is imperative that local traders are consulted on the detail of these proposals. An improved public transport system needs to be in place prior to implementing parking restrictions.

Preferred Preferred Sussex Enterprise endorses the use of developer contributions from new Comments noted. Option TP 2 developments to fund infrastructure improvements. We also support the promotion of Green Travel Plans, provided that there is a provision of adequate public transport.

The traffic management option seeks to use developer contributions to introduce

213 Although more efficient public transport is desirable the Core Strategy has no influence over public transport provision. TP 2 could include some text on public transport infrastructure but this would need to be done in partnership with the County Council, and local bus operators which is more appropriately addressed through the Quality Bus Partnership.

Preferred Preferred A park and ride for Worthing town centre will help to reduce congestion and pollution Comments noted. No change needed Option TP 4 whilst improving road safety and relieving some of the pressure on city centre to policy parking. Sussex Enterprise supports these proposals. Again, consultation with local traders about the provision and location of park and ride sites is essential.

Preferred Preferred Sussex Enterprise's 'The State of Housing in Sussex 2005' says that the high cost of Support and comments noted. Option H 1 housing in Sussex may have prevented between 3,300 and 6,100 jobs being created in the Sussex economy last year. Sussex businesses need more housing in all districts particularly one and two bedroom properties. We estimate an extra 2,200 - 4,100 homes that are affordable are needed now across Sussex to ease businesses recruitment difficulties due to housing costs. The report estimates that the mortgage gap for first time buyers in Worthing Borough is approximately £40,000 for a flat or maisonette. We, therefore, fully support the proposals for a minimum of 4,000 dwellings between 2006-2026, according to the advice in the South East Plan, and at the densities suggested.

214 We also support the proposal to make use of existing stock and re-use previously developed land for housing. However, developments on brownfield sites are inherently more expensive. Gap funding, to make developments financially viable, could be met by, for example, Regional development Agencies and other partners. In addition, to make best use of existing stock, the Government should incentives or penalise owners of vanat brownfield land or other premises who do not attempt to release it for use.

Preferred Preferred To support business needs Sussex needs more housing in all districts, particularly Support noted. Option H 5 one and two bedroom properties. We support the proposal for a significant provision of one and two bedroom dwellings but urge Local Authorities to fast track planning applications to support the local economy (i.e. one and two bedroom properties).

Preferred Preferred Sussex Enterprise supports the proposals for affordable housing. The per cent of Support noted Option H 6 affordable housing required in new developments should be consistently applied and monitored to make sure that newly built properties meet demand. We also urge Local Authorities to broaden the definition of key workers to include all those who are unable to buy a home locally. This will help to address skills shortages in the Borough.

Representor : 383 St Barnabas Hospice (St Barnabas Hospice)

Agent : 382 Mr Richard Maile

ID / Type Heading Response / Representation Officer's Recommendation

215 Preferred Preferred There is a need to build a new St Barnabas in order to replace the current old and The representation is supportive of the Option HP 1 tired pre-fabricated buildings and provide a new range of facilities, thereby enabling principle of working with partners to St Barnabas to continue to deliver the highest quality of specialist palliative care identify suitable and accessible sites for service provision to the Worthing community. new care centres, though looks to draw specific attention to the enhancement of St. Barnabus Hospice. Preferred Option HP1 looks to focus on all forms of healthcare provision within the Borough, and while the important role played by the hospice is noted, to focus specifically upon an individual healthcare facility is not appropriate within the Core Strategy.

The adult hospice was originally built in 1972 as one of the first of the new style of The representation does suggest that it smaller hospices serving more localised communities. With the severely restricted may be worth altering the text of the charity funding available in the early 1970's and no real assurance as to the direction policy to refer to 'enhanced' care the hospice movement would take in the future, the short-term nature of the flat- facilities. roofed pre-fabricated buildings constructed at that time was an entirely appropriate cost saving. However, although the charity has nurtured the fabric of those buildings over the past few years (including relining the flat roof) they are becoming increasingly unsound and eventually will be deemed no longer fit for purpose.

The charity's regulating body, the Healthcare Commission, has continued to support Recommendation: Officers to review St Barnabas Hospice but has stated that, although its care remains of the highest the text of Policy HP1 to also consider standard, steps must be taken in the near future to address building and the scope for improvement to existing accommodation issues. Obviously, with the current building nearing the end of its centres. useful life, investing heavily in updating/modernisation of the existing facilities would not be cost effective or represent a good use of charitable funds. There is no 'quick fix' solution.

216 In parallel with the rebuilding of the hospice facilities the charity wishes to capitalise upon the opportunity by incorporating a range of significantly extended and enhanced services. A new, larger building would offer considerable scope for the future and would better meet the increasing needs of the community.

St Barnabas is the only specialist palliative care provider in the area and, although the rebuilding project is forced by necessity, redesigning the facilities now will enable the charity to commence sooner rather than later several vital new care criteria that it had planned following discussions with its various stakeholders.

Suggested amendment to Paragraph 8.59 as follows:

In line 4, after the words 'Worthing Together' add the words 'and St Barnabas Hospice'.

Amend Policy HP1 as follows:

After the words 'new care centres' add the words 'enhanced palliative care facilities to be provided by St Barnabas Hospice'.

Representor : 384 Gracemount Developments Ltd (Gracemount Developments Ltd)

Agent : 382 217 Mr Richard Maile

ID / Type Heading Response / Representation Officer's Recommendation Preferred Preferred Paragraph 6.4 rightly highlights the important linkages between the retail element of Representation noted. As the Option R 1 the town centre and the seafront. representation rightly points out the area around Montague street has been considered and consulted upon in some detail through the Worrthing Evolution Masterplanning exercise recently approved. The area known as Montague Place has been highlighted as an area for public realm improvements that will enhance the vista and linkage between the seafront and town centre.

However, there is a need to enhance the principal linkage between Montague Street The extent to which the area will and the seafront via Montague Place. enhanced and to what extent there is scope for further development has yet to be explored by the commissioning of a Public Realm and Seafront Strategy. The outcome of the strategy and resolved aspirations for Montague Place may appropriately be incorporated into subsequent LDF documents. It is not considered appropriate for inclusion within the Core Strategy.

218 This is currently an unattractive parking area dominated by the unsightly flank wall of the Woolworth building. Montague Place should be laid out as a piazza with limited retail development alongside the Woolworth wall to meet the needs of retailers for a larger store and to provide an attractive linkage between shop and sea. This factor was established by the recent EDAW report.

The Primary A1 shopping area should include that part of Montague Place abutting the west wall of Woolworths.

Representor : 76 Mr Tim Nicholls (South Broadwater Residents Association)

ID / Type Heading Response / Representation Officer's Recommendation Preferred Preferred East Worthing Access Road - this document seems to ignore the ever increasing EWAR's main purpose, if it is built, will Option TP 5 amount of heavy traffic using Sompting Avenue / Road and Dominion Road as either be as a relief and access road, a route to the sea front or access to the industrial estates. The road was almost although in the longer term it could started once and the longer the authorities wait the more complex side issues. Mere perform a more strategic role as the access to admire the flowers in the strategic gaps renders the road to not only coastal districts of Adur and Worthing bottom priority but is absurd to the people suffering the problems. develop economically.

We support the building of the road but its primary roles should be as an access and The original route is no longer viable relief road. due to Highways Agency objections.

219 Change in priority for the road - bringing it forward - not be like the Worthing by pass. Policy TP 5 is still applicable due to the Keep to the original route - the waste transfer station was as far as residents were provisos made with respect to it concerned a tool to obtain relief from a chronic HGV problem. performing a more strategic role in the future in tandem with future overarching regeneration policies

Remove the part about using the strategic gap for housing - this was never the intention - how can that sit with preserving it for nature conservation.

Representor : 96 Ms Jane Griffin (SEEDA)

ID / Type Heading Response / Representation Officer's Recommendation Document Core Strategy No mention is made of the Regional Economic Strategy. This document stands Preferred alongside the South East Plan (see PPS11) and should be referred to. Options

Representor : 399 Mr Andrew Rayner (Resident)

220 ID / Type Heading Response / Representation Officer's Recommendation Preferred Preferred I am writing to respond to the recent public consultation exercise regarding the future Supportive of the promotion, provision Option COM 3 development of Worthing. and maintenance of high quality community facilities. The support is duly welcomed. With regards the provision

of community facilities at Lower I am writing as a private citizen (I shall also be submitting proposals on behalf of Northbrook Farm and Northbrook Highdown Church & Highdown Centre). I support those aspects of the Core Strategy College, it is more appropriate to which are designed to promote the provision and maintenance of high-quality comment under the Unlocking community and leisure facilities (CS 8.33) especially the proposal to support the Development Potential Document development of new community facilities (CS 8.47/COM3). allocation at UDP17.

I particularly wish to endorse proposals for additional community facilities in West Durrington. I would like provision to be made for a church/community facility. Our church (Highdown Church) has a vision to develop the Highdown Centre to serve the people of this area.

Highdown Centre would not be a traditional church building that would only have limited and occasional use. Our vision is for a multi-purpose centre capable of meeting the needs of the whole person. A wide range of sports activities could be offered as well as facilities for Parent and toddler groups, Adult education, Clubs and special interest groups, Counselling and Christian worship.

221 The land North of Littlehampton Road including Lower Northbrook Farm and Northbrook College (UDP17) is currently designated for light industrial use. I would like to see provision made for the Highdown Centre to be located in this area. This would be a good location as it is close to the local community (within easy walking distance of local housing estates) and would complement existing and proposed developments in this area.

I trust that these proposals will be incorporated in the future plans for the development of community facilities in this part of Worthing.

Representor : 401 Richard Battson

ID / Type Heading Response / Representation Officer's Recommendation

222 Preferred Preferred Reduction of carbon emissions is of paramount importance in ensuring sustainability Comments noted. The Department for Option ENV 4 of our world. To accord with the governments new sustainability strategy to reduce Local Communities and Local greenhouse gas emissions (also the Kyoto protocol carbon target) any new Government (DCLG) has recently development should have the effect of reducing such emissions by such means as published 'Planning and Climate using energy 100% from renewable sources, using building materials whose Change' Consultation Dec 2006, which embodied energy is small (i.e. timber instead of concrete), whose pollution in sets out how spatial planning should manufacture is small, whose transport limits are small and whose demolition at the contribute towards reducing emissions end of their useful life can be done with minimum energy and enabling maximum re- and stabilising climate change. Along use. with this the DCLG has also published a package of measures. This includes the "Code for Sustainable Homes" "Building a Greener Future” and the "Code for Sustainable Homes". All recently published advice will need be absorbed where appropriate by the emerging Core Strategy and will establish the Council's expectations with regards to sustainable development measures and the environmental performance of development to accord with principles established by existing and emerging government guidance.

223 Tree planting should be made mandatory to balance any residue of emissions. Recommendation: A review of the Sustainable Development Preferred Policies within the Core Strategy in light of the above will be undertaken to ensure policies taken forward are consistent with national guidance and the emerging South East Plan.

The paltry 10% leading to 20% of energy from renewable sources is 7.33 is woefully It is not considered viable or achievable inadequate to meet the need for sustainable development. that the Core Strategy promote new development produce 100% of energy from renewable sources .

Preferred Preferred Needs more direct policy on encouraging bus travel by providing facilities for Strategy has no influence over public Option TP 2 punctual bus service that are pleasant to use, for example : transport provision. TP 2 could include some text on public transport infrastructure but this would need to be done in partnership with the County Council, and local bus operators which is more appropriately addressed through the Quality Bus Partnership.

Dedicated bus lanes or overflow routes.

