Preferred Approach' Consultation

Southbourne Parish Council Agenda Item 4

29 January 2019

Chichester District Council Local Plan Review 'Preferred Approach' Consultation

Southbourne Parish Council Responses PART B

Please use a new form for each representation that you wish to make. Please note anonymous comments cannot be accepted. Any personal information provided will be processed by Chichester District Council in line with the General Data Protection Regulations 2018. More information is available at: http://www.chichester.gov.uk/dataprotectionandfreedomofinformation.

To which part of the document does your representation relate?

Page/ 24 & 56 Policy Reference: Spatial Vision and Paragraph Number: 3.3, 3.6, 3.7, 3.8 & Strategic Objectives – 4.88 East-West Corridor

Do you support, object, or wish to comment on this policy or paragraph? (Please tick one answer)

Support □ Object □X Have Comments □X

Enter your full representation here giving details of your reasons for support/objection: Objection

3.4 Given the huge amount of development proposed for the settlements to the west of Chichester we object to the emphasis placed on Chichester in the special strategy at the expense of the settlements on the receiving end.

There needs to be a fresh look at the cumulative impact on the settlements along the A259. We are not primarily an East-West corridor; we have our own distinct identities and histories. While the term ‘East-West corridor’ describes the road and rail links to the west of Chichester it is not a sufficient description of the Bourne villages.

3.7 Maintaining and enhancing the relationship between the SDNP and the Harbour AONB requires the reinstatement of the proposed Wildlife Corridor at Ham Brook. Without this corridor, this aspiration has no teeth.

3.8 Southbourne’s “good transport links” have recently been downgraded with loss of all north- south buses which will be needed to connect any new housing growth north of the railway line to both the station and the A259. The station itself needs nearby parking and/or drop-off points, electric car chargers and secure cycle storage. .

What improvements or changes would you suggest?

We suggest that the Bourne villages area be considered a ‘green / blue ladder’ between the AONB and the National Park rather than an East-West transit corridor. Varied countryside views from the Bourne villages towards the SDNP and AONB should be protected, as should views from the A259 and railway of the local countryside and countryside gaps. This will require properly contoured development and good screening. (Continue on separate sheet if necessary)

1 PART B

To which part of the document does your representation relate?

Page/ Page 29 Policy Reference: Spatial Strategy – Paragraph Number: Section 1 Sustainable Development Principles

Do you support, object, or wish to comment on this policy or paragraph? (Please tick one answer)

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Objection

A reliance upon national ‘sustainable development’ principles is insufficient as these national policies are inadequate for delivering genuinely sustainable development.

There needs to be an emphasis on economic, social and environmental sustainability. The built environment and history, so frequently lumped in with environmental sustainability, should be considered as part of economic and social sustainability where this conflicts with natural environmental sustainability.

The construction industry is a significant contributor of carbon emissions and while we recognise that there is limited scope to make requirements beyond those mandated by national legislation the Local Plan should nevertheless indicate the direction of travel. It should set out what the community will increasingly come to expect from the industry in the years ahead, including the increasing weight that may in future be given to developments and developers which are making serious attempts to become carbon neutral.

The objective of the Local Plan should be to aim higher. While recognising that not everything is possible, we suggest referring to the principles set out in the Wildlife Trust’s ‘Homes for People and Wildlife’ policy guidance: https://www.wildlifetrusts.org/sites/default/files/2018- 05/homes_for_people_and_wildlife_lr_-_spreads.pdf and the World Health Organisation’s ‘Urban Green Spaces – A Brief For Action’: http://www.euro.who.int/en/health-topics/environment-and- health/urban-health/publications/2017/urban-green-spaces-a-brief-for-action-2017 .

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What improvements or changes would you suggest?

See comments in section above.

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3 PART B

To which part of the document does your representation relate?

Page/ Page 66 Policy Reference: Spatial Strategy – Paragraph Number: Section 17 Thorney Island

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Object

We welcome the presence of the military base and recognise that the needs of the military will determine policy while the base is maintained, including the need for an upgrade of the housing stock on the base.

However, should Thorney Island cease to be required for military purposes, rather than masterplanning for new development, the island should receive at least equal protection to other areas within the AONB, including the presumption against new development. Any proposed development should follow the principles laid out in the Chichester Harbour Conservancy’s Planning Principles policy: www.conservancy.co.uk/page/planning.

In addition, while not seeking anything that would compromise the base’s security, the policy should be to expand the Dark Skies sites and, where necessary, to take additional steps to support the existing ones e.g. by upgrading or redirecting street lighting.

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What improvements or changes would you suggest?

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5 PART B

To which part of the document does your representation relate?

Page/ Page 82 Policy Reference: Strategic Policies – Paragraph Number: Section 24 Countryside and Countryside Gaps

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Support

However, much of the language in this section is weak and aspirational rather than strong and definitive.

5.37 The coastal, alluvial agricultural plain has a particular historic and environmental character which we value greatly. This includes, but is not limited to recognition of its value for agriculture / food production. While we do not expect that this landscape will have the same protection as that inside the SDNP, it forms part of the setting for the National Park and deserves some recognition of the threats facing it from piecemeal (though rapid) development.

The draft Plan in its present form does not give sufficient recognition to the inherent value of the land. It would make sense for this to be rectified as part of a strategy or vision for the whole of the Bournes area, perhaps in a supplementary planning document.

We would like to see the preservation, protection and even reintroduction of bees and their habitats be given real consideration, given their ecological importance. It makes sense to do this as part of a policy covering countryside gaps so as to avoid conflict with humans.

We call for greater support to be offered to the establishing of community orchards and nut plantations. Doing so would also contribute to improving the balance between people and nature, enhancing social sustainability goals and promoting wellbeing.

5.40 We strongly support the “encouragement of proposals that enhance the woodlands and recreational links to and within this area.”

5.41 There needs to be greater engagement with the SDNP and greater recognition from the SDNP that it is at risk of becoming an island, which will have serious negative impacts upon the park. We need the National Park to be more flexible in accepting a greater amount of housing within the park in order to relieve some of the pressure on the park’s surroundings. While

6 development is concentrated around the Park, we need to know that the Park will not object to the provision of infrastructure that such development needs to be sustainable, provided that it is planned sensitively.

5.42 We strongly support the maintenance of individual settlement identities. Southbourne would like to have a significant input into the formation of a settlement gap policy (and expects other communities along the A259 to feel the same). We would like a meaningful input at an early stage so that we can help shape a policy that commands wide public support.

What improvements or changes would you suggest?

See comments above.

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7 PART B

To which part of the document does your representation relate?

Page/ Page 84 Policy Reference: Strategic Policies – Paragraph Number: Section 25 The Coast

Do you support, object, or wish to comment on this policy or paragraph? (Please tick one answer)

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Object

This policy is very weak. A policy for protecting and managing the coast simply must address the wholly inadequate waste water infrastructure capacity and the frequent discharging of untreated waste into the Harbour.

It must also include a robust strategy for mitigating pressure on the harbour and coastal habitats from walkers and dog walkers by providing for alternative, attractive routes. This should clearly link up with policies promoting wildlife corridors, countryside gaps and green/ blue space.