Bus controlled traffic lights.

Bus stops that are free of parked cars.

Bus lanes/Roads free of humps which make for an uncomfortable ride (I find it almost painful and the older people more so riding in bus over humps)

224 Better coverage by bus services, particularly evening with a min 20 min service during the day and 60 min service during the evening/Sunday on all routes.

Representor : 402 Colin Knappitt

ID / Type Heading Response / Representation Officer's Recommendation Chapter 1 Introduction Having seen light pollution clauses established in the Local Plan and with its Include wider reference to light pollution inclusion this year under the Statutory Nuisance regime, it appears from my perusal in the portrait of the Borough of the three documents to be getting short shrift.

Page 7 - Environmental Characteristics - no mention of light pollution in 1.17 - 1.21.

Section Sustainable No mention of energy conservation through the use of external lighting. Comment is noted. Development The use of Breeam standards should alleviate this issue Preferred Preferred There is no mention of light pollution here but ambiguity in "....concerned with Comments are noted. Option ENV 4 emissions soil, water....." Presumably, this should read "....emissions, soil....." rather that the less likely but possible " ....emissions from soil..." 7.27

225 The reading of para 7.35 is that development must be both harmful to quality of soil Policy ENV 4 does advocate reviewing and water resources and cause excessive noise and light pollution before it will be the percentage of renewable energy avoided. It looks like we need a series of OR's rather than AND's here. sources over the Core Strategy period

Representor : 31 Ms Emily Watts (The Co-Operative Society)

ID / Type Heading Response / Representation Officer's Recommendation Preferred Preferred With regard to preferred option EMP2 we consider that this should allow for a An idea of what criteria to be used is Option EMP 2 criteria-based policy approach to potential employment development in locations needed before assessing any which are not specifically located within the LDF. This would enable future development applications for this type of development to be considered against the relevant criteria and determined on this basis.

Preferred Preferred We support the expansion of the Primary Shopping Area northwards under Policy Support noted. Option R 1 R1

Preferred Preferred We support the approach in preferred option H2 that residential development should PPS3 indicates that 30 dph is the Option H 2 make the best use of land, however, we consider that the minimum density of 35-40 national indicative minimum and allows dwellings per hectare identified in this policy is low when compared with the range of for Local Planning Authorities to set out densities set out in PPG 3 (30 to 50 dwellings per hectare with a more efficient use a range of densities across the plan made of land within accessible locations) and draft PPS3 (which recommend a area rather than one broad density density of 45 to 75 dwellings per hectare in urban areas). Any future policies should range. The policy approach will need to allow for a greater degree of flexibility in the density of new developments, for be reviewed in the light of this new example in accessible and sustainable locations, in line with national planning guidance. guidance.

226 Preferred Preferred We support the approach set out in the preferred option H5 that a mix of housing Support noted Option H 5 types and sizes should be provided in new developments, particularly the need for a significant provision of one and two bedroom dwellings in the Borough, which are likely to be suitable in central locations such as site UDP 2.

Preferred Preferred We agree that a flexible policy approach should be taken to the provision of Support noted. The policy already has Option H 6 affordable housing which considers the size and viability of the development (as flexibility regarding site costs and recognised within para 8.28 of the Core Strategy). We consider however that this viability. should be reflected within preferred option H6 which should recognise that it may be appropriate to apply flexibility to any affordable housing provision where the provision of affordable housing may impact upon the viability of any redevelopment.

Representor : 107 Ms Janyis Watson (Sussex Wildlife Trust)

ID / Type Heading Response / Representation Officer's Recommendation Preferred Preferred We are concerned that whilst the policies aim to deliver sustainable development, Observations noted. Under the Option TC 7 there is no mention of the natural environment or the 'services' it provides in the Sustainable Development Spatial regeneration section. This is of particular concern when considering development on Objectives listed on page 18 of the draft the coast with respect to the effects of climate change, which are predicted locally Core Strategy the enhancement and (e.g. Policy TC7). protection of the natural environment is given acknowledgement.

227 Recommendation: The Department for Communities and Local Government has recently issued statement for consultation on Planning and Climate Change. In reviewing this consultation statement further local guidance may be incorporated within the Sustainable Development Chapter of the Core Strategy.

Preferred Preferred The Sussex Econet Observations noted. Officers to review Option TC 9 the scope of including biodiversity and Policy TC9, A Connected Town, offers the opportunity to establish a multi-functional coastal environment issues within the green network across the Borough. This approach is being explored by other Sustainable Development Chapter. planning authorities, e.g. Brighton and Hove Draft Core Strategy, Objective SO21, Policy OS3. Sussex Wildlife Trust is promoting the establishment of an Ecological Network for Sussex – The Sussex Econet. The approach of an ecological network has been taken up by a number of regions in England following the European model and recognises that isolated designated nature sites will not halt the decline in biodiversity.

When assessing potential sites for development the local authority should be mindful of the connectivity of existing habitats in the area. Of particular importance are natural linear features such as river systems and hedgerows that can provide wildlife corridors. As well as areas of ancient woodland and shaws and other semi-natural habitats that could provide 'stepping stone' sites for species movement.

228 The importance of the size of connected habitat cannot be underestimated in terms of the range and number of protected and BAP priority species that it would be able to support. The importance of this connectivity and species movement is now recognised in Government guidance and is particularly important when planning for climate change.

PPS9 - Paragraph 12 states that: ‘Local authorities should aim to maintain networks by avoiding or repairing the fragmentation and isolation of natural habitats through policies in plans. Such networks should be protected from development, and, where possible, strengthened by or integrated within it.’

The draft of the South East Plan further supports this in policy NRM4 (Conservation and Improvement of Biodiversity) which states: ‘In the development and implementation of policies, plans and strategies, local authorities and other bodies shall seek to avoid net loss of biodiversity, and actively pursue opportunities to achieve net gain across the region by:

iv) identifying areas of opportunity for biodiversity improvement targets reflecting those in figure NRM2 and pursuing opportunities for biodiversity improvement in particular large-scale habitat restoration, enhancement and recreation in the areas of strategic opportunity for biodiversity improvement.

229 vi) establishing accessible green networks and open green space in urban areas to create habitats of importance to local communities.’

Preferred Preferred Policy ENV2, Strategic Gaps, is robust in its protection of the Western Gap, but fails The comments regarding the eastern Option ENV 2 to protect the Eastern Gap sufficiently. We support its retention and the development gap are noted. Policy ENV 2 is of areas for nature conservation. The purpose of strategic gaps is to prevent considered to give the appropriate coalescence of settlements, i.e. is essentially about stopping a negative rather than recognition of distinctiveness between delivering a positive. the west and eastern gap. It has been considered that greater flexibility of the eastern gap may be required in the longer term to meet transport improvements. It should also be noted that a landscape character assessment is being carried out on the Strategic gaps to assess their existing function and future role within the context of the Borough. The Core Strategy approach will be modified once the outcome of the assessment has been analysed

In addition strategic gaps should be promoted because of their positive biodiversity value. This has two elements:

1. Biodiversity value of the land within a strategic gap

2. Network function, linking areas of wildlife value and preventing fragmentation of habitats.

230 The West Sussex coast is one of the most heavily urbanised in Europe and these gaps represent one of the few places that wildlife can “get through”. These provide migration routes for birds, corridors for amphibians, butterflies, badgers, foxes, barn owls bats etc.

About 7% of the area of SSSIs and SNCIs in West Sussex lies in strategic gaps. This is not significantly different to the situation over the whole of West Sussex, but the location of strategic gaps is important. Strategic gaps interact with the concept of an ecological network. Some merge with the county ecological network (Econet) others form local links to Econet.

There are many examples of where species are in retreat even though individual sites are in favourable condition. Species need to live in a functioning environment. Developing an effective ecological network so species can move and adapt to a changing environment is essential in order to achieve biodiversity objectives (e.g. Convention on Biological Diversity, UK Biodiversity Strategy and the Sussex BAP - www.biodiversitysussex.org)

Instead of seeing strategic gaps as places where something doesn’t happen we should turn this around and see them as places where something does happen. Instead of seeing strategic gaps as gaps between urban settlements, we could see them as elements within an ecological network – so the towns become the gaps within the network!

Preferred Preferred Climate change is currently the greatest threat to biodiversity. The effects are also Objection noted. Option ENV 3 predicted to be socio-economically very costly. There is Government commitment to preventing climate change and this should be reflected in Policy ENV3 which is only

231 The Department for Local Communities and Local Government (DCLG) has recently published 'Planning and Climate Change' Consultation Dec 2006, which sets out how spatial planning should contribute towards reducing emissions and stabilising climate change. Along with this the DCLG has also published a package of measures. This includes the "Code for Sustainable Homes" "Building a Greener Future” and the "Code for Sustainable Homes". All recently published advice will need be absorbed where appropriate by the emerging Core Strategy and will establish the Council's expectations with regards to sustainable development measures and the environmental performance of development to accord with principles established by existing and emerging government guidance.

Recommendation: A review of the Sustainable Development Preferred Policies within the Core Strategy in light of the above will be undertaken to ensure policies taken forward are consistent with national guidance and the emerging South East Plan.

232 Preferred Preferred Policy ENV4 is in need of strengthening as it fails to stress the need to ensure Policy ENV 4 does advocate measures Option ENV 4 biodiversity gains rather than merely compensate for loss, as per PPS9 and PPS1 to compensate for losses of natural habitats if development takes place.

ENV 4 also states that development will be refused if it has negative effects on biodiversity.

Preferred Preferred We do not consider Park and Ride schemes to be a sustainable option. They may The provision of a Park and Ride site Option TP 4 contribute to a reduction in congestion in town centres, but do not reduce car use. will only be considered if the criteria set This can lead to an increase in car use and a reduction in bus use in rural areas. out in TP 4 are met and there is no This will lead to an increase in carbon emissions and land take. overriding conflict with national guidance, The issue of reducing car usage must be considered within the range of options which look to bring forward alternative more sustainable modes of travel. It is accepted that Park & Ride alone cannot reduce car usage.

TP 4 is still valid policy approach. Preferred Preferred The East Worthing Access Road (Policy TP5) is not a sustainable transport solution. EWAR would reduce congestion on the Option TP 5 It will not reduce the number of cars on the road and therefore congestion in the A27 and provide access and egress town centre. It also compromises the protection of the Eastern Strategic Gap. relief from the eastern industrial estates. It would only be built after considering the future role of the strategic gap.

Policy TP5 is therefore still applicable

233

Representor : 410 Ms Amy Reid (Environment Agency)

ID / Type Heading Response / Representation Officer's Recommendation Chapter 1 Introduction Water Quality There is a need to ensure that the Core Strategy is a concise document that does not simply repeat Government As highlighted above, we are concerned about the narrow description provided in the guidance. However, there may need to document of the Worthing environment and the failure to even acknowledge the be additional references added to the water environment. As per our earlier comments, we would like to see the need to introductory section to ensure that there protect water quality; both surface waters and groundwaters recognised as a are adequate links to the relevant component of Worthing’s environment that should be protected. issues but without simply replicating information contained in circulars and policy statements.

Waste Management

These paragraphs do not cover issues relating to waste, waste management performance or baseline data for waste in the borough. All Local Authorities have a role to play in the sustainable management of waste arisings in their boroughs. Dealing with an increasing amount of waste arisings from all sources is an issue, which all Local Authorities must tackle. At the very least a sustained and in some cases increased effort is required by Local Authorities to ensure the diversion of Biodegradable Municipal Waste from landfill and to increase recycling rates to meet statutory targets.

We would like to see more comprehensive coverage of environmental issues relating to waste in the Core Strategy document, including data on waste management in Worthing Borough. Some sources from which such data can be obtained include:

234 Environment Agency - including publicly available data on all waste streams including Commercial & Industrial, Hazardous and Construction Demolition wastes from our website (http://www.environment- agency.gov.uk/subjects/waste/1031954/315439/923299/?version=1&lang=_e)

Defra - including their annual Municipal Waste Management Survey (http://www.defra.gov.uk/environment/waste/statistics/index.htm)

Department for Communities and Local Government - data on all aspects of local government performance including waste management (http://www.bvpi.gov.uk/pages/keyFacts_BVPI.asp?lastpage=1&aid=188)

In addition there is the South East England Regional Assembly, West Sussex County Council, and of course the records held by your Council.

Chapter 2 Issues Facing We are concerned about the lack of reference made to water quality. We suggest Specific reference to water quality can the Borough that this section includes the protection of surface and ground water, particularly be added to the environmental issues. when considering abstractions (including protected rights abstractions) and the It is not considered necessary to alter recent drought. This could also be linked to the existing issue of 'impact of climate the reference to land contamination, as change'. this encompasses the proposed changes.

The issue 'need to address land contamination' should be altered to ‘identify and remediate areas of land contamination' and linked to 'effective use of land and resources'.

235 Chapter 3 Impact of This section seems to present a fairly limited selection of Plans, Policies and This section demonstrates the main Other Policies Programmes that might be relevant to the Local Development Framework for strategic documents that influence the and Strategies Worthing Borough. We would like to see the following also included: Core Strategy. It is considered that cross reference to specific topic guidance, directives and circulars is more appropriately located in Appendix 1. The Core Strategy must reflect the spatial strategy for Worthing and not At an international level, we suggest that the following be added: simply repeat National Guidance.

Landfill Directive

This sets targets for Member States to achieve the diversion of Biodegradable Municipal Waste (BMW) from landfill. Decomposition of BMW in a landfill environment produces methane gas, a potent ‘greenhouse gas’ driving climate change.

Water Framework Directive 2000/60/EC

It is important that the WFD is acknowledged especially given that it doesn’t allow deterioration of a waterbody and also expands the scope of ‘water protection’ to include all waters, surface waters and groundwater.

At a national level, we suggest that the following be added:

Waste Strategy 2000 / Review of England’s Waste Strategy 2006

236 This sets out the Governments strategy for dealing with waste, and transposes/implements the targets for the diversion of Biodegradable Municipal Waste from landfill.

At a regional level, we suggest that the following be added:

RPG9

The policies set out in Regional Planning Guidance for the South East RPG9 apply until the South East Plan is adopted.

At a county level, we suggest that the following be added:

West Sussex Minerals and Waste Development Framework (in development) This Framework is a portfolio containing the structure and local plans prepared under the former planning system and new local development documents.

Joint Municipal Waste Management Strategy 2004-2009

This aims to provide a framework for the work carried out across the County to cut waste and recycle more.

Joint Materials Resource Management Strategy 2005 – 2035 (draft)

237 This includes key policies, objectives and commitments for all the local authorities of West Sussex. An action plan focused on waste prevention, waste reuse, recycling, composting, and end treatment and final disposal. A real alternative to the previous high levels of landfilling of residual wastes in West Sussex.

Preferred Preferred We stress that Policy ENV3 on Climate Change and supporting paragraphs are both The comments are noted. Option ENV 3 incorrect and unacceptable with regard to reference to flood risk. Our reasons for this are highlighted in the following sections:

Paragraph 7.20 The supporting paragraphs and Policy ENV 3 will be reassessed to take into account the response comments .

We highlight that there should be a presumption against any development within flood risk areas. This paragraph appears to support flood plain development through mitigation measures. We would rather see a policy stating that development in the flood plain should be resisted.

In addition, this paragraph seems to imply that Sustainable Drainage Systems (SuDS) are a mitigation measure for development in the flood plain, which is not the case. We highlight that SuDS are not a mitigation measure for building in the floodplain, but are specific drainage designs, which should be used on all development sites regardless of their location.

Paragraph 7.21

238 While we agree that any new development in undeveloped areas within Flood Zone 3 should be avoided, the final sentence of this paragraph should deleted. This implies that the construction of new defences will be seen as unsustainable and is totally contrary to the theme of this section within the Core Strategy.

Paragraph 7.22

This paragraph implies that only development in Flood Zone 2 requires a FRA. However, we highlight that all development sites require a FRA in accordance with PPG25 and the emerging PPS25. The range and scope of any such FRA will be dependent on the type and location of the development.

Paragraph 7.23

This paragraph is not exactly correct and our comments above relating to both SuDS and FRA's also apply.

Paragraph 7.26

We suggest that the second sentence of this paragraph is amended to read….” should be to protect and enhance sites that are important for nature conservation and biodiversity”.

Paragraph 7.3.2

239 In addition to the policy identified in the Sustainable Development section (paragraph 7.32) it would be useful to have a policy or guidance for developers specific to ecological surveys. The addition of this paragraph will make it clear when they would be required to submit an ecological survey, mitigation and enhancement measures, and could be reworded very similarly to Policy 7.3.2. This will help to ensure that development is steered away from inappropriate sites.

Suggested Rewording of ENV 3

As a result of our comments above we suggest that Policy ENV 3 should be completely re-written. In its current stance this policy is inconsistent with the principles of both PPG and the emerging PPS 25 and therefore fails the test of soundness in accordance with Test 4 (Inconsistency with National Planning Policy)

As a summary, we suggest that it is essential that the following points are addressed in your reworded policy:

PPG 25 promotes a ‘precautionary approach’ to ensure that new developments are directed away from areas at risk of flooding.

The wording of this policy should therefore make it clear that all proposals for residential development will be considered in accordance with the sequential tests advocated in government guidance (PPG25).

Development should be supported by an appropriate FRA as set out in Government guidance.

240

While flooding is not a major concern within the Worthing Borough, the Core Strategy should acknowledge the various forms of flooding (in accordance with Annex C, PPS25). Amongst other sources, this states that flooding can also occur from overwhelmed sewers and drainage systems as well as rising groundwater and overland flows. We note that any SFRA must also assess all sources of flooding.

While we are certainly supportive of promoting the use of SuDS, it is important that SuDS are not relied upon as a mitigation measure against flooding. Instead, they should be seen as a way of minimising flooding through various drainage design systems. These may be used individually or in combination and include:

Water butts for rainwater harvesting and recycling

Permeable surfaces for drives, car parking and roads

Filter strips and swales

Infiltration trenches/basins

Detention basins (dry balancing ponds), retention ponds (wet balancing ponds) and wetland areas.

241 In addition to aiding drainage, the use of SuDS also have wider advantages which include reducing the risk of pollution of both surface and ground waters, promoting biodiversity and aiding rainwater harvesting and the recharge of aquifers.

Preferred Preferred Paragraph 3 of Policy ENV4 Comments are noted. Option ENV 4

There is no reference in this policy to the requirement for biodiversity protection and Consideration to be given to reviewing enhancements to be part of all development and therefore it does not promote net the text to reflect where omissions may gain in biodiversity as required by PPS9. have been made and which are not already covered by other guidance.

As a result of these comments, we suggest that this policy is reworded as follows: The Core Strategy needs to have a strategic focus and if areas are covered in regional and national guidance they should not be included in a Core Strategy.

“Measures should be sought through all development proposals to protect sites of nature conservation and biodiversity. Any negative effects should be mitigated, and biodiversity enhancements sought through all developments. Development should result in a net improvement in biodiversity”.

Preferred Option ENV 4 could also include:

Site Waste Management Plans

242 We would recommend that this document requires development contractors to have in place Site Waste Management Plans (SWMPs). These are an important tool for construction companies and their clients to improve their environmental performance, meet regulatory controls and reduce rising costs of disposing of waste. Site Waste Management Plans: Guidance for Construction Contractors and Clients is a voluntary code of practice which sets out the basic structure of SWMPs and how companies can use them to improve and manage their operations at all stages of site activity (http://www.constructingexcellence.org.uk//resources/publications/view.jsp?id=2568).

Recycling facilities

We would recommend that this document requires development proposals to include provision for recycling facilities within new developments i.e. dedicated space for internal storage/kerbside collection of recyclables in residential developments and local recycling centres to be incorporated into public spaces / community facilities.

Use of recycled/secondary materials

We would recommend that this document requires development proposals to include the use of recycled materials / materials from secondary sources wherever practicable, especially re-using those materials that are produced on site i.e. recycled aggregates.

Commercial & Industrial waste

243 The local authorities in their role as Waste Collection Authorities will be handling at the very least some commercial waste arising from those businesses within the district that have requested such a service from them. There are opportunities to integrate the management of waste under the control of local authorities and that from businesses, achieving significant efficiencies, and positive economy of scale.

Preferred Preferred The relationship between Brownfield/Previously Developed Land and land It is not considered necessary to repeat Option H 3 contamination should be made within this policy, with the inclusion of "in compliance national guidance within the policy. with PPS23". Also there is no mention of land contamination and the benefit from remediation to protect surface and ground waters from pollution.

With regards to bullet point 1, we note that the quality of the environment should also be enhanced in terms of biodiversity.

Appendix Appendix 1 ENV4: Sustainable Development. Comments are noted. Targets for ENV4 Monitoring and will be reviewed together with an Implementation The first indicator and target are not very strong and are very subjective. We assessment of the need for any question how it is proposed that the ‘negative impact on sites of nature conservation additional targets. and biodiversity’ will be measured?

Sustainability measures should be robust and tangible, and objectively measured. This could be for example ‘the number of developments going ahead against Environment Agency and Natural England conservation advice’ (should be reduced), or ‘the number of developments (over 10 dwellings) incorporating biodiversity enhancements’ (all).

244

[Note that English Nature has now been incorporated into the new Natural England.]

No mention is made in the Core Strategy of environmental targets (both local and national) that need to be met over the coming years. It may be that these will be covered in the Sustainability Appraisal LDF document. These should include:

SSSI targets to reach favourable status.

The Water Framework Directive targets for all waters to reach good ecological status (or potential).

Biodiversity Action Plan targets.

These should be incorporated at the LDF level to ensure that they are consistently addressed in the local area.

Appendix Appendix 3 The emerging PPS 25 should also be acknowledged in this section. It is essential The comments on PPS 25 are noted. National that the importance of undertaking a SFRA as a fundamental method of flood risk is Planning also included in the explanatory text. We offer the following wording for you to work Policies with:

“This policy statement explains the need to consider flood risk at all stages of the PPS 10 relates to policy to be taken planning and development process in order to reduce vulnerability and future into account by waste planning damage and risks to people. This is achieved primarily through the requirement for a authorities. The County Council carry SFRA to be undertaken to inform the preparation of Development Plan Documents out this role. (DPD’s), particularly for the Core Strategy and the ‘Unlocking Development Potential’ DPD”.

245 Planning Policy Statement 10: Planning for Sustainable Waste Management should also be added to this list. This Policy sets out issues to be taken into account by waste planning authorities and forms part of the national waste management plan for the UK.

PPS10 specifically states that:

‘The policies in this PPS should be taken into account by waste planning authorities in discharging their responsibilities; by regional planning bodies in the preparation of regional spatial strategies; by the Mayor of London in relation to the Spatial Development Strategy in London; and, in general, by local planning authorities in the preparation of local development documents. They may also be material to decisions on individual planning applications. These policies complement other national planning policies and should be read in conjunction with Government policies for sustainable waste management, in particular those set out in the national waste strategy’.

Appendix Appendix 4 The definition of Brownfield/PDL should include the potential for contamination from Comments noted Glossary previous land use.