The Plan should also seek to work with agriculture and horticulture businesses to reduce the impact of chemical and nutrient run-off into the Harbour. We recognise that there are constraints both in terms of national policy and market forces but the Plan should make clear that the direction of travel is towards greater environmental sustainability and reducing the environmental impact from businesses.

(Continue on separate sheet if necessary) What improvements or changes would you suggest?

See section above.

8 PART B

To which part of the document does your representation relate?

Page/ Page 85 Policy Reference: Strategic Policies – Paragraph Number: Section 26 The Natural Environment

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Object

This policy is too weak.

5.52 & 5.53 The Plan should seek to work with agriculture and horticulture businesses to reduce the impact of chemical and nutrient run-off into the Harbour. We recognise that there are constraints both in terms of national policy and market forces but the Plan should make clear that the direction of travel is towards greater environmental sustainability and reducing the environmental impact from businesses.

We note that the adopted Local Plan links its Natural Environment strategy to that which protects and promotes biodiversity, but this link seems to have been dropped in the draft proposal. We recognise that there is a section on biodiversity but question the implication of the breaking of this link.

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What improvements or changes would you suggest?

The policy needs to be strengthened.

9 PART B

To which part of the document does your representation relate?

Page/ Page 86 Policy Reference: Strategic Policies – Paragraph Number: Sections 27 and 30 Flood Risk and Water Management

Do you support, object, or wish to comment on this policy or paragraph? (Please tick one answer)

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Object

It is very disappointing not to see a much stronger role for the use of green / blue space in mitigating flood risk. E.g. reed banks and areas designated for wildlife can form both a natural flood defence and promote other environmental goals of the Plan. Tree planting should also form part of this strategy, as should other measures to strengthen the land’s resistance to flood degradation.

The reinstatement of the Ham Brook Wildlife Corridor would provide an opportunity to introduce many of these features in a part of the District prone to the flooding of homes and to storm- related discharges of untreated wastewater into the harbour.

The policy must think beyond what individual sites can do to mitigate the risk of flooding on small areas of land and look at the wider picture and what a more ambitious strategy could achieve.

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What improvements or changes would you suggest?

The policy must think beyond what individual sites can do to mitigate the risk of flooding on small areas of land and look at the wider picture and what a more ambitious strategy could achieve.

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10 PART B

To which part of the document does your representation relate?

Page/ Page 88 Policy Reference: Strategic Policies - Paragraph Number: Section 28 Pollution

Do you support, object, or wish to comment on this policy or paragraph? (Please tick one answer)

Support □ Object □ x Have Comments □

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Object

We are astonished that this policy is so thin. There needs to be a strategy which recognises different forms of pollution, including air quality, inland and coastal water and carbon emissions (not least from the construction industry). We need more detail on strategies to address the different forms of pollution and to be looking to a less polluted future, not simply mitigating against the deterioration of the status quo.

(Continue on separate sheet if necessary)

What improvements or changes would you suggest?

See above section.

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11 PART B

To which part of the document does your representation relate?

Page/ Page 89 Policy Reference: Strategic Policies – Paragraph Number: Section 29 Green Infrastructure

Do you support, object, or wish to comment on this policy or paragraph? (Please tick one answer)

Support □x Object □ Have Comments □x

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Support

However, there needs to be an explicit recognition of the sometimes conflict of interest between green infrastructure primarily intended to be of human / community use and enjoyment and that intended to protect natural habitats and which may require restrictions upon access by the community.

There also needs to be much more thought given to coordinating the creation and protection of multiple green / blue infrastructure sites across the Plan area (or sub-sections of it). Many opportunities will be lost if sites are considered separately rather than as part of something larger. ‘Islands’ of green space are of much less benefit to humans and wildlife than larger, linked green and blue infrastructure. Again, this supports the reinstatement of the Ham Brook Wildlife corridor.

(Continue on separate sheet if necessary)

What improvements or changes would you suggest?

See comments in section above.

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12 PART B

To which part of the document does your representation relate?

Page/ Page 90 Policy Reference: Strategic Policies – Paragraph Number: Sections 30 & 5.64 Strategic Wildlife to 5.68 Corridors Background Paper 032:Strategic Wildlife Corridors Supporting Document 024, Solent Recreation Mitigation Strategy

Do you support, object, or wish to comment on this policy or paragraph? (Please tick one answer)

Support □x Object □ Have Comments □x

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Support

We are delighted to see a wildlife corridor policy included within the draft Local Plan, as this builds upon the aims pursued in the made Southbourne Neighbourhood Plan and the work of the Southbourne Environment Group. We do however very strongly object to the removal of the proposed Chidham / East of Nutbourne Wildlife Corridor, identified in the Background Paper. It should be reinstated.

Doing so would work towards the policy objectives of S30, and complement its specific proposals. 1) There are a great many “preferable sites available outside the wildlife corridor” so reinstatement would not hinder the District or Parish’s ability to meet its housing target. 2) Without prejudging the community consultation it is conceivable that proposed development sites WITHIN the proposed corridor could be approved provided they do “not have an adverse impact on the integrity and function of the wildlife corridor”.

Paragraph 5.5 of the Background Paper states that "the close proximity of residential areas and proposed development, mean that the corridor may be too narrow to act as a suitable functional strategic corridor." This actually prejudges the review of the Southbourne Neighbourhood Plan and we reject this argument. The proposed Ham Brook Wildlife Corridor is or could easily be, as wide as others in the policy paper and it is for the community – through the Neighbourhood Plan – to determine where development goes ahead. The community cares very deeply about the local

13 environment and could easily choose to focus development outside of the proposed route of the Wildlife Corridor.

There is no national or local policy reason why there should be no more than one wildlife corridor in a single Parish, especially where there is no conflict with the points above / in policy S30 and where the parish is one of the largest in the District and is home to several distinct communities. On the contrary, reinstating the Ham Brook corridor would strengthen the goals set out in paragraphs 5.64 and 5.65 of the Local Plan, namely, allowing the "movement of species between areas of habitat by linking wildlife sites and reducing the risk of small, isolated populations becoming unsustainable and dying out... They also function as green infrastructure."

This last point is itself emphasised by the Plan’s policy AL13 for Southbourne and many objectives would be advanced by reinstating this particular Wildlife Corridor. i.e.:

8. It COULD provide for some public open space for the Parish (not all of which is, will be part of or will be connected to Southbourne VILLAGE’s Green Ring). 9. It would enhance the setting of the SDNP and reduce settlement coalescence (without restricting development elsewhere in the Parish). 10. It would expand provision for green infrastructure. 11. As per background paper paragraph 5.5. referenced above, it would reconcile the need to avoid an adverse impact on the nature conservation interest of identified sites and habitats while maintaining a wildlife corridor wide enough to be of ecological value. 12. It would provide mitigation to ensure the protection of the SPA, SAC, and Ramsar site at Chichester Harbour.

As per Supporting Document 024, Solent Recreation Mitigation Strategy, paragraph 2.12, there is a requirement for the creation of a Suitable Alternative Natural Greenspace (SANG). Furthermore, Southbourne’s made Neighbourhood Plan’s Green Ring policy specifically aims to provide alternative routes for dog walkers to relieve pressure on the harbour. As per paragraph 4.12 “these could be created by a developer as part of a very large housing scheme [such as is proposed for Southbourne] or alternatively will be implemented through the Solent Recreation Mitigation Partnership.”