Representor : 397 Mr Peter Stafford

246 ID / Type Heading Response / Representation Officer's Recommendation Chapter 4 Spatial Vision Worthing needs to be a place that residents are proud to live. We have much to be Support noted pleased about, such as the Pavilion, Assembly Hall, Connaught Theatre, Museum, Pier, department Stores, Hospital etc. but we still don’t punch our weight in other areas.

For example, the town does not possess, or to my knowledge even plan for :

a) a single business class hotel

b) an Olympic size swimming pool

c) any marine leisure facilities (e.g. Marina or sports centre)

The proposed redevelopment of the Teville Gate area is welcome in that it will give the town some presence, but does not appear to address any of those issues.

Section Climate Section 7 does not make it clear that protection from the sea will be a priority. Whilst Comment noted Change this may be the case (I've not seen the shoreline management plan), it needs to be clearly stated to reassure residents that their properties will be safeguarded against this threat.

It also needs to be clear whether such protection will be afforded to all parts of the borough.

247 Section Transport While the borough council is not in a position to determine the future road A Worthing bypass requires funding programme, section 3 should reassure residents that the case is strongly made for a and commitment from the Government Worthing bypass. and the Highways Agency.

Far smaller places have bypasses, and the lack of a south coast artery restricts There is no commitment from the economic opportunities in Worthing. Questions need to be raised about how the Government to build a bypass for options for relieving congestion have been costed. Whilst the government wishes to Worthing. In fact previous Government discourage further road building, surely this should mean surface roads. Tunnels are studies have recommended a bypass a different proposition. The notion of a Worthing bypass going under the Downs (South Coast Multi Modal Study 2002) should not be discounted on grounds of cost because of the long term benefits, but it was rejected by the Secretary of namely : State for Transport on environmental and cost grounds.

a) reduction of traffic levels within the borough (time and fuel saving, lower pollution The preferred approach to transport levels within the borough) and travel in the Core Strategy reflects the reality that the A27 bypass option is unlikely to be considered until 2016.

b) the presence of a bypass could free some land for a park and ride scheme

c) the environment impact will be minimal Preferred Preferred Smaller towns than Worthing have park and ride schemes to reduce parking facilities No comment needed. TP 4 still Option TP 4 could conceivably be developed in the area where the A27 joins Titnore Lane - considered a sound approach should a probably in conjunction with the development of a bypass. site for Park & Ride come forward

248 Again it would be good for residents to see that there is such a vision, and that the Borough is actively trying to make its case in the widest context.

Section Housing One reason why we have so much congestion, is the space each of us occupies. I It is considered that Policies H2, H3 don’t see this fact given any prominence. As stated in the document, there is and H4 provide the correct emphasis precious little room for expansion outwards, so a greater emphasis should be placed on making the best use of land and on going upwards and downwards. It would be good for residents to know that there resources and maximising opportunities could be disincentives/penalties for : for redevelopment.

a) property unoccupied for more than a specified time

b) property used intermittently (i.e. second/holiday home)

c) replacement of private gardens by car parking spaces

d) parking of environmentally unfriendly vehicles (i.e. 4 wheel drives)

e) property extensions

f) under occupied property (i.e. 1 person living in a 3 or 4 bedroom house)

Representor : 126 Mr David Paine (GOSE)

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ID / Type Heading Response / Representation Officer's Recommendation Chapter 5 Key Diagram We are pleased to see a key diagram The key diagram can be amended to show the external links and relationships with neighbouring areas. Consideration will be given to a more detailed town centre diagram to highlight the major opportunity areas.

Referring to PPS12, paragraph 2.13, please show external links and relationships with neighbouring areas and ensure that soundness text vi is addressed.

Also, we suggest major opportunity areas could be shown diagrammatically (a star would do) rather than just subsumed in a more general shading such as town centre.

Preferred Preferred Please refer to paragraphs 24 and 25 of PPS7: Sustainable Development in Rural Comments noted. Option ENV 2 Areas, which set the general context for our objection.

We are not convinced about the proposed retention of rigid old style strategic gap A landscape character assessment is designations in policy ENV2 although we can understand the authority’s objective to being carried out on the Strategic Gaps maintain settlement identity and avoid coalescence. You risk a formal objection at to assess their existing function and submission. future role within the context of the Borough. The Core Strategy approach will be modified once the outcome of the assessment has been analysed.

250 We would accept that the core strategy and other development plan documents should demonstrate that the decisions made in selecting broad locations on the key diagram and sites on the proposals map have taken account of this objective, if that is the authority's wish and if it can demonstrate that development needs can be met in full.

However, we can see no point in defining strategic gap boundaries once major development areas have been identified because to do so might place unnecessary constraints on the rural economy. Indeed, it may undermine what you are seeking to achieve with the East Worthing Access Road.

This rules-based approach reinforces our concern that the core strategy will be weak in terms of strategic thought and proactive focus on delivery.

Preferred Preferred What does policy ENV3 add to national policy? How does national guidance impact It is accepted that Policy ENV 3 as Option ENV 3 in reality on how you propose to implement, say, your regeneration strategy? Does it worded repeats national guidance restrict what you can do in certain parts of areas identified for regeneration? In other provided by PPS25. words what are the spatial implications for Worthing?

251 The Council is currently undertaking a Strategic Flood Risk Assessment, (SFRA) to help inform the Core Strategy’s preferred spatial approach and Site Allocations to come forward through the Unlocking Development Potential Document. The Study will test both the spatial vision and objectives outlined in Section 4. The Council will respond once the conclusions of the study have been analysed.

Preferred Preferred What value does policy ENV4 add to what you are already supposed to have done Comments noted. Option ENV 4 through sustainability appraisal in selecting broad locations for housing and other strategic development? Generally, this is very bland and lacks local distinctiveness. The Department for Local Communities and Local Government (DCLG) has recently published 'Planning and Climate Change' Consultation Dec 2006, which sets out how spatial planning should contribute towards reducing emissions and stabilising climate change. Along with this the DCLG has also published a package of measures. This includes the "Code for Sustainable Homes" "Building a Greener Future” and the "Code for Sustainable Homes". All recently published advice will need be absorbed where appropriate by the emerging Core Strategy and will establish the Council's expectations with regards to sustainable development measures and the environmental performance of development to accord with principles established by existing and emerging government guidance.

252 Recommendation: A review of the Sustainable Development Preferred Policies within the Core Strategy in light of the above will be undertaken to ensure policies taken forward are consistent with national guidance and the emerging South East Plan.

Officers to review the extent to which Preferred Policy ENV 4 repeats national and regional guidance as opposed to concentrating on areas which provide an approach based upon local distinctiveness.

Preferred Preferred How do you propose to address public transport as a component of more Officers to review appropriate text to Option TP 2 sustainable travel? provide appropriate reference to improving public transport infrastructure.

Preferred Preferred We have already raised the issue about this being a strategic objective, but have Further amendments will be needed to Option H 1 some detailed comments. ensure that there is sufficient flexibility should the figures in the South East Plan be increased. In addition, revisions may be necessary to the timescales for the delivery of the key sites, following further work on the infrastructure requirements. There also needs to be more detail regarding the contingencies should some sites not come forward.

253 Given that published RSS is still RPG9 as informed by the adopted West Sussex The appendix to the Core Strategy sets Structure Plan, we need you, please, to address soundness test ix (flexibility) to out in detail the quantity of development explain how the core strategy might cope with a range of reasonably foreseeable from each of the identified sites, an outcomes such as draft RSS figures or existing structure plan requirements rolled assessment of the contribution from forward, for example. What happens if the sources identified are not enough to meet unidentified sources, together with the RSS housing requirements? What is your strategy then? phasing. These details could be included in Policy H1, but would need to be more concise.

In order to address soundness test viii (monitoring and implementation) you will need to say how much development is expected to come forward from each source of supply.

In order to address the last part of PPS12, paragraph 2.10, and soundness test iv (spatial & consistent with national policy) we would expect you to provide a broad indication of where the main sources of supply are located and how much development is expected in each broad location. What are the implications for particular locations (community facilities, supporting infrastructure etc) for the broad quantum of development expected?

Have you considered setting out policy H1 along the lines of:

- aaa already completed since 2006 (any significant distribution issues?);

- b under construction as at 2007 (any significant distribution issues?);

- c with PP as at 2007 (any significant distribution issues?);

- d at West Durrington (carried forward local plan allocation);

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- m allowance for unidentified windfall PDL to 2018 (any significant distribution issues?);

- xxx on sites identified in Town Centre;

- y on sites to be identified in Seafront; etc ?

In addition, have you considered including, for each broadly identified location, an explanation as to what the provision of housing means in terms of other development strands in the locality and how they join up to support place-making for a sustainable community?

Monitoring and Implementation Framework

We will expect to see a strategic housing trajectory provided as part of supporting evidence to demonstrate how and when the different elements of supply will come on stream and how contingencies will be triggered in time to maintain continuity of housing supply and deal with uncertainties over the emerging RSS.

Preferred Preferred We are uneasy about this policy. Why would you wish to potentially block the more The intention is not to prevent Option H 4 efficient use of land through redevelopment of the existing housing stock? You may redevelopment unless there is a net feel that amenity issues could be covered by other generic policies if that is the loss of housing, this is set out in the driver for this issue. Alternatively, what is your housing market and housing needs background text but could be clarified in assessment telling you? the policy text.

255 Once gain, this rules-based approach (and others like it) reinforces our concern that the core strategy will be weak in terms of strategic thought and proactive focus on delivery.

Preferred Preferred We wonder why Worthing is seeking 30% affordable housing on sites of 15+ An assessment of the impact of a range Option H 6 dwellings or 0.5+ ha when neighbouring authorities are seeking more. What is the of affordable housing thresholds and justification for this? percentages on the viability of development is underway and will inform the appropriate level of affordable housing to be sought.

How are you replacing larger social homes lost through Right to Buy on higher density developments?

Representor : 100 Ms Patricia Butcher (The British Horse Society)

ID / Type Heading Response / Representation Officer's Recommendation Section Transport Whilst Worthing is predominately urban in character, it does have a significant area Comments noted. of countryside to the north of the Borough that falls within the AONB.

256 The area contains important public rights of way, which provide links to the South Consideration will be given to adding to Downs and many equestrians are stabled or ride in this area or in the strategic gaps the introductory text. and gain access to the beach, as well as the downs.

In the West Structure Structure Plan pg 48 para 202, it states "the public rights of way network of west Sussex is therefore an important resource for residents as well as visitors giving access to the distinctive countryside of the County"

The structure plan in policy NE11 (b) (6) states that local plans will include policies to ensure that "new development does not result in the loss of, or adversely affect, an important recreational resource (including open space and rights of way) unless a new resource is provided which is of at least equivalent value or measures are undertaken to mitigate the harmful effects of the development".

PPG17, para 32, states that "Rights of way are an important recreational facility, which local authorities should protect and enhance. Local Authorities should seek opportunities to provide better facilities for walkers, cyclists and horse riders, for example by adding links to existing rights of way networks"

257 I may be mistaken, but I could not find any reference to public rights of way in your Core Strategy. Increasing traffic volumes are of great concern to vulnerable road users, whose routes are being severed. The A27 is a barrier for horse riders in particular along almost most of its length. The Society feels that a reference to the Borough Council's commitment to protect and enhance public rights of way should be included in the Core Strategy, possibly in para 8.41.

Representor : 462 Mrs S.A. Groves (Resident)

ID / Type Heading Response / Representation Officer's Recommendation Preferred Preferred Would support a policy which promotes tourism through meeting demand for a big Support noted. Option TC 6 leisure centre, swimming pool, cinema and skating.