The route for the proposed Wildlife Corridor outlined in paras 5.3 and 5.4 of the Background Paper does not present the full picture of the area’s ecological importance. The Ham Brook follows a natural environmental feature from the AONB to the SDNP. This natural water course is home to water voles (seen by CDC Wildlife Officer and local environmental volunteer as recently as January 2019) and the land north of Priors Leaze Lane is a Barn Owl Habitat (as referenced in Chidham and Hambrook Parish’s made Neighbourhood Plan). There is ancient woodland either side of the railway line next to the trout farm and this is a dormouse habitat too.

In conclusion, S30 is an excellent policy but it MUST be strengthened by the reinstatement of the Ham Brook Wildlife Corridor. Doing so would not compromise any development objectives of the Local Plan. Indeed, doing so would advance several objectives and policies within it.

What improvements or changes would you suggest? As above section

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14 PART B

To which part of the document does your representation relate?

Page/ Page 127 Policy Reference: Strategic Site Paragraph Number: Section AL13 Allocations - Southbourne

Do you support, object, or wish to comment on this policy or paragraph? (Please tick one answer)

Support □ Object □ Have Comments □x

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Comment

6.88 – To sustain and enhance Southbourne’s role as a hub it is VITAL that development is properly phased AND that necessary infrastructure provision is made prior to new occupations.

Policy AL13 item 12: the protection of the SPA, SAC and Ramsar site at Chichester harbour necessitates the reinstatement of the Ham Brook wildlife corridor as part of giving the harbour and wildlife that uses it ‘breathing space’ and a ladder to the SDNP and as part of the strategy to relieve the pressure imposed upon the harbour by walkers and dogs.

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What improvements or changes would you suggest?

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15 PART B

To which part of the document does your representation relate?

Page/ Page 81 & 110 Policy Reference: Strategic Policies – Paragraph Number: Sections 23 and Transport AL6 Infrastructure

Do you support, object, or wish to comment on this policy or paragraph? (Please tick one answer)

Support □ Object □ x Have Comments □

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Object

To the proposed Birdham Road to the A27 Fishbourne Roundabout.

With so much new development – and traffic – proposed for settlements along the A259, our road is going to be the focus of a huge amount of new congestion, with all of the associated negative impacts on air quality and sustainable transport goals. Feeding more traffic into the Fishbourne roundabout will only make it harder for drivers from the A259 to get onto / across the A27.

In addition, the proposed link road goes straight through a flood plain and site of great environmental importance – one which links the coast to the city of Chichester. Furthermore, the proposed link road would have a significant negative impact upon views from the coast to the city and the SDNP and from the city and SDNP to the coast and Manhood Peninsula. It would also negatively affect the setting of the proposed Fishbourne Wildlife Corridor.

We support creation of an integrated and sustainable transport plan for the District, or at the very least for the area west of Chichester. This plan should draw upon the ongoing work of the ChEmRoute group’s investigations and proposals and be coordinated with WSCC with the goal of introducing high quality and separated cycle links between the villages along the A259 and Chichester. The route or routes may include a fast but safe link along the A259 aimed primarily at experienced cyclists and commuters as well as a slower, more meandering and leisurely route north of the A259 (and perhaps the railway). To make these cycle routes sustainable they will need connections and feeder routes from new and existing developments.

16 What improvements or changes would you suggest?

See comments in section above

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17 PART B

To which part of the document does your representation relate?

Page/ Pages 35,36,64 Policy Reference: S3 Development Paragraph Number: Paras 4.111 to 4.115 Strategy and para 6.87 S4 Meeting Housing Needs AL13 Southbourne Parish

Do you support, object, or wish to comment on this policy or paragraph? (Please tick one answer)

Support □ Object √□ Have Comments □

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Strategic policy should be included that consider the area west of Chichester as a whole rather than as a series of unrelated settlements along the A259 transport route, which is implied by it being referred to as the “east-west corridor”. A number of common issues would benefit from collective and co-ordinated attention eg waste water treatment, traffic congestion/management, landscape protection, wildlife corridors and the need to prevent coalescence (para 6.87). The area is expected to provide for a minimum 2250 new dwellings, in addition to the allocations in the current Local Plan (475), and is under great pressure due to its being squeezed between Chichester Harbour and the National Park, both being areas having the benefit of particular protection. This pressure is exacerbated by the National Park not accommodating its fair share of new development and by substantial development in neighbouring Emsworth, Hampshire, that adds to the pressures on the Chichester Harbour AONB and West Sussex infrastructure including road traffic and the capacity of Thornham Wastewater Treatment Works.

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What improvements or changes would you suggest?

Supplementary Planning Guidance is required to address the issues specific to this area, provide clarity of guidance for developers and enable co-ordinated solutions.

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18 PART B

To which part of the document does your representation relate?

Page/ Page 42 Policy Reference: S6 Affordable Paragraph Number: Para 4.36 Housing

Do you support, object, or wish to comment on this policy or paragraph? (Please tick one answer)

Support □ Object √□ Have Comments □

Enter your full representation here giving details of your reasons for support/objection:

Affordable housing should relate more closely to local income levels. Local residents have made the point many times, during the preparation of the current Neighbourhood Plan and more recently in connection with the Neighbourhood Plan review, that local people cannot afford local housing, either to buy or rent. The Parish Council intends to commission a Local Housing Needs Survey which could help identify the quantity and type of need in the Parish.

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What improvements or changes would you suggest?

(add to end of para 4.34) This means housing is unaffordable to many people in the Plan area and why income levels will be taken into account in establishing house prices and rent controls. 80% of the local market rent is the maximum, but lower rents are likely to be justified in some instances.

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19 PART B

To which part of the document does your representation relate?

Page/ Page 42 Policy Reference: S6 Affordable Paragraph Number: Para 4,42 Housing

Do you support, object, or wish to comment on this policy or paragraph? (Please tick one answer)

Support □ Object √ □ Have Comments □

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Developers must deliver their “affordable” requirement if sufficient housing to meet local needs is to be provided. This should not be a problem if proper account is taken of the cost of land acquisitions and development at a sufficiently early stage. Subsections 1 and 5 in Policy S6 allow too much flexibility, especially the use of the word “appropriate” in subsection 1 which is too subjective.

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What improvements or changes would you suggest?

Delete or amend subsections 1 and 5, as appropriate.

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20 PART B

To which part of the document does your representation relate?

Page/ Page 139 Policy Reference: DM2(2) Housing Mix Paragraph Number: Paras 7.14 to 7.24

Do you support, object, or wish to comment on this policy or paragraph? (Please tick one answer)

Support √□ Object □ Have Comments □

Enter your full representation here giving details of your reasons for support/objection:

The Parish Council fully supports Policy DM(2). It considers that there is likely to be a need in the Parish for more rented accommodation, especially social rented, than is proposed in Policy DM2. It is understood that this is one of the most expensive areas for housing in the country and young people, in particular, struggle to find accommodation they can afford close to their families. A Local Needs Housing Survey of the Parish is likely to be undertaken in preparing the review of the Neighbourhood Plan to help identify the extent of local need and investigate ways to meet it. Accordingly, an alternative housing mix may be prepared for Southbourne Parish (para 7.19)

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What improvements or changes would you suggest?

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21 PART B

To which part of the document does your representation relate?

Page/ Page 74 and 139 Policy Reference: S20(6), DM1 and Paragraph Number: Para 5.5, 7.12, 7.13, DM2(3)(4)(5) 7.23, 7.24 Specialist Housing

Do you support, object, or wish to comment on this policy or paragraph? (Please tick one answer)

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Local consultation has revealed a shortage of specialist housing, especially for the elderly and the disabled. It is considered that creative policies promoting adaptable “lifetime” dwellings are required to enable the elderly to remain in the community for longer. The Local Housing Needs Survey of the Parish is expected to confirm this.

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What improvements or changes would you suggest?

Add “the disabled” into the policy.

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22 PART B

To which part of the document does your representation relate?

Page/ Page 139 Policy Reference: DM2 Housing Mix Paragraph Number: Para 7.7, 7.20 to 7.23

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There appears to be confusion in the percentage provision of 4+ bedroom market dwellings. The Preferred Approach promotes up to 20%, the HEDNA recommends 25% and the National Park is promoting 5 to 10%. It is particularly difficult to see why the Plan area figure is so much higher than the National Park. Para 7.7 implies that a number of larger houses will be vacated by the elderly downsizing or moving to extra-care accommodation but this will only happen where such replacement accommodation is available. The proposed mix is also at odds with the ONS prediction that there will be a rapid rise in single person households up to 2041, emphasising the effect of an aging population.

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What improvements or changes would you suggest?

The market housing 4+ bedroom % needs to be reduced in favour of more single person accommodation. The Parish Local Housing Needs Survey is expected to confirm this

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23 PART B

To which part of the document does your representation relate?

Page/ Pages 127 to 129 Policy Reference: AL13 Southbourne Paragraph Number: Paras 6.86 to 6.90 Parish

Do you support, object, or wish to comment on this policy or paragraph? (Please tick one answer)

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It seems likely that most of the 1250 dwellings proposed (and this is a minimum figure) will be in Southbourne village. Some sections of the local community are very concerned about the change that an over 50% increase in households, over and above the current new development of 300 dwellings, will bring. Some consider that it provides an opportunity to bring some creative thinking to the future format of the village. Whatever increase in development may come, it appears that most residents do share the view that the 30% “affordable housing” proposed in the Local Plan should be truly affordable for those people in the Parish who are in housing need, and the Parish Council has made comments on the relevant policies in this Plan accordingly.

However, at present, it is clear that Southbourne is not in a position to successfully accommodate 1250+ further dwellings due to inadequate infrastructure. While it is recognised that Southbourne village may qualify as a “hub” due to existing services, it must be recognised that a number of these are currently inadequate and substantial improvement is required before development on this scale is delivered. It is understood that new development cannot be required to pay for current deficits, but it is unacceptable to add to these problems without some “up-front” provision to cater for increased needs. Three examples serve to make the point:-

(1) Crossings over the railway, both road and pedestrian, are required before any delivery of 1250 new dwellings. Even if this development is phased, it could be assumed that there will be a completion rate of some 80 dwellings a year (1250÷15). The additional pressure on the Stein Road level crossing arising from a combination of construction traffic and new residents will create unacceptable congestion, pollution and waiting times at the barriers. Inlands Road and Cooks Lane are not suitable for lorry routing. AL13(4) “Opportunities as they arise to improve the situation relating to the various existing or planned railway crossings” is much too weak to secure timely delivery. While this may be addressed in the review Neighbourhood Plan Masterplan, support at District level is required with appropriate priority in the CDC Infrastructure Delivery Plan (IDP) (Policy

24 subsection 14).

In addition, no attention has been given to traffic management, either on the A259 or within the village, in the Preferred Approach. Strategic sites of a broadly similar scale around Chichester have integral transport proposals, but they are lacking in Southbourne. One key issue is that all along the A259 from Emsworth to the Apuldram junction it is becoming increasingly difficult for traffic entering onto the A259 (whether heading east or west) due to the high volume and at times seemingly continuous flow of traffic in either direction: this is a cause of driver frustration and potential cause of road accidents.

(2) The Parish Council has raised the issue of Wastewater treatment many times, and there have been difficulties arising from the current development sites. Reassurance is required that AL13 subsection 16 will be adhered to (16 – Ensure sufficient capacity within the relevant Wastewater Treatment Works before the delivery of development as required).

Stormwater discharges to Chichester Harbour appear to be on the increase and this is not satisfactory. The issue needs to be addressed and resolved by the Wastewater Water Quality Group (para 5.71).

(3) The Parish requires a significant increase in Public Open Space. The proposed Green Ring has received considerable public support and a Trust has been established by the Parish Council to deliver it. Some sections of the Green Ring will not be able to rely on developer delivery and while the project is included in the IDP it is accorded almost no priority (Policy subsection 14). This needs to be remedied.

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What improvements or changes would you suggest?

Specific commitment in the Preferred Approach to the delivery of crossings over the railway, assured delivery of timely and appropriate Wastewater Treatment and specific commitment to the delivery of the Green Ring.

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25 PART B

To which part of the document does your representation relate?

Page/ Page 140 Policy Reference: DM3 Density Paragraph Number: Para 7.26

Do you support, object, or wish to comment on this policy or paragraph? (Please tick one answer)

Support √ □ Object □ Have Comments □

Enter your full representation here giving details of your reasons for support/objection:

The Preferred Approach advocates a flexible approach to housing density. While an average of 35 dwellings per hectare is recognised as a reasonable guideline, the Parish Council considers that some areas of a higher density would be appropriate, especially where single person accommodation could include small privet patios, terraces or balconies (for flats) in recognition that not all householders want a large private garden, provided that appropriate public open space is delivered as an alternative. Higher densities, as appropriate, also reduce land take.

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What improvements or changes would you suggest?

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26 PART B

To which part of the document does your representation relate?

Page/ Policy Reference: Policy S23: Paragraph Number: Transport and Accessibility

Do you support, object, or wish to comment on this policy or paragraph? (Please tick one answer)

Support □X Object □ Have Comments □x

Enter your full representation here giving details of your reasons for support/objection:

Spatial Strategy, Transport Infrastructure , Page 78 s5.27 In addition, the County Council is expected to continue to support new development through a package of transport improvements which will continue to aim to reduce congestion and encourage people to use sustainable modes of travel such as walking, cycling and public transport.

This supports Southbourne’s desire for a pedestrian bridge over the railway line as that will encourage people to walk rather than drive, as well as supporting a road over the railway line as this will also reduce the walking time for many residents wherever the road is placed. It may avoid current routes which involve walking through fields and over unmanned rail crossings. A road would be safer and more useful to pedestrians. The requirement for bridge should be included in policy S23.

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What improvements or changes would you suggest?

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27 PART B

To which part of the document does your representation relate?