Preferred Preferred There are too many offices empty, plus more are being built. Employment space Comment noted. Option EMP 2 should be used now, not in the future.

However, The Employment Land Review Study commissioned in 2005 concluded a requirement for more modern floorspace over the life of the Core Strategy. Floorsace which must accommodate the needs of exiting , expanding and new businesses coming into the Borough

258 Preferred Preferred Would support a creative/cultural arts quarter. This should be located somewhere The creation of a creative is located Option EMP 3 along the seafront. towards the seafront, detailed in the draft site allocations document ‘Unlocking Development Potential’ Reference UDP7.

Preferred Preferred B&B's should not be protected as these are too common. Would support the Representation noted, however, officers Option EMP 4 upgrading of existing accommodation to match changing consumer demands, as we do not concur with the view that B & Bs should be looking to go up-market all the time. are considered “too common”. Conversely, such accommodation provides for a proportion of the tourism sector in Worthing. A range of accommodation is a key component to delivering a sustainable tourism/visitor offer.

Preferred Preferred We need to improve the appearance of the town centre, and identify sites for existing Support noted. Option R 1 retailers who need larger floor areas.

Preferred Preferred Greater flexibility should be provided in areas of district centres which are found to Support noted. Option R 2 be in poor health. Failing areas should be redeveloped. The safeguarding of, and encouragement to adapt these centres to provide a shopping and community destination outside the town centre is therefore supported.

The appearance of less healthy neighbourhood and local centres should be improved through landscaping.

Preferred Preferred Development which would affect the character of an historic area or building should Comments noted Option ENV 1 only be allowed if it complies with high quality design standards.

259 Preferred Preferred The strategic gaps should be retained, and no urban land uses should be allowed to Comments noted. Option ENV 2 take place within them.

PPS7 requires local planning authorities to rigorously consider the justification for retaining existing local landscape designations as part of reviewing their development plans. Paragraph 24 states that carefully drafted criteria - based policies in LDD’s, utilising tools such as landscape character assessment, should provide sufficient protection without the need for rigid local designations that may unduly restrict acceptable sustainable development.

Preferred Preferred New development should be built to higher sustainability standards. The re-use and Comment noted Option ENV 4 recycle of construction materials from demolition on-site during construction should be encouraged.

Preferred Preferred Does not agree with preferred parking option, though no details are provided. No comment required Option TP 1

Preferred Preferred Supportive of the submission of travel plans with new commercial development. No change of policy needed Option TP 2

Preferred Preferred Would support the re-use of buildings including conversion of dwellings. Support noted. Option H 4

Preferred Preferred We should identify those facilities which offer opportunities for improved leisure and The representation is supportive of Option COM 1 recreation provision. Policy COM1, and the support is duly welcomed. No change.

260 Preferred Preferred Supportive of a policy framework which would resist the loss of community facilities. The support is duly welcomed Option COM 3

Preferred Preferred Supportive of an infrastructure contribution to address crime and anti-social The representation is supportive of the Option COM 5 behaviour where development is located in areas specifically identified as being at a principle of Policy COM5, and the high risk of such incidents. Also supportive of contribution towards health and social support is duly welcomed. care.

Preferred Preferred Supportive of working with partners in order to identify sites for new educational Support noted. Option ED 1 facilities.

Representor : 411 Miss Angela Rawkins (Resident)

ID / Type Heading Response / Representation Officer's Recommendation Preferred Preferred Thinking of good neighbourhood centres, am grateful for the report's assurance that Support noted. Option R 2 shops in local parades will be protected.

Preferred Preferred I should not want any further development 'out of centre' if the downs were further Representation noted and the impact of Option R 3 encroached on. the development on the South Downs is a consideration to be taken into account at the detailed planning application stage.

261 Preferred Preferred I should not want strategic gaps mentioned in the report to be encroached on, and Comments noted. South Downs / NP Option ENV 2 do feel much concerned about our Downland also (and about present National Park are covered within national planning status arguments). guidance.

PPS7 requires local planning authorities to rigorously consider the justification for retaining existing local landscape designations as part of reviewing their development plans. Paragraph 24 states that carefully drafted criteria - based policies in LDD’s, utilising tools such as landscape character assessment, should provide sufficient protection without the need for rigid local designations that may unduly restrict acceptable sustainable development.

A landscape character assessment is being carried out on the Strategic Gaps to assess their existing function and future roles within the context of the Borough. The Core Strategy approach will be modified once the outcome of the assessment has been analysed.

262 Section Housing I think my main priority where urban planning is concerned would be affordable Support and comments noted. Provision housing, especially for first time buyers. The average property rise (e.g. from £106,075 to £183,663) of 73% increase in 6 years is, though to my advantage in one sense, extremely worrying, and very sad to me.

How in particular young family life can be nurtured and sustained is surely of great concern, and of course good housing, even if of a very modest kind, and with opportunity for that, is basic to this.

I can see some advantage for some people and even for the community in general when the Tories under Thatcher sold off allocated houses but if the stock of available council houses then became inadequate (through non-replacement, no alternatives - was that so in Worthing?) that would be detrimental to a growing town.

I think re-lets are needed, and if Titnore proposals go ahead will hope no more land encroachment will become necessary. Whether within the present town boundaries there is good possibility for further housing association growth (not only for the elderly) - perhaps on a 'small version of Rowntrees' basis? Could large businesses be encouraged (to combine?) to form one/several with their own employees primarily in mind? I think the NHS does this a little already, near Worthing Hospital - maybe if there's a large enough hospital left to us - this could be extended as properties become available.

263 Preferred Preferred I'm sure that its wise to encourage brown site development where possible and safe Comments noted. Option H 3 to do so, but realise this isn't always sufficient.

Representor : 470 Teresa Arrowsmith

ID / Type Heading Response / Representation Officer's Recommendation Section Transport The reduction in parking and reliance on public transport/park and ride schemes is of The need to reduce car usage is a a concern to me as most people do prefer to park in town and these alternatives Government requirement set out in need to be attractive i.e. affordable otherwise people might travel to Planning Policy Guidance 13 - Brighton/Chichester etc. Transport

Brighton and Chichester are guided by the same requirements as Worthing to reduce car usage and encourage greater use of public transport.

Chapter 8 Providing for The replacement of the Aquarena with a 25m pool is inadequate - the town needs to the Community maintain a larger swimming facility (at least 33m pool or even better an Olympic size pool)

Representor : 120

264 Mr Chris Cousins (West Sussex County Council)

ID / Type Heading Response / Representation Officer's Recommendation Chapter 1 Introduction Coastal: Neither text nor policy refers to conserving or enhancing the biodiversity or The portrait of the Borough reflects the landscape quality and character of the coast and beaches as natural assets. The main issues and characteristics coastline and beach is a natural asset not mentioned in Environmental identified in the Scoping Report. It is Characteristics Page 7. Yet highlighted as a main issue on Page 10. P27 identifies essential that the Core Strategy is a both the coast and the seafront as the primary reason for visiting the town. It is also streamlined document which reflects part of the open space unique to Worthing’s location and natural features (PPG17). the specific spatial issues facing Worthing. It should not simply repeat National Guidance on the protection of AONBs or coastlines.

Core Strategy should promote the importance of the coast and its beaches as natural assets. Policy should refer to the need to protect and, where possible, enhance the Coast. (Landscape).

South Downs AONB Neither text nor policy refers to the need to protect and, where possible, enhance the South Downs AONB or its setting.

Core Strategy and policy should refer to the need to protect and, where possible, enhance the South Downs AONB and its setting. (Landscape).

Chapter 6 Regeneration Page 24-30:Options TC1-TC9: Core Strategy preferred options TC1 to TC9 offer a It is considered that preferred range of supporting measures that are consistent with the West Sussex County approaches outlined by policy TC1 – Council Economic Strategy (WSECC). TC9 provide a diverse framework in which regeneration objectives can be attained.

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However, the preferred options are, to some extent, underdeveloped in relation to It is noted that the Business the specific objectives contained in the WSCCES. In particular the regeneration Improvement Areas require additional approach envisaged by the Worthing Core Strategy is one which has little in the way detail to reflect their overall economic of a clear idea of how to diversify the local economy. In some respects the strategy objectives and contribution to seems to encourage further significant development in sectors where lower-added regeneration. value employment predominates, for example, in retail and tourism. While the identification of BIA is important there is no explicit goal in relation to these. There perhaps needs to be a clearer statement of what the potential goals of developing BIA might be and in particular how this proposal links to the Worthing Evolution Masterplan.

Section Economy The approach to economic development is somewhat narrow in the sense that it There is no indication in the Core chooses to concentrate on Worthing’s historical sector strengths. This does mean strategy that it is intended to that plans for diversification may be limited. Further, while the retention of major sites concentrate on Worthing's historical for B1, B2 and B8 uses is consistent with the WSCCES, there is little to indicate how sector strengths. The intention is to pay Worthing Borough intends to apply this policy in practice and what it needs to do to recognition to the economic strengths encourage both high value-added and diverse activity and it is not clear whether of the town and recognise that a such an approach would require a more stringent policy regime in relation to the balanced approach is required to potential loss of employment space less than 300 sq. m. There is a wider need to sustain this sector. strengthen the linkage between the goals of the preferred options and specific site level proposals contained within the earlier Unlocking Development Potential document.

The Core Strategy is advocating a flexible approach to stimulating the local economy.

The sites in the Unlocking Development Potential document provide for mixed use development opportunities with the objective of attracting new and diverse investment into the town.

266 Preferred Preferred Options EMP1–EMP4: Specific economic development preferred options include the Support noted. Option EMP 1 importance of retaining major existing employment sites for B use. This, coupled with a commitment to a specified minimum capacity for employment land use is clearly consistent with the WSCCES objectives in relation to providing locations and opportunities or excellence.

A more flexible approach to the loss of minor employment sites is also likely to allow A clear statement of how the pressure a consistent approach to achieving Worthing’s overall Spatial Vision within a for any change in employment land use framework which works to complement the WSCCES. A clearer statement of how designation will be managed is to be the pressure for any change in land use designation will be managed would set out in more appropriate detailed strengthen this approach. guidance – Sustainable Economy SPD

Section Provision of The approach to economic development is somewhat narrow in the sense that it There is no indication in Policy EMP 2 Employment chooses to concentrate on Worthing’s historical sector strengths. This does mean that it is intended to concentrate on Sites that plans for diversification may be limited. Further, while the retention of major sites Worthing's historical sector strengths. for B1, B2 and B8 uses is consistent with the WSCCES, there is little to indicate how The policy is merely advocating a Worthing Borough intends to apply this policy in practice and what it needs to do to minimum employment floorspace of encourage both high value-added and diverse activity and it is not clear whether 50,000 square metres. There is no text such an approach would require a more stringent policy regime in relation to the to infer that diversification would be potential loss of employment space less than 300 sq. m. There is a wider need to limited strengthen the linkage between the goals of the preferred options and specific site level proposals contained within the earlier Unlocking Development Potential document.

The Core Strategy does advocate flexibility when assessing some loss of employment use.

Preferred Preferred There is also a clear commitment to support the creative economy through Support is noted Option EMP 3 establishment of a creative quarter.

267 Preferred Preferred The Core Strategy also seeks to defend the tourism sector within the Borough quite Observations noted. The current Option EMP 4 rigorously. Protection and improvement of existing stock of visitor accommodation climate n Worthing is such that the and the introduction of a criteria based policy to the loss of visitor accommodation to visitor economy is heavily focused consider alternative leisure or visitor uses. It is important to note that although this towards visitor accommodation, without may not appear to be consistent with the WSCCES objective of fostering the the diversity of complementary uses to development of higher value-added economic activities, it may act as foundation for sustain the “offer”. The preferred the development of these activities in other sectors, for example in the creative approach seeks to redress the industries. imbalance to a level which is stainable.