Page/ 7 Policy Reference: Policy AL13 Paragraph Number: Southbourne Parish page 129

Do you support, object, or wish to comment on this policy or paragraph? (Please tick one answer)

Support □ Object □ Have Comments □x

Enter your full representation here giving details of your reasons for support/objection:

7. Expansion and provision of community infrastructure potentially to include early years’ childcare provision, community hall/centre and expansion of doctors’ surgery plus flexible space for employment/small-scale leisure use;

As the open space and pitch reports put the improvement of the Bourne college facilities and the recreation ground improvements as a high priority project, this should be mentioned in this point

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What improvements or changes would you suggest?

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28 PART B

To which part of the document does your representation relate?

Page/ Page 129 Policy Reference: Policy AL13 Paragraph Number: 8 Southbourne Parish

Do you support, object, or wish to comment on this policy or paragraph? (Please tick one answer)

Support □ Object □ x Have Comments □

Enter your full representation here giving details of your reasons for support/objection:

8. Provision of on-site public open space and play areas in accordance with Policy DM34;

Object as it does not mention youth provision also, as it has been highlighted as missing and needing to be provided in the parish.

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What improvements or changes would you suggest?

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29 PART B

To which part of the document does your representation relate?

Page/ Policy Reference: Policy DM34 Open Paragraph Number: Space, Sport and Recreation including Indoor Sports Facilities and Playing Pitches

Do you support, object, or wish to comment on this policy or paragraph? (Please tick one answer)

Support □ Object □ x Have Comments □x

Enter your full representation here giving details of your reasons for support/objection:

Policy DM34: Open Space, Sport and Recreation including Indoor Sports Facilities and Playing Pitches

Object due to issues in the supporting evidence.

Chichester Infrastructure Delivery Plan, Southbourne Parish – Local Plan Review Policy SA13 page 90 section 15.4 In the title, play space (children) is given, when the project is actually children and youth combined.

The heading needs to be amended to Play Space (Children and youth)

Chichester Open Space, Sport Facilities, Recreation Study and Playing Pitch Strategy: Open Space Study Sub Area Analysis (Part 2 of 2) Page 13 table 4 This table says there is good provision for childrens play space, when section 2.3 table 3 shows there to be a shortfall throughout the district.

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What improvements or changes would you suggest?

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30 PART B

To which part of the document does your representation relate?

Page/ Policy Reference: DM34: Open Space, Paragraph Number: Sport and Recreation including Indoor Sports Facilities and Playing Pitches

Do you support, object, or wish to comment on this policy or paragraph? (Please tick one answer)

Support □ Object □ x Have Comments □x

Enter your full representation here giving details of your reasons for support/objection:

Chichester Playing Pitch Strategy Final Strategy Page 27, s4.8

It is questioned why this Options and Recommended Action states “…The priority at present lies in addressing deficiencies within Chichester itself. …” when it usually takes 30 minutes or more to access the facilities in central Chichester from Southbourne. Given the huge number of houses being built west of Chichester, either already planned for, already being built, or allowed for in this local plan, it is inappropriate to say that facilities for the existing and new residents Fishbourne to Emsworth are not to be prioritised. Central Chichester has facilities that need to be expanded. The residents along the A259 from Fishbourne to Emsworth have very few facilities and are in great need of new facilities.

Object due to issues in the supporting evidence.

Chichester Open Space, Sport Facilities, Recreation Study and Playing Pitch Strategy: Page 58 6.5 Play Space (children and youth) The FIT guidance ‘Beyond the Six Acre Standard’ recommends provision of 0.25ha/1000 population of equipped/designated play areas, with a walking distance of 100m for Local Areas for Play (LAPs), 400m for Local Equipped Areas for Play (LEAPs) and 1000m for Neighbourhood Equipped Areas for Play (NEAPs). The previous FIT guidance (The Six Acre Standard) recommended provision of 0.8 hectares per 1000 people for children’s play of which around 0.3 hectares should be equipped provision. The previous open space assessment (2013) recommended the following local standards for play space: • Quantity: 0.15 ha per 1000 population • Access: 480m (10 minutes straight line walk time) for children’s play space and 600m (12-13 minutes straight line walk time) for youth play space.

31 Current average levels of provision of children’s play space is 0.03 ha/1000 population, for youth space this is 0.01 ha/1000 population; Considering the above, there is a justified need to increase the provision of children’s play space and youth space, and there is a slightly greater identified need for increasing youth provision. Therefore, a standard of 0.05 ha/100010 is recommended for youth play space and for children’s play space to assess current levels of provision and to inform the requirements from new development. • The previous assessment recommended a combined (children’s and youth) standard of 0.15ha/1000. This new, slightly lower standard is considered to be more achievable and deliverable, whilst still providing sufficient space.

This is not acceptable. The current provision is woefully low across the district (0.03 ha/1000), according to this data. FIT recommendations are that they should be 0.25 ha/1000. Instead of leaving the proposed levels at the 2013 levels of 0.15ha/1000 or raising them to enable to eventually meet the 0.25 FIT recommendation, this policy is suggesting reducing the standard to 0.05 ha/1000 to make life easier for developers. This is letting down the children and teenagers of existing and future developments.

There is no mention here of the district’s policy on disability access. This needs to be included in the policy.

Chichester Infrastructure Delivery Plan, Sports, Leisure and Playing Pitch Facilities, Page 39 Future requirements Football The Playing Pitch Strategy has identified a future need for the equivalent of 2-3 full size floodlit Artificial Grass Football Pitches. Possible sites:  ….. Bourne Community College (school/football) Other opportunities include:  …Enhancements to off-site provision at Southbourne

This should be referenced in the local plan preferred approach.

Chichester Open Space, Sport Facilities, Recreation Study and Playing Pitch Strategy: Page 52 6.2 Allotments The previous open space assessment (2013) recommended the following local standards for allotments: • Quantity: 0.40 ha per 1000 population for main settlements and proposed housing growth areas, and 0.30 ha per 1000 population for all other areas.

The trend for smaller gardens in new development is likely to increase demand; • The previous assessment recommended differing quantity standards for main settlements/housing growth areas. On reflection, it is considered that a single standard across the study area is most achievable and deliverable; • Based on the above, there is a justified need for an increase in levels of provision and therefore a standard of 0.30 ha/1000 is recommended for analysing existing provision and for new provision.

This makes no sense – previous local standard was .4 ha per 1000 population for housing growth areas. This policy says that the small gardens in new builds will increase need for allotments. Why then reduce the local standard to 0.30 ha per 1000? More logical to increase to 0.40 ha per 1000.

Chichester Open Space, Sport Facilities, Recreation Study and Playing Pitch Strategy: Page 58 8.7 Developer Contributions 4) Thresholds for provision

32 The chart recommends no provision required for allotments, parks & recreation grounds or play space (youth) for sites of 50-99 dwellings.

Object – there should be a requirement for a provision for this size of developments. If they cannot be provided on site, then the developer should provide for facilities nearby or enhancements to nearby facilities.

Chichester Playing Pitch Strategy Final Strategy Page 40 4 APPENDIX A: PROVISION OF AGPs in CHICHESTER – OPTIONS This chart states re Option E, Bourne Community College, Southbourne - football “…3G AGP (lo… “ and rugby “..3G AGP is unlikely to be *WRC, owing to additional cost and location outside Chichester…”

This report does not take into account that adults and children at the far west of the district are travelling to Hampshire to participate in sport, due to the lack of facilties available in West Sussex. There are junior football teams on Hayling Island where half the team are from Southbourne. It takes less time to get to the far end of Hayling Island from Southbourne than it does to get into central Chichester due to the A259 and A27 traffic issues. The calculations here are based on new CDC residents only. Should there be facilities in Southbourne, the existing residents from Southbourne to Bosham will be able to use them more easily than travelling either to Hampshire or to central Chichester. Existing Hampshire residents of Emsworth, Westbourne would be likely to use these facilities. There are 2,100 houses going up now on the site off Southleigh Road in Emsworth. There are various sites in and around Emsworth involving 500+ new homes. All these new residents will be likely to use facilities in Southbourne as these will be local to them.

(*WRC = world rugby compliant)

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What improvements or changes would you suggest?

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33 PART B

To which part of the document does your representation relate?

Page/ page 15, page 25, Policy Reference: AMEC Water Paragraph Number: page 60 para.3.10.2 Quality table 1.1 Assessment 3.8.18

Do you support, object, or wish to comment on this policy or paragraph? (Please tick one answer)

Support □ Object YES Have Comments □

Enter your full representation here giving details of your reasons for support/objection:

Housing allocation: The Thornham evaluations have been based on a housing increase in the Thornham catchment area, over the period covered by the report (2020-35), of 1,000-1,500 dwellings. In view of the fact that the Havant-Emsworth plan also has many hundreds of new builds planned in this catchment area, this estimate would seem to be grossly under-estimated ref. Page 25, Table 26. Page 15: “Westbourne” should be added to Table 1.1. Page 60 para. 3.10.2 claims to include Havant but Havant is excluded in other parts of the report e.g. Table 1.1.

To which part of the document does your representation relate?

Page/ page 28 Policy Reference: AMEC Water Paragraph Number: Quality Assessment 3.8.18

Do you support, object, or wish to comment on this policy or paragraph? (Please tick one answer)

Support □ Object YES Have Comments □

Enter your full representation here giving details of your reasons for support/objection: Climate change: it is disappointing that any effects of climate change have been specifically excluded (page 28).

34 To which part of the document does your representation relate?

Page/ page 29 para. 3.2.4 Policy Reference: AMEC Water Quality Paragraph Number: page 60 para. 3.10 Assessment 3.8.18

Do you support, object, or wish to comment on this policy or paragraph? (Please tick one answer)

Support □ Object YES Have Comments □

Enter your full representation here giving details of your reasons for support/objection: Assessment of Headroom: in assessing headroom, AMEC’s report states that the Environment Agency guidelines, specify 150 litres/person/day and five people per dwelling. The report has used different figures i.e. 120 litres/person/day and 2½ people/dwelling. Their justification for this (para. 3.2.12) is that Southern Water prefer these figures. The effect is to reduce the Thornham WwTW’s current headroom from 1,063 dwellings down to 400. Any calculations must be formally agreed with the Environment Agency. Page 29 para 3.2.4 suggests that this has yet to be agreed. There is considerably inconsistence in the quotation of dry weather flow (DWF) and Headroom. Page 60 para. 3.10 indicates that consented DWF (hence Headroom) is already in excess of consent (consented DWF 6,565 m3/day, current DWF is 6,580 m3/day). Statement of headroom, without dates, or methodology are meaningless.

To which part of the document does your representation relate?

Page/ page 61 para.3.10.13 Policy Reference: AMEC Water Quality Paragraph Number: page 21 Table 2.1+ Assessment 3.8.18 2.3

Do you support, object, or wish to comment on this policy or paragraph? (Please tick one answer)

Support □ Object YES Have Comments □

Enter your full representation here giving details of your reasons for support/objection: Discharges: some assessments are omitted on WwTW, which discharge directly into estuary/coastal waters and Thornham WwTW has been put into this category (table 2.2). In practice, Thornham discharges onto Eames Farm from where it flows through Little Deep, into Great Deep before discharging into the shellfish beds (already classified as “unfavourable”) at Prinsted (Chichester Harbour) as in Page 61 para. 3.10.13. Page 21, Table 2.3 is incorrect. In its objectives (page 10), the report indicates that it should be considering any impact on shellfish. No impact on these shellfish beds seems to have been assessed.

35 To which part of the document does your representation relate?

Page/ page 61, para. 3.10.9 Policy AMEC Water Paragraph Number: page 23, para. 2.2.12 Reference: Quality page 25, para. 2.2.19 Assessment 3.8.18 page 61, para. 3.10.9

Do you support, object, or wish to comment on this policy or paragraph? (Please tick one answer)

Support □ Object YES Have Comments □

Enter your full representation here giving details of your reasons for support/objection: Storm discharges and shellfish: the report (Page 61 para. 3.10.9) states that storm discharges have been a significant problem for the Thornham WwTW. However, it specifically excludes any consideration of storm discharges over this period (2020-2035). It does not assess the effect of large quantities of primary-treated sewage (filtered only) on the Eames Farm marshland or the Prinsted shellfish beds (Page 23 para. 2.2.12, Page 25 para. 2.2.19). The AMEC report seems to suggest that the discharges processed through Thornham WwTW will have a minimal affect. This observation does not take into account, the very large levels of (Grade 1) untreated storm discharge.

To which part of the document does your representation relate?

Page/ Policy Reference: AMEC Water Quality Paragraph Number: Assessment 3.8.18

Do you support, object, or wish to comment on this policy or paragraph? (Please tick one answer)

Support □ Object YES Have Comments □

Enter your full representation here giving details of your reasons for support/objection: Data: There are significant areas, where Thornham WwTW’s data has not been provided and National Average data used instead.

Page/ page 9 Policy Reference: AMEC Water Quality Paragraph Number: Assessment 3.8.18

Do you support, object, or wish to comment on this policy or paragraph? (Please tick one answer)

Support □ Object YES Have Comments □

Enter your full representation here giving details of your reasons for support/objection: Objectives not met: Page 9 Objective “investigate demonstrably deliverable ways of dealing with Wastewater treatment capacity”. The MWH Report (2010) page 17 clearly indicates that expansion of Thornham WwTW was not viable. No comment or way of dealing with capacity limitation has been investigated.

Clear statements of exactly what additional works and what realistic dates are required.

36 To which part of the document does your representation relate?

Page/ page 91: 5.69, Policy i) Adopted Surface Paragraph 5.70, 5.71, 5.72 Reference: Water and Foul Number: + Box Policy S31 Drainage SPD

Do you support, object, or wish to comment on this policy or paragraph? (Please tick one answer)

Support □ Object YES Have Comments □

Enter your full representation here giving details of your reasons for support/objection: 5.69-5.72 , Section 9.1 of the Surface Water and Foul Drainage SPD and its referenced Headroom Tables are out of date, need to be updated, and its guidance amplified, to cover the timescale of the Local Plan Review 2019 to 2035 and the impact of future housing development. Reasoning Headroom Table 2 of the Water Quality Assessment Report states that as at 31st October 2018 the Estimated remaining headroom (households) was 1,020. This is well below the combined Southbourne and neighbouring West Sussex parishes Local Plan Review planned housing development numbers without even taking into account that Thornham WwTW also serves the Emsworth area in Hampshire which is is the subject of increased and significant additional housing development. This issue is of particular importance given the large scale development proposed for the Southbourne Parish under the Local Plan Review, that this SPD is “a material consideration when assessing planning applications or appeals for any new dwelling(s)” and that the Local Plan Review itself states that “measures will need to be put in place at each WwTW and their associated catchments and sewer networks in order to tackle current and future water quality issues to support future housing growth.” These measures include “Upgrades to physical capacity and Upgrades to sewer networks”.