Section Expanding the Option R1-R3: Worthing’s Core Strategy approach to the flexibility in support for Observations noted. Primary district and neighbourhood retail centres and the restriction of out of centre retail Shopping Area growth is broadly consistent with the WSCCES’s objectives for the regeneration of the Coastal West Sussex economy.

However, a cornerstone of the preferred options for retail within the Borough The expansion of the Primary Shopping involves an expansion of primary shopping area in Worthing town centre. This may Area does not preclude mixed use possibly involve the prioritisation of A1 use over redevelopment for B1 use. It may be development incorporating retail at the case that this preferred option will restrict opportunities to meet the diversification groundfloor with B1 uses above for and high added-value, higher skill objectives of the WSCCES. The potential example. The Expansion of the Primary transport implications of an expansion of the primary retail centre are also not Area has been justified by the explored in detail. conclusion of the DTZ Retail Capacity Study and the requirement placed on LPAs through PPS6 under para. 2.3 bullet point 1 " .. local planning authorities should actively plan for growth and manage change in town centres over the period of their development plan documents by:

268 o selecting appropriate existing centres to accommodate the identified need for growth by:

- making better use of existing land and buildings, including where appropriate redevelopment;

- where necessary, extending the centre.

The transport issues related to retail and wider development focus toward the town centre have been covered Sustainable Development preferred policies TP1 -TP4 and Regeneration preferred policy TC9.

Chapter 7 Sustainable Countryside: Development Policy required that refers to the need to protect and, where possible, enhance the countryside. (Landscape).

269 Section Strategic Gaps ENV2: Strategic Gaps: Pleased to see policy for supporting principle of Strategic Comments noted. Gaps. PPS7 identifies the need for local landscape designations to be based on criteria based policies in LDDs utilising tools such as landscape character assessment. They should ensure that such designations are based on a formal and robust assessment of the qualities of the landscape concerned. To this end I am pleased to note Worthing Borough are commissioning a landscape study on the Western and Eastern Gaps, based on landscape character and visual sensitivity. However, visual and landscape sensitivity also extends to areas of countryside outside the built development limits, the settlement edge and the coast. In order to comprehensively inform decisions on spatial strategy and any sequential test on sensitive locations, study should be extended to these additional areas.

If WBC feel its appropriate to allow certain kinds of development within strategic A landscape character assessment is gaps it should ensure that opportunities are taken to enhance the natural being carried out on the Strategic Gaps environment as per PPS1 & 9: to assess their existing function and future role within the context of the Borough. The Core Strategy approach will be modified once the outcome of the assessment has been analysed.

Section Climate Option ENV3: Climate Change: The effects of climate change can be mitigated Comments noted. Change through appropriate plantings and provision for wildlife. With climate change the natural environment needs to flex and move, shifting from areas becoming It is accepted that the mitigation unsuitable to new more suitable areas. Urban areas have a significant role to play in measures outlined in this ensuring that wildlife can move through the built landscape and exist within it. Should representation with respect to planting ensure robust landscaping proposals contain a strong element for wildlife, e.g. use of and provision for wildlife are important. native species and other provision for wildlife. The detailed application of such measures are not considered to fall within the remit of the broader spatial Core Strategy but rather more detailed guidance received form statutory consultee (such as the County Council) through the planning application process.

270 Section Sustainable Options ENV1-ENV4: The Core Strategy and preferred options exhibit a good Comments have been noted Development understanding of how policy for sustainable development relates to economic development objectives. A positive approach to built environment enhancement including the promotion of excellence in design is a necessary precursor to the creation of a location which affords both quality jobs and economic opportunities. The Core Strategy takes a balanced approach to new development with key energy and resource use specifications.

Preferred Preferred ENV4: Sustainable Development: The text states that there are 11 locally important Comment noted Option ENV 4 sites (para 1.18, page 7). These sites are of county importance and are designated ‘Sites of Nature Conservation Importance”. SSSIs should be considered sacrosanct. These comments relate to the CS's Ancient woodlands and SNCIs should only ever be developed as a last resort and as introductory text and not Policy ENV 4. a matter of absolute necessity as set out in Structure Plan Policy ERA2: Nature However the 11 locally important sites conservation. With reference to Sites of Nature Conservation Importance the policy mentioned are given protection and explanation states: “Wherever possible, new development should enhance the enhancement status via existing biodiversity of the site and of the surrounding area by creating new habitats or national planning guidance. improving existing ones. In certain circumstances, a new resource should be provided which is of at least equivalent value, where possible, to a site or feature which is lost as a result of development. This could include the creation of a new habitat on the site or elsewhere if this is more appropriate. However, in general, the loss of habitats should be resisted.” See PPS1 and 9.

Preferred Preferred ENV4: Sustainable Development: The text states that there are 11 locally important Comment noted Option ENV 4 sites (para 1.18, page 7). These sites are of county importance and are designated ‘Sites of Nature Conservation Importance” SSSIs should be considered sacrosanct

271 These comments relate to the CS's introductory text and not Policy ENV 4. However the 11 locally important sites mentioned are given protection and enhancement status via existing national planning guidance.

Section Transport TP1-TP5: The Core Strategy is clear about the need for infrastructure improvements Comments noted for sustainable transport solutions. There are a number of specific preferred options which offer both support for transport infrastructure improvement and the encouragement of more sustainable modes of transport. The promotion of Green Travel Plans (such as car sharing schemes) and the exploration of the potential for a Park and Ride scheme would support moves towards better and more sustainable transport and communications. The Core Strategy also seeks to promote the development of traffic demand management measures to reduce the problem of through traffic routes within Worthing town centre; however the preferred options envisage this to be reliant on developer contributions. With the clear intention to develop an expanded primary retail centre there is a challenge in meeting the conflicting needs of both expanded access to the retail centre and traffic demand management measures.

Preferred Preferred Option TP1: Parking: Provision should be made for the short term as the option is Policy TP1 does advocate a balance Option TP 1 very long term. More detail is needed regarding Local Authority Parking Enforcement between short and long term parking. (LAPE). Details of LAPE will be considered and if appropriate will be given appropriate reference in the emerging Core Strategy.

272 Preferred Preferred Sustainable Transport: None of the preferred options are likely to result in The Core Strategy cannot advocate Option TP 2 improvements to public transport services and infrastructure. Suggest that this could service improvements for public be added to TP2 which could read: transport as this is beyond the responsibility of WBC. TP 2 could advocate developer contributions funding some public transport infrastructure but this would need to be done in partnership with the County Council, and local bus operators which is more appropriately addressed through the Quality Bus Partnership.

"Preferred Option TP 2: Sustainable Travel The issues with regards to encouraging Green Travel plans, car sharing schemes and car clubs will be considered.

Use developer contributions from new developments to fund infrastructure improvements such as safe and well-designed cycle routes, infrastructure and service improvements for public transport, which will both alleviate the effects of any extra traffic generation produced and also provide greater modal choice.

Use major new commercial and residential development to encourage the setting up of Green Travel Plans, car sharing schemes and car clubs in order to increase car occupancy, hence reducing the number of cars on the town’s roads and alleviating the pressure on both on and off street car parking areas."

Section Traffic The preferred option requires substantial modelling and assessment work before it Transport modelling is currently being Management can be implemented. This will take place once the model is developed, but it would undertaken to help inform new be prudent to put forward an alternative at this stage in case this is not workable. infrastructure requirements. No diversionary route has been formulated in the Core Strategy so an alternative is not required.

273

TP 3 is still applicable in its original format

Section Park and Ride The preferred option requires substantial modelling and assessment work before it TP 4 does not contain any reference to can be implemented. This will take place once the model is developed, but it would a Park and Ride location. If a suitable be prudent to put forward an alternative at this stage in case this is not workable. site is found there will inevitably be further consultation and environmental impact assessments, as well as transport assessments and modelling

Park and Ride: WSCC has undertaken previous work to identify a viable park and Any Park and Ride facility must comply ride site without success. with the criteria set out in TP 4 before implementation to ensure its' validity and efficiency.

WBC acknowledge that they will have little control over the Town Centre parking No change in TP 4 required. arrangements in the short term, which may make it difficult to implement a competitive park and ride operation in the short to medium term. An alternative to this option should be provided in case a site cannot be identified.

Park and ride infrastructure should not impact on areas of known wildlife value. In accordance with PPS9 and 1 provision should be made to incorporate features that will enhance the local natural environment

274 Section East Worthing East Worthing Access Road: At the issues and options stage, WBC acknowledged Collaboration work is ongoing between Access Road that the East EWAR cannot be built without assistance from others (Highways WBC and Adur. Alternatives to the Agency, Adur DC). Collaborative working is required between WBC and Adur DC to original EWAR route have been help resolve this issue. It may be necessary to provide an alternative in case EWAR considered in a consultant’s report and cannot be delivered. additional work is still required. To inform the core strategy approach.

Preferred Preferred The Core Strategy seeks to support further consideration of the East Worthing The comments are noted, however it is Option TP 5 Access Road (EWAR). There is an acknowledgement that the potential benefits of not possible at this stage to say how the EWAR cannot be assessed in isolation to other transport improvements. EWAR can specifically contribute to the However the case for how the EWAR may contribute to the strategic development of strategic development of transport transport infrastructure for Worthing specifically is actually not addressed in any infrastructure in Worthing. There is as detail. There needs to be a clearer demonstration of why the EWAR should be yet, no defined route for EWAR and considered in this way given the major revision that will be necessary to the original there is bound to be impacts upon construction plans and the continuing significant barriers to the delivery of the Adur's transport network if the road is project. built.

It is however accepted that additional work on the potential of EWAR needs to be carried out to explore the strategic value such a road might have for both districts.

Section Housing H1-H7: The preferred options for housing provision present no significant challenges Support noted Provision to the objectives of the WSCCES. Indeed, there is a well developed plan to utilise brownfield sites to meet provision needs

275 Preferred Preferred It is not clear how a minimum threshold (35 dwellings per hectare) can be averaged The comments are noted and this Option H 2 across the Borough The minimum threshold should always apply unless there are policy approach will need to be exceptional circumstances. The clause "averaged across the Borough" should be reviewed in the light of PPS3, with the deleted. minimum target of 30 dph.

The minimum of 35 dwellings per hectare is supported. However, the phrase "significantly higher than 40 dwellings per hectare" in the second bullet point of Preferred Option H2 is insufficiently precise, and consideration should be given to seeking a range of higher densities in more sustainable locations, rather than setting a minimum target of 40 dwellings per hectare.

Section Affordable The approach of seeking Affordable Housing on a tapered site size threshold is fully An assessment of the impact of a range Housing supported. With respect to the thresholds: of affordable housing thresholds and percentages on the viability of development is underway and will inform the appropriate level of affordable housing to be sought. The second threshold range of "11 to 14 dwellings net" should not go on to say "or more".

The minimum size of the taper could go down to single dwellings, to stop developers purchasing or bringing forward small sites and/or a low density in an attempt to avoid Affordable Housing.

The requirement of commuted sums for sites of 11 to 14 dwellings net is not in keeping with the governments' Communities agenda, and Affordable Housing should be required instead, with commuted sums for any fraction of a dwelling.

276 Paragraphs 8.26 to 8.28 of the Consultation Document discuss the findings of the Adams Integra study of the financial viability impacts of affordable housing policy options in West Sussex, and argue that a target of 40% affordable housing would be viable in some wards in Worthing. In addition, the Monitoring and Implementation targets for Policies TC5 and H6 refer to 40% targets for sites of 50 or more dwellings.

The draft South East Plan refers to a regional average of 35%. Specifically, Section E2 (South Coast sub region), Policy SCT8 introduces the overriding principle of achieving the maximum affordable housing that any developments can viably support.

The text of Policy H6 allows for the possibility of accepting lower percentages of affordable housing in order to ensure viability. Therefore, the key point is to pitch the requirements for different size sites for the whole Borough at a level which will allow for the variations in viability indicated by the Adams Integra study.

The Policy text could be amended as follows:

· on all sites of 1 to 10 dwellings net, 10% affordable housing will be required via a commuted sum

· on all sites of 11 to 14 dwellings net, 20% affordable housing will be required

277 · on sites of 15 - 14?dwellings net , or 0.5 ha or more in size, at least 30% affordable housing will be required, with the precise level to be determines by taking into account the size and viability of a development

* on sites of 50 or more dwellings, 40% affordable housing will be required.

Commuted sums will be required in place of any fractional dwellings.

Section Community Community Infrastructure options largely involve the goal of retention and possible The representation supports the Infrastructure enhancement of indoor sports facilities and open recreation space. An overall positive policy approach to community resistance to the loss of community facilities and a commitment to the need for infrastructure covered within the development plans and designs to consider issues of crime and community safety chapter. The support is duly welcomed. offer a positive supporting contribution to the objective of providing an excellent No change. location in which to live and do business.

278 Preferred Preferred Open Recreation Space: Pleased to see a policy included for preservation of Open Representation supportive of the Option COM 2 spaces. However, PPG17 also refers to planning for new open space and local principle of preserving open space, authorities should seek opportunities to improve local open space network to create though outlines that greater emphasis public open space from vacant land and to incorporate open space within new should be placed upon the strong development. With particular relevance to Worthing, it refers to the countryside recreational links between Worthing around towns providing valuable resource for the provision of sport and recreation and the South Downs AONB. It is noted particularly in the absence of land in urban areas to meet provision. In view of the that reference should be made to the close relationship to the South Downs AONB with strong recreational links, this recreational role of the South Downs. policy does not go far enough for provision in Worthing. Much is made of linking the The representation wishes the policy to urban space to the coast but no reference is made to improving linkages to the place a greater emphasis upon Downs. Policy should refer to the promotion of greater public access by providing improving linkages to the Downs, and new bridleways, footpaths and cycle ways into the surrounding countryside, from the while the policy does look to enhance urban areas and the coast. existing green corridors, it may be appropriate to introduce additional text discussing improved access to open recreation space. In addition, Policy TR2 covers issues of sustainable travel and improvements to the cycle network. The need for new development to incorporate open space is covered under Policy COM5.

279 PPS7 Para 26 Local Planning Authorities should ensure that planning policies in LDD’S address the particular land use issues and opportunities to be found in the countryside around all urban areas …….recognising its importance to those who live or work there and also in providing the nearest and most accessible countryside to urban residents. This should include improvement of public access

Section Healthcare The healthcare proposals have little direct linkage to the objectives of WSCCES. The Preferred Core Strategy has However, public health issues are particularly relevant in strategies and policies highlighted a specific approach which designed to limit and reduce the effects of worklessness, deprivation and social allows for a framework in which exclusion. Public health strategy needs to be consistent with the goal of equipping relevant health providers could bring individuals with capacity to develop better skills and sustain higher added-value forward improvements. The Borough economic activities. It would be useful from the point of view of the objectives of the Council itself has a supporting and WSCCES to have a clearer idea of what Worthing Borough proposes to do to enabling role but as a local planning encourage public health improvements more explicitly. authority cannot bring about health improvements.

Section Education and The objective of better skills is one which is emphasised as a key objective of the Observations noted, it is accepted that Skills WSCCES. Within the Worthing Core Strategy, there is consideration of how to further work may be requires to address needs for accommodation and further education provision. There is also understand skills and employment within the preferred options a commitment to seek developer contribution in areas of linkages. where strain may be put on existing educational provision.

However, there is no detailed consideration of what the Borough needs in relation to the skills required to deliver the Spatial Vision. In particular the linkage between the education and skills preferred options and the diversification of the economy to higher value added activity appears relatively underdeveloped. While rationalisation is hinted at, there is no real demonstration of what this may achieve.

280 Appendix Appendix 1 Sustainable Development: No reference to PPS7 in Appendix 1: National Planning Reference to PPS7 can be added. Monitoring and Policies Page 13. No corresponding countryside, landscape character, coastal (as Implementation opposed to seafront), AONB or Recreational policies.

Appendix Appendix 2 There is a strong possibility that the Table includes a significant element of double Further analysis of the housing land Housing Land counting in the assumptions about the amount of housing to be delivered on supply will be undertaken to ensure that Supply previously developed land. In addition, the amount of land proposed for development there is no double counting and that the in the Preferred Options Draft Document appears to be excessive when compared proposed phasing of development is with the housing requirements set out in this section. Further technical advice on realistic. these points will be provided in due course.

Representor : 472 Mrs R A Prentice

ID / Type Heading Response / Representation Officer's Recommendation Section Economy Looking over the outline I am very concerned with the very low profile given to A key principle of a sustainable town is creation of jobs for Worthing residents in the LDF. Economic Development has to be best reflected by the Corporate Plan key to the prosperity of the Borough because it impacts on so many factors being vision: addressed in the plan.

281 For example, pollution from cars of people driving to other towns for work, would be For Worthing to be a thriving Borough lowered if work was created locally. Congestion on major roads, like the A27 and in which to live, work and invest. A24 would also be minimised if people could work locally rather than needing to commute to Horsham, Arun and beyond.

Retail expenditure would be increased in Worthing if people earning money were The Core Strategy is considered to based locally. If residents of Worthing work in towns, their lunchtime expenditure, provide for the correct framework for their after work shopping/drinks/meals are more likely to take place where they work. both employment and housing If jobs are not created logically, neither does wealth generation occur locally. provision..

There are a worrying number of existing local employers, downsizing their The profile of economic development is operations and outsourcing the jobs. The jobs at Inland revenue, Norwich Union, considered to have a clear focus in the Eurotherm, Lloyds TSB registrars need to be replaced with equivalently skilled jobs. Core Strategy. This is reflected in If Worthing Hospital closes, this will cause another significant employer loss. The policies EMP1- EMP4 and also the Council needs to address this situation. town centre and seafront regeneration.

Professionally trained people are unlikely to welcome retail jobs, so they will feel the As a spatial planning document the need to look in other towns to satisfy their career requirements. Unless new Core Strategy policies are considered employers of equivalent quality and skills are attracted to Worthing, a Brain Drain will to provide sufficient flexibility to respond occur amongst the working population i.e. those people age below 60, with young to the changing requirements of major families who would naturally want to use the facilitates like the leisure centre, the employers within the Borough, while at swimming pool etc, which are to be developed. the same time providing for new inward investment, with the allocation of strategic development sites and Business

282 Wealth generation needs to be created in Worthing in a sustainable way. The Improvement Areas. retirees who came to Worthing may be very wealthy and able, initially to spend a lot in retail and leisure pursuits in the town. However, in the medium term they then cause a major dependency on caring services.

We have young children who will need to have jobs in the future. At the present time, Reference to retailing and job creation we cannot see the prospect of jobs for them in Worthing. must be seen within the context of town centre regeneration. Vibrant and healthy town centres attract employers and their employees to the area.

Please have economic development at the forefront of the development plan. Allocating new industrial areas alone is insufficient to attract employers. There are too many buildings already vacant in the town from the employers downsizing/outsourcing as noted above.

Representor : 236 Mr Steven Beard (Servite Houses)

ID / Type Heading Response / Representation Officer's Recommendation

283 Section Housing Providing for the Community This level of detail may not be Provision appropriate for a Core Strategy, particularly as requirements and needs may change. The approach in the Core Strategy is to ensure that densities are maximised and new development addresses the housing needs of the wider community.

8.9 Density policies could consider indicative habitable room density ranges/standards as a complement to indicative unit density ranges/standards.

8.18 Noted that there is an acute need for 1 & 2 bed dwellings. However, within the context of the LDF, consideration needs to be given to the long term sustainability of affordable housing development. 1 & 2 dwellings meet an entry level need for affordable housing- however that in itself will create a future need for larger dwellings as households grow. In other words, there is an on-going need for larger affordable dwellings, albeit possibly at a lesser rate of development than smaller dwellings.

Preferred Preferred Preferred Option H6: Affordable Housing This could be dealt with in SPD, Option H 6 detailing the mechanisms for the delivery of affordable homes.

As with 8.9, consideration could given to % of habitable rooms or even % of developable land. This provide far more flexibility for the local authority to achieve what it needs on a site by site basis over the term of LDF, otherwise developers will push for smaller affordable housing units.

284 Preferred Preferred Preferred Options COM5, HP2, ED2 The representation observes that any Option COM 5 contribution sought will need to be specifically generated by the site in question. The observation is duly noted, and it is recommended that the Preferred Option text be re-worded in order to remain in keeping with the guidance outlined in Circular 05/05. The representation also notes that it may be appropriate to consider applying greater flexibility to developer contributions on affordable housing sites.

285 Any contributions via the above must be justified by need specifically generated by the site in question, not seen as a ‘slush fund’. Consideration could also be given to any additional contributions being provided by local authority or exempted on affordable housing sites.

Representor : 94 Ms Amanda Green (Amicus Horizon Housing Group)

ID / Type Heading Response / Representation Officer's Recommendation Preferred Preferred Page 46 should we and developers be looking to provide a % of housing to lifetime This comment should be assessed in Option ENV 4 homes standards, we try to do a 100% lifetime homes on all land led developments. the Housing section in Providing for the Community

Preferred Preferred General: SPD on infrastructure contributions, Option H 6 including affordable housing is being prepared and will ensure a strategic view of contributions.

286 Contributions to education, health , highways etc -whilst it is accepted there needs to Whilst the Core Strategy can refer to be some input of finance into these where large developments will have an impact the Empty Homes Strategy, it is the on such services such contributions can be inhibitive to affordable housing. Empty Homes Strategy which is the Affordable housing is already subsidised and by paying contributions RSLs end up in correct location for the detailed actions effect giving funds from one govt dept to another. There needs to be joined up being undertaken to bring empty thinking around these issues so any contribution is limited and would not make the properties back into use. affordable housing unviable.

There is little in the strategy about bringing back to use empty homes and a need to ensure private landlords/owners do not leave property empty for any length of time and what can be done with such properties etc to help the housing shortfall.

Preferred Preferred Page 62 all new developments whether private or affordable should aim for secure Preferred Option COM4 requires all Option COM 4 by design if they want to improve security and safety. new development to take account of the need to reduce opportunities for crime and promote safe and secure living environments. At the Issues and Option stage, the requirement for all new development to comply with Secure by Design Guidance was widely supported, and will be a key consideration under Policy COM4.

287 Preferred Preferred Page 63 community facilities /provision of play areas and open spaces - these need The recently undertaken PPG17 study Option COM 5 to be considered very carefully as whilst provision must be made it must be the right has reviewed the current provision of provision, too many such areas are provided at a high cost and high maintenance open recreation space typologies within cost but end up not being used or being vandalised, a lot of consultation is needed. the Borough, considering levels of usage and identifying demand for specific typologies is greatest, The study also investigates quality of outdoor space, and outlines sites where issues of quality exist. The study will enable the Council to carefully consider outdoor recreation need in order to target those locations within the Borough where demand is greatest, or where the need to address quality issues is most pressing.

Representor : 474 Victoria Barlow

ID / Type Heading Response / Representation Officer's Recommendation Preferred Preferred More recreational and play areas across the town. Option COM 2

We live in Worthing and enjoy having fun here. we think it is good to have lots of play areas so we do not get bored.

Representor : 475 288 Catherine Barlow

ID / Type Heading Response / Representation Officer's Recommendation Preferred Preferred More recreational and play areas across the town. Option COM 2

We live in Worthing and enjoy having fun here. we think it is good to have lots of play areas so we do not get bored.

289

Appendix 2.9 - Results of Sustainability Appraisal

Representor : 374 Mr John Coote (Sustrans)

ID / Type Heading Summary of Response Officer's Recommendation Document Core Strategy and The Sustainability Appraisal does not identify the causes of climate change The SA is a tool used to help inform Unlocking Development as the single most important issue of sustainability. It fails to recognise that decisions for the spatial proposals. Potential Sustainability climate change is a threat not just to environmental security, but long-term The SA must look in balance at Appraisal economic sustainability as well. environmental, social and economic objectives and the conflicts which may arise between them. A sustainable economy is a key component of the regeneration objectives outlined in the draft Core Strategy within the Borough. Environmental sustainability cannot be considered in isolation, and the requirement to accommodate future development need must be considered with balanced consideration.

290 1. The Sustainability Appraisal as it stands is unable to conclude what the Recognition to climate change, its overall effect will be of the plans and policies in the LDDs on carbon dioxide impact and measures to reduce emissions. development impact are to be addressed in Core Strategy policies and additional LDDs.

2. The Sustainability Appraisal as it stands does nothing to resolve It is important that sustainability is arguments about which plans and policies are and are not sustainable. addressed both in the policies as well as in the SA. The definition of sustainability is one which has been globally accepted. New research like the Stern-report was recognised and mentioned in the consultation Planning Policy Statement (PPS) Planning and Climate Change, a supplement to PPS1, published in December 2006. There are also various other Government Policy guidance documents dealing with climate change. The commitment to produce a PPS on Climate Change was made clear in both the Government’s Climate Change Programme and Energy Review. The draft PPS sets out how spatial planning should contribute to reducing emissions and stabilising climate change (mitigation) and take into account the unavoidable consequences (adaptation).

291 3. The Sustainability Appraisal perpetuates the trade-off of economic and It is the Government’s intention to environmental objectives and thus compromises long-term environmental and move towards a common economic security. methodology for regions in monitoring and reporting on the expected carbon impacts of regional spatial strategies (RSS) as soon as possible. A methodology and robust data will need to be developed. Practice Guidance is currently being developed. This will then need to be done for the local level. These will be included in LDF monitoring documents.

PPS1 requires Local Planning Authorities (LPAs) to ensure that development plans contribute to global sustainability by addressing the causes and potential impacts of climate change. It is recognised that we need to review our draft policies as a result of the publication of PPS1 supplement Planning and Climate Change. Please see the recommendations to our Core Strategy policies for details.

292 Currently there is no need to adapt the Sustainability Appraisal as the indicators included are considered appropriate.

Representor : 26 Mrs Margaret Pratt (Highways Agency)

ID / Type Heading Summary of Response Officer's Recommendation

293 Document Core Strategy and The sustainability framework (chapter Unlocking Development 7) of the SA identifies Objective 5 to Potential Sustainability reduce car journeys and promote Appraisal sustainable transport. There are 4 indicators with this objective to monitor this objective which we consider to be sufficient. The 4 indicators are: 1. Number of days per year when air pollution is moderate or worse. 2. Annual average nitrogen dioxide concentration. 3. Growth in volume of traffic.4. Percentage in modal split of people aged 16-74 re travel to work.

In addition the West Sussex Transport Plan 2006-2016 has had its own Sustainability Appraisal. Trunk roads are included in that.

294 Document Core Strategy and The aim of the LDF is to develop Unlocking Development policies which are sustainable and Potential Sustainability with regards to new development and Appraisal transport the focus is on reducing car use. Worthing has to work with a minimum target for housing development set by SEERA the regional government. The Core Strategy proposes a number of regeneration areas and policies all within the existing urban area and on the seafront to provide the required housing. These regeneration areas and policies give the best opportunities to reduce car journeys and use of public transport and other sustainable modes of transport (walking, cycling) and therefore minimising environmental impact.

The West Sussex Transport Plan 2006-2016 gives information about air quality on trunk roads. There are two areas on the A27 which have had a detailed assessment and no AQMS had to be installed to date. Part of the traffic on the A27 is through traffic and can not be apportioned to Worthing.

295 At this stage it is not known what the impact of new developments on car use is going to be and how public transport and other modes of transport (walking, cycling) encouraged by the Core Strategy are going to affect air quality in detail. As mentioned in response to your objection ID 183, the Council is also preparing a Sustainability Appraisal which identifies Objective 5 to reduce car journeys and promote sustainable transport. There are 4 indicators with this objective to monitor this objective which we consider to be sufficient. The 4 indicators are: 1. Number of days per year when air pollution is moderate or worse. 2. Annual average nitrogen dioxide concentration. 3. Growth in volume of traffic.4. Percentage in modal split of people aged 16-74 re travel to work.

Representor : 265 Mr G L Boots (Worthing Astrological Society)

ID / Type Heading Summary of Response Officer's Recommendation Document Core Strategy and The addition of 'light' to preferred Unlocking Development option ENV1 would not affect the Potential Sustainability (score of) Sustainability Appraisal as Appraisal that already has a positive score. The number of SA objectives and 296

Representor : 202 Mr Alistair Hume (Hillreed Developments Limited)

Agent : 385 Mr Craig Noel (Strutt and Parker)

ID / Type Heading Summary of Response Officer's Recommendation Section Economy Support noted. Chapter Appendix Four: Appraisal The text will be amended. The long- of the Core Strategy term use of the strategic gaps does Preferred Options depend on EWAR and a number of other factors such as flooding issues, contamination and landscape character. A Strategic Flood Risk Assessment study and Landscape Assessment study are being carried out at the moment (January 2007) to inform the LDF.

Representor : 402 Colin Knappitt

ID / Type Heading Summary of Response Officer's Recommendation

297 Chapter Appendix One: List of The list shows the statutory Consultees consultees all local authorities are required to consult, initially at Issues and Options stage. (PPS12) However, the Sustainability Appraisal together with the two other documents the Core Strategy and the site allocations document 'Unlocking Development Potential' was sent to over 300 individuals and organisations. More information about how the council is committed to engaging the community is included in the document Worthing’s Statement of Community Involvement, adopted in 2006. Updates on consultation and the different stages of plan making are available on the Council’s website and in the Annual Monitoring Report, also available on the website.

Chapter Appendix Two: Plans and This has been noted. Policies Influencing the Local Development Framework

Representor : 410 Ms Amy Reid (Environment Agency)

ID / Type Heading Summary of Response Officer's Recommendation

298 Document Core Strategy and A Strategic Flood Risk Assessment is Unlocking Development being carried out at the moment. The Potential Sustainability SFRA deals with both the Core Appraisal Strategy and the site allocations document Unlocking Development Potential.

Comments about water quality are dealt with in representations 398, 391, 392 and 393.

Comments about waste are dealt with in representation 390. Please also see representations 391 and 392 for officer recommendations dealing with your waste comments.

Chapter Chapter 1 Non Technical Water quality has been addressed in Summary Objective 11 of the Sustainability Framework. The quality of bathing water and percentage of new development with water efficiency measures have been included as indicators for this objective. The suggested indicators will be added provided data is available.

Chapter Chapter 5 Baseline More information will be included Information about the water quality of surface waters and groundwater provided the data are readily available.

299 Provided data are readily available more information will be included about waste.

Chapter Chapter 6 Sustainability The protection of water resources are Issues identified as a Sustainability Objective in Chapter 7 Sustainability Framework. Indicators for these objectives will be added as per your comments provided data is available. Reference to water quality will be added to the sustainability issues.

Reduction of waste generation and disposal and achieving sustainable waste management has been included as a Sustainability Objective in chapter 7. Two indicators have been identified. Reference to sustainable waste management will be added to the sustainability issues.

Chapter Chapter 7 Sustainability Observations and suggested points for consideration. Government Guidance on the Water Framework Framework Directive is expected in March 07 therefore reference has not been made to the guidance so far.

300 The additional indicators will be considered to see whether they are relevant and useful in Worthing's context.

The waste indicators are considered to be relevant and sufficient. There needs to be a balance between all possible indicators to be monitored and the practicality and usefulness of adding indicators. The amount of waste collected and recycled is not necessarily linked to the spatial planning strategy for Worthing but much more influenced by collection methods, grants and education of people regarding waste minimisation and recycling etc.

The suggestion to add an indicator for 'materials used in new developments that are produced wholly or have content from secondary/recycled sources' is considered too detailed and will not be added. It is considered that the existing indicator 'Percentage of construction materials re-used or recycled' is sufficient.

301

Chapter Appendix Two: Plans and Object - There does not appear to be any structure to the way in which the The plans are ordered by Policies Influencing the plans and programmes are presented. environmental, social and economic Local Development issues. Framework

Waste Framework Directive is included as a National Plan/Programme. This Waste Framework Directive will be needs to be changed, as it is in fact an International Plan/Programme. changed to international.

Landfill Directive and Waste Strategy will be added.

Wildlife and Countryside Act will be added.

302 Emerging Minerals & Waste Development Framework for West Sussex will be added

Chapter Appendix Four: Appraisal Observation noted. of the Core Strategy Preferred Options

Representor : 120 Mr Chris Cousins (West Sussex County Council)

ID / Type Heading Summary of Response Officer's Recommendation Chapter Chapter 5 Baseline it should not be overlooked that there is a pre-existing pattern of land use and A local landscape study is currently Information settlement development which extends back into prehistoric and Roman being undertaken by consultants to times. The West Sussex coastal plain has demonstrated that it was equally inform the LDF on landscape matters. active, in archaeological terms, as the South Downs. Supporting Evidence Base should make reference to West Sussex Landscape Strategy 2005 and other study landscape assessment work.

303 Reference will be made to the various landscape strategies and surveys mentioned by West Sussex County Council.

Archaeological remains in the West Sussex coastal plain will be considered at planning application stage as required.

Chapter Appendix Two: Plans and A local landscape study is currently Policies Influencing the being undertaken by consultants to Local Development inform the LDF Core Strategy on Framework landscape matters.

We have identified an objective in the SA 'to protect the rural setting of the town'. Landscape is included in the appraisal of the LDF documents under this objective.

The various landscape studies will be added to Appendix 2 with an explanation of the guidance.

304 Historic environment issues at planning application stage will be dealt with at that stage. Core Strategy policy ENV1 deals with the built environment including building design and townscape character. The Core Strategy is a strategic spatial planning document and will not set out detailed regulatory development control policies.

Chapter Appendix Five: Appraisal It is unclear as to whether the Sustainability Appraisal truly assesses the The 'Building out to sea' proposal has of the Preferred Options Preferred Options stage as far as Aquarena and Building out to Sea. been added to the Aquarena site after Unlocking Development the Issues and Options stage as it Potential has evolved from the Masterplan proposals. It has been added due to commercial interest and is an opportunity to maximise seafront use in accordance with corporate regeneration objectives. The development would benefit from new sea defences. The feasibility of the development will need extensive research and the option has been included now to be consulted on as part of the Unlocking Development Potential document. This is in accordance with PPS12 which states not to stifle any development proposals.

305