To which part of the document does your representation relate?

Page/ Section 5.72 Policy Paragraph Para. 2.3, 2.4 Reference: Number:

Do you support, object, or wish to comment on this policy or paragraph? (Please tick one answer)

Support □ Object YES Have Comments □

Enter your full representation here giving details of your reasons for support/objection: 5.72, Policy S31 states that “Proposals for development within the Plan area should be able to demonstrate no adverse impact upon the quality of receiving waters” It is proposed that this statement should be amended to be clearer and more appropriate to local circumstances, as follows: “Proposals for development within the Plan area must be able to demonstrate no adverse impact upon the quality of receiving waters including with regard to the capacity and condition of existing wastewater and sewage systems, local storm discharge risk and the capacity of the Wastewater Treatment Works. The Council as planning authority will look to satisfy itself on these matters including to ensure sufficient capacity within the relevant Wastewater Treatment Works before the delivery of development as required.” Reasoning The referenced Surface Water and Foul Drainage SPD is out of date and insufficiently clear and rigorous in its guidance and requirements. The SPD needs strengthened with regard to new development requirements and potential adverse impacts on Chichester Harbour AONB, on the small watercourses feeding into the Harbour waters, given known local problems with the sewer network (as referenced in Para. 2.4) e.g. at Nutbourne, and as Para. 2.3 of the Surface Water and Foul Drainage SPD states “The condition of the water environment is not currently good enough to meet the required standards (of the European Water Framework Directive). Policy AL13 for Southbourne Parish also states that “Development will be expected to address the following requirements (including), !6. Ensure sufficient capacity within the relevant Wastewater Treatment Works (i.e. Thornham) before the delivery of development as required”.

38 PART B

To which part of the document does your representation relate?

Page/ Pages 17/18 Policy Reference: Characteristics of Paragraph Number: 2.1 to 2.5 the Plan Area – A Spatial Portrait

Do you support, object, or wish to comment on this policy or paragraph? (Please tick one answer)

Support □ Object □ Have Comments □

Enter your full representation here giving details of your reasons for support/objection:

Proposed Supplementary Planning Guidance

Object

Objection is raised to the use of the term East-West Corridor with regard to west of the City of Chichester. The use of the term corridor implies the focus of policy is on transport and through movement to the detriment of a more balanced focus on local settlement, existing residential, local countryside and amenity issues.

There is a lack of vision, clarity and coherence of planning policy towards the Bourne Villages, their character and the surrounding countryside that lies between the South Downs AONB and Chichester Harbour AONB. The current piecemeal policies approach that focuses on the individual settlements and individual thematic policies is detrimental to the coherence and effectiveness of planning policy, the character of these settlements and their surroundings and to the two neighbouring AONBs.

The Preferred Approach fails to take account of the potential impact arising as a result of the scale of proposed allocations. The adopted Chichester Local Plan Key Policies 2014 – 2029 document allocated a total of 620 additional houses: Westbourne 45, Southbourne/Nutbourne 350, Chidham & Hambrook 35, Bosham 70 and Fishbourne 70. The Review Document proposes additional housing allocations (minimum) at Southbourne 1250 houses, Chidham & Hambrook 500, Fishbourne 250, Broadbridge/Bosham 250 – a total of 2,250 additional houses, an increase of + 246% over previous allocations and with these villages taking a 46% share of proposed additional allocations in the Local Plan Review area.

The absence of a Countryside Settlement Gaps Policy at Local Plan Review stage is regretted and one is only verbally promised for June 2019. The lack of a coherent vision for the Bourne Villages is at odds with the approach taken to other Chichester areas and their communities which is reflected in a statement made by Cllr Tony Dignum (Leader of

39 CDC) on 18 October 2018 in the Chichester Observer: “there is no doubt that we live and work in one of the most beautiful areas of the country and we want to keep it that way. We aim to deliver improvements within our city and towns so that our area continues to be one of the best places to live, work, and visit in the UK. These improvements are being expressed through ‘vision’ projects for the city and for each of our towns” (Selsey, Midhurst and Petworth are cited as examples).

There is at least an equally strong case for there to be a vision for the Bourne Villages, the band of settlements, countryside and amenity land that lies between Emsworth and Chichester, the South Downs and Chichester Harbour AONBs. Not to have a coherent vision for this area is detrimental to the Bourne villages and to the neighbouring areas. Much of the character of these settlements, especially Southbourne, derives from the wider area within which they are situated.

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What improvements or changes would you suggest?

1 Chichester District Council should prepare Supplementary Planning Guidance on a vision for the Bourne Villages, comprising Westbourne, Lumley, Hermitage, Prinsted, Southbourne, Nutbourne, Chidham, Hambrook, Bosham and Fishbourne, the surrounding countryside and their relationship with neighbouring Emsworth/Havant, the City of Chichester, the South Downs and Chichester Harbour AONBs

2 The use of the term East-West Corridor with regard to west of the City of Chichester be restricted and only be used for transport issues and the A27 itself, and not be applied to the Bourne Villages and their surroundings..

The above comments/representations also relate to the following Plan references: i) Page/para nos: page 22 §2.29 Policy reference: Character of the Plan Area. ii) Page/para nos: p24 – 25; §3.3 - §3.10 Policy reference: Spatial Vision & Strategic Objectives: East-West Corridor iii) Page/para p35 Policy reference: Spatial Strategy – Policy S3: Development Strategy iv) Page/para nos: p82 – 84; §5.34 - §5.42 & §5.44 Policy reference: Strategic Policies – Countryside S24: Coast S25 v) Page/para nos: p 92; §6.4 - §6.6 Policy reference: Strategic Development - S32

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Supplementary Planning Document for Bourne Villages

Proposal 1. That Chichester District Council develops a Supplementary Planning Document and policy guidance on a vision for the Bourne Villages (Westbourne, Hermitage, Prinsted, Southbourne, Nutbourne, Hambrook, Chidham, Bosham, Fishbourne), the surrounding countryside and their relationship with neighbouring Emsworth/Havant and Chichester City and the South Downs and Chichester Harbour AONBs. 2. Use of the term East-West Corridor with regard to west of the City of Chichester be restricted and only be used for the A27 itself and not be applied to the Bourne Villages and their surroundings. Reasoning There is a lack of a vision, clarity and coherence of planning policy towards the Bourne Villages, their character and the surrounding countryside that lies between the South downs AONB and Chichester Harbour AONB. The current piecemeal policies approach that focuses on the individual settlements and individual thematic policies is detrimental to the coherence and effectiveness of planning policy, the character of these settlements and their surroundings and to the two neighbouring AONBs. (One reflection of this is the absence of a Countryside Settlement Gaps policy, currently non-existent at Local Plan Review stage and only verbally promised for June 2019.) The lack of a coherent vision for the Bourne Villages is also at odds with the approach taken to other Chichester areas and their communities. In the Chichester Observer (Oct 18) Cllr Tony Dignum (Leader of the Council) said “There's no doubt that we live and work in one of the most beautiful areas of the country and we want to keep it that way. We aim to deliver improvements within our city and towns so that our area continues to be one of the best places to live, work and visit in the UK. These improvements are being expressed through 'vision' projects for the city and for each of our towns.” (Selsey, Midhurst and Petworth are cited examples) There is at least an equally strong case for there to be a vision for the Bourne Villages, the band of settlements, countryside and amenity land that lies between Emsworth and Chichester, the South Downs and Chichester Harbour AONBs. Not to have a coherent vision for this area is detrimental to the Bourne villages and to the neighbouring areas. Much of the character of these settlements, especially Southbourne, derives from the wider area within which they are situated. It is therefore proposed that Southbourne Parish Council objects to the Local Plan Review with regard to the absence of a vision for the Bourne Villages and proposes and presses for the development and introduction of a Supplementary Planning Document as an integral element of the Local Plan. This would need to be taken forward with other Bourne Village Parishes. It is also proposed that Southbourne Parish Council object to use of the term East-West Corridor as a designation for the area to the west of Chichester between South Downs and Chichester Harbour AONBs and proposes that use of this term should only apply to the A27 and transport issues. Use of the term corridor implies the focus of policy is on

41 transport and through movement to the detriment of of a more balanced focus on local settlement, existing residential, local countryside and amenity issues.

Annexe - Cllr Tony Dignum article Chichester District Council (http://www.chichester.gov.uk/home)

Your visions for our city and towns - October 2018

There's no doubt that we live and work in one of the most beautiful areas of the country and we want to keep it that way.

With organisations and community groups from all across the district, we aim to deliver improvements within our city and towns, so that our area continues to be one of the best places to live, work and visit in the UK.

These improvements are being expressed through 'vision' projects for the city and for each of our towns. We recognise that these communities all have different needs and so each one has its own 'vision' for the future. Each vision is based on your feedback and input from the key organisations involved. For example, improvements to the street scene; support for local businesses; regeneration of areas; and creating a welcoming environment for our visitors, to name just a few examples.

Each 'vision' is at a different stage. We have already adopted the Chichester Vision and are now working hard to deliver the actions that have come from it. In Selsey, people are currently being asked what they want to see delivered for the town over the coming years. Midhurst has already benefitted significantly from its first Vision, and this is now being updated to plan ahead for the next 10 years. The Petworth Vision was created in 2014 and we are working with our partners to help deliver the projects identified within this.

As a council, we are leading the Chichester Vision, but working with a series of partners across the city, including Chichester City Council, West Sussex County Council, the Chichester BID, Visit Chichester, the University of Chichester, Chichester http://www.chichester.gov.uk/article/30640/Your-visions-for-our-city-and-towns---October-2018 04/12/2018, 22E26 Page 1 of 2

Cathedral and Chichester College. Meanwhile in our towns other organisations are taking the lead and we are supporting them. Each Vision is very much based on what each local community wants to see and how they want their area to develop.

Research shows that cities and towns that develop a strategic vision benefit significantly. Their uniqueness is protected and their economic growth and new jobs are enhanced. Like other towns and cities with a strong heritage and cultural base, the district has survived the impact of the economic recession better than many. These Visions aim to provide further opportunities for our city and towns to grow and flourish. We will be telling you more about the exciting projects that are coming from the visions. If you would like to find out more now, please visit www.chichester.gov.uk/cityandtownvisions (http://www.chichester.gov.uk/cityandtownvisions).

42 PART B

To which part of the document does your representation relate?

Page/ Pages 77,78 Policy Reference: S23 Strategic Paragraph Number: Paras 5.15 to 5.32 Policies - Transport Infrastructure/Transport Accessibility

Do you support, object, or wish to comment on this policy or paragraph? (Please tick one answer)

Support □ Object √ □ Have Comments □

Enter your full representation here giving details of your reasons for support/objection: Southbourne Parish Council responses on the Jacobs Chichester Area Transport Model Report (March 2013), Chichester District Council Chichester Local Plan – Key Policies 2014-2029 and Chichester Local Plan Issues and Options Consultation has consistently drawn attention to the restricted scope of the transport studies undertaken to establish the impact of proposed development allocations within the Plan area. Studies have been concentrated on establishing the effects in the immediate vicinity of Chichester, particularly on the junctions of the A27. Traffic movements generated within/or destined for Southbourne Parish are assigned to a single Traffic Zone (TZ73). These movements are aggregated with other movements in the other TZs of the Western Corridor in order to assess the impacts at the cordon boundaries of the County boundary with Havant/Hampshire but most significantly the point of contact with the A27. Mitigation requirements have been assessed solely in respect of reducing increased congestion at A27 junctions. In respect of Southbourne generated movements these relate to the Fishbourne Roundabout.

CDC, in association with WSCC Highways, has failed consistently to examine local network impacts other than those projected to arise on the 19 junctions in the immediate vicinity of Chichester and the A27. This remains the situation with the update by Peter Brett associates of the Jacobs Study. However, in respect of the Bourne Villages this approach fails to take into account the impacts likely to arise within the local road network of the respective traffic zones. In particular, this lack of examination fails to take account of the potential impact arising from the scale of proposed housing allocations in this corridor. The adopted Chichester Local Plan Key Policies 2014 – 2029 document allocated a total of 620 additional houses comprising: Westbourne 45, Southbourne/Nutbourne 350, Chidham & Hambrook 35, Bosham 70 and Fishbourne 70. The Review Document proposes additional housing allocations (minimum) at Southbourne 1250 houses, Chidham & Hambrook 500, Fishbourne 250, Broadbridge/Bosham 250 – a total of 2,250 additional houses, an increase of + 246% over previous allocations and with these villages taking a 46% share of proposed total additional

43 allocations in the Local Plan Review area.

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What improvements or changes would you suggest?

CDC together with WSCC Highways should undertake to provide specialist advice to those Parish Councils chosen to implement proposed strategic housing allocations through Neighbourhood Plans in order to assess the impacts of the scale of such allocations on the local highway network. Such advice should be provided in order to aid site selection prior to any master planning of the subsequent development proposal and to help find solutions to traffic problems arising.

The above comments/representations also relate to the following Plan references:

Strategic Development/Design Strategies, pages 92-93, §6.1-§6.6. Policy S32

Strategic Site Allocations – Southbourne, pages 127-129, §6.68-§6.90; Policy AL13

Transport & Accessibility, pages 148-149, §7.4-§7.52; Policy DM8.

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Declaration

I understand that any comments submitted will be considered by Chichester District Council in line with this consultation and will be made publicly available on their website www.chichester.gov.uk and may be identifiable by my name or organisation, if provided.

Name (print): Date: