Arun Draft Local Plan Comments from Villages Action Group

These comments on the Arun Draft Local Plan have been prepared by the Villages Action Group to assist the effective development of Arun District Councils Draft Local Plan. The Villages Action Group represents residents in the three parishes of Barnham, Eastergate and Aldingbourne. It was formed originally in 2003 to fight large scale Greenfield development in the area and has been re-invigorated by the Option 2 housing and A29 by pass proposals in the draft Arun Local Plan 2012 .

Introduction

The Villages Action Group welcomes preparation of Arun’s Draft Local Plan as a means of promoting a coherent view of the needs of the District and a mechanism for guiding future development. However the Village Action Group believes that the current draft needs to better reflect the needs of the area and its residents and present a coherent achievable vision.

The Draft Local Plan was published in July 2012 as part of an 8 week consultation. The publication of the draft during the summer holidays, in the year of the Olympics, was regrettable. The draft refers to a large volume of background documentation and further relevant documentation has been published elsewhere. In view of the competing demands on the time of volunteers during the consultation period there may therefore be further matters which VAG would wish to raise at a later stage of the Plan process (including EiP) which it has not been possible to adequately research in the time allowed.

VAG helped raise awareness about the plan by the following means:Encouraging the 3 Parish Councils to hold Open Meetings for the public and distributing ADC’s comments sheet and summary information about proposals affecting the villages. Putting information on the VAG website about consultation events, open meetings and how to respondDistributing leaflets advertising ADC’s events and the Open Meetings.Holding a public meeting to provide further opportunity for questions and comment and information about how to respond.Holding a stall in Barnham to draw attention to the fact that consultation closes on 10th Sept and provide further opportunity for questions.

VAG has drawn on the following contributions in preparing this reponse:Points made by the public at 4 parish and VAG public meetingsPoints made by the public attending/after attending ADC consultation eventsPoints made by telephone, Email, via the VAG website and a “Stop the A29 Bypass” facebook group set up by members.Contributions from residents with appropriate professional experience.

The public consultation process

The National Planning Policy Framework (NPPF) provides the context in which public consultation on the Local Plan should be conducted. That context would seem to require a paradigm shift in the approach that Planning Authorities need to take.

In the foreword to the NPPF Greg Clark indicates (Para 12) that:

“this should be a collective enterprise. Yet, in recent years, planning has tended to exclude, rather than include, people and communities. In part, this has been a result of targets being imposed, and decisions taken, by bodies remote from them. Dismantling the unaccountable regional apparatus and introducing neighbourhood planning addresses this. In part people have been put off from getting involved because planning policy itself has become so elaborate and forbidding – the preserve of specialists, rather than people in communities.”

The introduction to NPPF states (Para 1 last line):

“It provides a framework within which local people and their accountable councils can produce their own distinctive local and neighbourhood plans, which reflect the needs and priorities of their communities”

The first of the twelve Core planning principles starts by indicating that planning should:

“Be genuinely plan-led, empowering local people to shape their surroundings, with succinct local and neighbourhood plans setting out a positive vision for the future of the area.”

Promoting healthy communities (Paragraph 69) “The Planning system can play an important role in facilitating social interaction and creating healthy, inclusive communities. Local planning authorities should create a shared vision with communities of the residential environment and facilities they wish to see. To support this, local planning authorities should aim to involve all sectors of the community in the development of Local Plans and in planning decisions, and should facilitate neighbourhood planning…..”

Plan-making (Paragraph 155) ..“Early and meaningful engagement and collaboration with neighbourhoods, local organisations and business is essential. A wide section of the community should be proactively engaged, so that Local Plans, as far as possible, reflect a collective vision and a set of agreed priorities for the sustainable development of the area, including those contained in any neighbourhood plans that have been made”

Paragraphs 183 and 184 of the NPPF are also relevant.

The Village Action Group (VAG) supports a more open and engaging public consultation exercise involving the Parish Councils and embracing the emerging Neighbourhood Plans.

VAG feels that despite the positive statements within the Draft Local Plan Par 1.5 and the Overview Par 2.1 there appears to have been little engagement and consultation with the public in preparation of the draft and numerous requests to extend the consultation process, which was held over the school summer holidays in Olympic year, resulted in only a one week extension. The result in our opinion appears to be a desire to set the strategic objectives ahead of the completion of an effective neighbourhood planning process. In the minds of many local people this would render the Neighbourhood Plan process redundant, with communities left to deal with the consequences of strategic decisions with which they profoundly disagree. This process does not square with the idea promoted by the NPPF nor the concept of improved local decision making and the Big Society which was part of this government rationale in pushing forward the NPPF.

We thank ADC for holding 3 public consultation meetings in the 3 villages, which provided valuable opportunity to question planning officers and view detailed maps which tend to be slow to download and difficult to view properly online.

Sustainable Development

The NPPF makes it clear that the purpose of the planning system is to contribute to sustainable development. The UK Sustainable Development Strategy ‘Securing the Future’ sets out five ‘guiding principles’ of sustainable development : Living within the planet’s environmental limits; ensuring a strong, healthy and just society; achieving a sustainable economy; promoting good governance; and using sound science.

The draft has a section on Sustainable Development but there is nothing in the draft which commits the Council to pursuing a clear strategy for ensuring development is in practice sustainable. and acknowledging it does not appear to commit itself to this process, The only clear commitment appears to be Para 7.4 which indicates that ‘The sustainable growth of its economic base will be reliant on ensuring the protection of these sectors .. namely agriculture, horticulture as well as tourism”. Unfortunately even this misses the point – see the five principles above.

There is also no assessment of Arun’s current environmental footprint against which an approach to achieving sustainability can be effectively planned and measured.

This position is further compounded by the Sustainability Appraisal which fails to provide any rigorous or effective test of the plans proposals. Consequently the Plan’s overall approach to Sustainability is unsound.

The implications of climate change does not appear to have been effectively addressed within the report. For example, there is no reference to a plan for reducing carbon emissions or encouraging carbon capture/storage, which may include planting more woodland and taking steps to protect grassland. The environmental implications of outcommuting, of additional housing creating additional car journeys, for example, are not addressed.

Economic Development

The overall terms Arun’s Employment and Enterprise makes for depressing reading. VAG understands and supports the principle of promoting economic development but believes that this must be based on a realistic achievable strategy.

Open For Business – An Economic Strategy for Arun 2009-2026 Section 5 indicates that:

‘Over the recent past, Arun’s economy has performed steadily. It’s growth has not been spectacular, but nor has it been disastrous. Although the number of jobs in Arun grew only marginally between 2001 and 2007 (by 390 jobs or 0.9%) rates of unemployment were very low over this period.

Trend-based forecasts published by Experian in 2006 suggested that 6,500 net additional jobs would be created within the district between 2006 and 2020; a liner extrapolation to 2026 would increase the figure to almost 9,000.

However these trends pre-date the current recession. They also appear optimistic given the scale of recorded growth between 2001 and 2007 (+390 jobs).

There are no other, more recent economic forecasts for Arun that are in the public domain.

More recent forecasts exist for other areas and these obviously take some account of the impact of recession. Informed by these, speculative adjustments to Experian’s 2006 forecasts would suggest something in the order of 5,000 net jobs in Arun over the period 2006-2026.

However this may be too optimistic. Recent work commissioned by West Sussex County Council and completed by Local Futures suggests that within the 2009 calendar year, Arun is likely to see job losses numbering 1,125 some 2.6% of the employment base. This would, if true, total three times as many jobs as were created between 201 and 2007.

The economy of Arun, like that of most other local areas is affected by the current recession.

The net effect of this points to low economic growth for the District. The 3,100 projection for the growth (Ref Employment and Economic Land Assessment December 2010 ) in jobs now appear to start from a lower base, given the projected 2009 loss. This suggests that overall Arun may only achieve growth in the region of 2,000 jobs or around 4.3% based on 2001 figures over the plan period.

There is no economic evidence that we can find within the Draft Local Plan or the supporting documentation that supports the need for a major expansion of housing beyond the 6,000 (Housing currently allocated, plus Village allocations) nor is there evidence that the infrastructure improvements proposed to the roads, in particular the A29, will aid economic development. Indeed, Table 1 on P7 of the Employment and Infrastructure Strategy 2012 is reported as showing that no improvements are necessary to the A29 for the delivery of strategic employment sites. A reference to realignment of the A29 increasing the appeal of the area to investors appears unsubstantiated.

VAG believes that Arun need to rethink its approach. It is unrealistic to expect companies to be attracted from outside the area with a marginal reduction in travel times on the A29 given the “pull” factors which create competition with Portsmouth and Southampton, which have good motorways links and ports. National companies are also less likely to remain at times of economic stress, when branches tend to be closed, than locally connected companies, so it makes more sense to provide the conditions in which small, local companies can thrive.

The Plan should build vibrant long term vision around sustainability, maintaining and generating a quality environment both rural and urban which is attractive to local people and likely to attract in new business in the long term. Within this context it should be promoting the development of local talent, and local business opportunity could be emphasised. More could be done to promote education and training / skill development along with the provision of low cost start up units. VAG would also suggest that there should be more partnership working with Parish councils to look at local employment opportunities. With Arun Officers working directly with Parish Councils.

The ongoing refurbishment of Bognor and Littlehampton as attractive seaside towns to visit and where local people go to shop or for leisure, is welcomed as is the development of recreational activities which will assist the local tourist industry. These are felt to have more potential to enhance the economy than an A29 by pass.

Soil, Horticulture and Equine Developments

The Draft Plan indicates (Paragraph 12.1) that it is Government Policy to safeguard the long-term potential of the best and most versatile agricultural landing conserving soil resources. Paragraphs 12.2 and the Plan recognise that much of the land classification for the District is

1, 2 and 3a. However the plan proposes to put the 2,000 strategic housing allocation on grade 1 and 2 agricultural land.

The Environmental Appraisal says of DM5 (which incidentally should read DM8) in relation to Soil – Soil Quality “this policy affords protection to the highest quality agricultural land and so will have a positive impact” The Sustainability Appraisal fails to mention soil quality at all in its review of Strategic Housing. Indeed the Sustainability Appraisal is so ineffective in its analysis of a number of issues that it meaningless.

The soils affected by the strategic housing allocation are Brickearths belonging to the Park Gate series and, being highly productive and currently capable of producing 11 – 12.5 Tonnes of wheat to the hectare.

Manor Farm Eastergate is a viable farm business based on 170 dairy cows producing around 8,000 to 10,000 litres of milk/ cow / year and employing two people. The proposed development of housing on this site would destroy an existing rural business, the livelihood of a local family and sweep away the last of our local dairy farms, once a traditional feature of the area.

Horticulture is identified as a key employment sector and one of four key sectors which are strong in the local economy. Water supply will be a long term issue here as for agriculture but the impact of substantial additional housing on the available water supply is not mentioned neither is the point addressed in the Sustainability Appraisal.

Housing numbers

The Draft Local Plan quotes a number of background documents and cites an extensive programme of consultation. VAG’s experience is that there appears to be a widespread lack of awareness among the public that this public consultation programme has been in place.

Housing Policy no SP8The Draft Local Plan presents two housing options, A target build of 6,000 by 2028 and a target of 8475 by 2028. The latter figure relates to the Regional Plan which is based on the 2001 census and sets a housing figure for the District of 11,300 by 2026 which has been extrapolated to 12,481 by 2028.

We think that it would be helpful to set out more clearly how the figures have been derived from the Strategic Housing Land Availability Assessment (SHLAA) because it is not immediately clear how these figures relate to a given / current population growth rate or a projection of economic growth

The Arun Locally-Generated Needs Study produced in May 2010 outlines the following points:

2.1 Housing need and demand is driven by growth in the population and the changing structure and age of households. Changes in the size and make up of the population are driven by three main components: birth rates, death rates and net migration, which is the balance between in and out migration to the District. In Arun District, the death rates has exceeded the birth rate in recent years and thus without net migration into the District, its population would fall. Because of the age structure of the population, with zero net migration, the Districts population would fall by 21,000 over the 20 year period to 2026.

2.2 A level of net migration into Arun District is thus necessary to maintain and grow the population base. This is necessary to support consumer and public services and the local economy more widely. We estimate that around 5.4% population growth is necessary in the district over the period to 2026 just to maintain the current level of employment in the district. Delivery of 360 homes per year would be required to support this.

2.3 Our research has shown that projections of future population and household growth are particularly sensitive to the migration assumptions. The level of net migration to the District will have a significant impact on the level of migration required. This however is an area in which there is some degree of uncertainty.

2.4 National projections of population and household growth in Arun are published respectively by the Office of National Statistics (ONS) and the Department of Communities and Local Government (CLG), both from a 2006 base. These project that the Districts population will increase by 27,000 or 18.6% between 2006 – 2026, and that 17,300 homes will be required driven by the resultant growth in households.

2.5 While these projections are based on a variety of inputs, they are particularly influenced by assumptions regarding future levels of migration. The ONS projections assume that levels of net in-migration to the district will rise from 1800 persons per annum to 2,300 over the 2006 – 2026 period. Our analysis suggests that this is above long-term trends; where over the last 15 years net migration has averaged 1900 persons per annum. Moreover the most recent statistics indicate that levels of net migration have actually been declining in recent years falling from 2,400 people in 2001-2 to just 800 people in 2007-8.

Figure 4, in this study provides an analysis of housing need in units per annum based on employment growth and population growth. Based on annual employment growth of between 230 and 380 jobs per annum (a total of between 4,600 to 7,600 jobs over the plan period 2006 -2026) the consultants projected the need of between 550 and 670 homes per annum.

Their projection of a 4% Growth (we assume this is meant to cover the economy), and a 2,100 increase in Employment Growth and 8.2% population growth up to 2026 generates, by their calculation a annual housing requirement of 450.

Through some extrapolation the 565 units per annum housing figure proposed by the Regional Strategy would suggest that some 4,700 jobs over the plan period, 361 jobs per year, would be required along with a population growth of some 11%. This appears unrealistic against Arun’s economic performance.

If Arun achieves static employment over the Plan period with a 5.4% population growth rate housing requirements amount to 360 units per annum.

It is unclear what the current in –migration figures / population growth or employment figures are being used by Arun are, but it is difficult to believe in the current climate that they amount to anything like the Office for National Statistics (ONS) or consultant’s projections. Economic projections are covered in the previous section and the Employment and Economic Land Assessment report predicts an increase of 3,130 jobs in the period up to 2026.

However, this latter figure appears to be unrealistic given the slowdown in the economy. It also needs to be borne in mind that the District is the ninth most heavily populated in the

South East, with only a small land area outside the protection of a National Park, which places pressure for development on a very small land area.

VAG accepts the need for housing to meet local needs and supports the lower housing figure of 400 p.a. and would like to see a clearer, robust evidence base within the plan for it. We object to the higher housing figure which is unsound. The conclusion here (as far as we can determine in the time available) is that neither the current population growth nor employment growth justify the higher housing figures and that there is no need for a strategic housing allocation of 2,000 additional houses within the plan.

This level of strategic housing in the Eastergate, Barnham, Aldingbourne area would completely change the character of the area. It would dwarf all three neighbouring villages and merge them together and contradicts some of the stated policies within the plan of ‘minimising impacts on the countryside’, preserving the individual character and identity of Arun’s towns and villages, avoiding over-development or the merging of settlements.

This scale of development is also unsustainable. The area is already an Area of Water Stress and the increase in housing would exacerbate this problem. There is a lack of infrastructure particularly Waste Water Treatment to cope with this level of increase, it will further increase and exacerbate traffic congestion on the existing road network and exacerbate flooding.

The Plan also indicates that ‘ The development of land that has not previously been developed (Greenfield) should only be considered where Brownfield land cannot be developed. However it is not possible from the SHLAA to establish what Brownfield land has been considered or indeed to establish what Brownfield land is available (if any) across the District.

We would like to see a clearer analysis of all sites outside settlements with future potential that are contained within the SHLAA (appendix 5).

Policy no SP9: We support the proposed policy towards provision of affordable housing (both rented and shared ownership) and suggest that the Council needs to be robust in ensuring that this is delivered. We also support the aTransport

Whilst a range of transport options are to be welcomed they are presented as a wish list of ideas with no concrete proposals beyond the realignment of the A29 to avoid the Woodgate crossing.

No clear strategic business case has been put forward to justify the proposed by-pass and closure of the Woodgate crossing other than a broad and unsupported assumption that it will improve economic development in Bognor.

There is no strategic transport study or figures to back up this proposal in the Draft Development Plan, either to provide a context for this proposal or to indicate that this specific proposal is the right or only solution to transport issues within the district. Other road improvement and other transport solutions may deliver greater public and business benefits.

The Plan does refer to the West Sussex Transport Plan 2011 -2026 .

Para 16.0.1: The West Sussex Transport Plan 2011-2026 identifies key transport issues in the district including ……

Level crossings on the A29 and the A284 cause delays between the A27 and the main towns of Bognor Regis and Littlehampton.

However the West Sussex Transport Plan indicates that the A29 is not part of the Strategic Road network within the county. Its is also worth making the wider strategic point that the A29 is a narrow and often twisting, single carriageway road for the whole of its length with only one town by-pass at Billinghurst. In that context the Woodgate crossing is only one of a plethora of pinch points consisting of small roundabout and junctions. Trying to focus on a single point within the A29 which is outside the strategic road network displays a lack of strategic thinking. Improvements in the A29 in one location outside of the strategic road network risk exacerbating problems elsewhere including further north on the A29.

The West Sussex Transport Plan also mentions in other bullet points including:

Rail services to and from the District particularly both Littlehampton and Bognor Regis and London are perceived as slow and there is a limited supply of modern rail stock available to provide extra capacity along the West Coastway.

Bognor Regis Station, in particular, is in need of improvement to make it a more attractive transport interchange for visitors and local communities.

Liaising with the rail industry to investigate ways to reduce the delays caused by level crossings.

Yet these alternative and potentially more sustainable options are not mentioned in the Draft Local Plan. It would be more sustainable to explore improvements in the rail network including signalling options (a point mentioned in the West Sussex Transport Study on several occasions) within the context of this plan both to improve transport and economic development.

In terms of the Woodgate crossing no attempt has been made to explore other solutions, a point raised in Councillor Derek Whittington’s response to the study:

“In addition the Bognor Regis Northern Relief Road is under construction and will provide an east-west link A259. This is not only a Bognor northern bypass, but also a southern bypass to the B2233 for all the communities along it from Yapton through Barnham, Eastergate, Westergate and Aldingbourne to Crockerhill.

Traffic flows along this new A259 are not known. What is also not known is the degree to which future movements along the A29 will be affected. It would be unwise to draw conclusions and make plans before these are known and calculations can be made in conjunction with signalling and gatedown times improvements by Network rail and others which would also benefit other rail level crossings along the coast.

This point also applies to the reduction in vehicle movements when the Lidsey Landfill site closes.”

There are already road schemes in place that will benefit traffic flows around Bognor and to the A27. Indeed the strategic transport principles for the area put forward by WSCC were put forward to take the traffic flow along the road network around the villages, principally the A27, the A259 Bognor Relief Road and Lyminster by pass improvements.

There is no indication or evidence within the Development Plan of how strategic transport issues are being dealt with in partnership with the surrounding Councils, which is required by

the National Planning Policy Framework, or alternatives to A29 realignment explored. This raises the question of whether other more effective transport solutions have been considered.

The specific A29 proposal put forward in the Draft Local Plan based on the Parsons Brinkerhoff (PB) study as commissioned by Arun is completely ineffective.

The traffic flow figures are based on the 2011 traffic flow figures of 13,129 annual average daily rate (two way) with a growth figure of 1.1 bring the 2020 figure to 14,489. These figures do not account for the proposed housing allocation of 2,000 homes as set out in the Local Plan nor do they account for the potential for traffic diverting to use this route.

The assertion in paragraph 4.3.3 that the highways agency note that traffic flows are unlikely to be a significant problem is erroneous as it deals with the existing flow rather than the increased flow resulting from the development. (Ref comment below)

In terms of the specific proposals:

Setting aside the lack of a strategic rationale the proposed by pass routes do not seem to provide an overall solution but move the problem of congestion to a series of northern junctions with the B2233, where there are narrow roads. These wider problems are not addressed in the study and there is a significant risk that the proposals will exacerbate existing traffic flows, damage a number of local businesses, causing job losses and loss of services, and require significant additional expenditure of public money to resolve the problem created by the proposal.

The traffic figures being used are based on projections of current traffic movements and do not take account of the additional traffic generated by the strategic housing allocation or the parish allocations. Based on the proposed strategic and parish allocations the Crockerhill Junction will be unable to cope with the additional traffic flows. Adjustments to the layout could include banning the right turn from the A27 but the Highways Agency say this “would allow some increased capacity at this junction but would lead to an increase in congestion and delay at upstream and downstream junctions” (ie principally Tangmere and Fontwell). These would require further development to manage traffic movements. Comments by the Highways Agency, 9th March 2011, indicate that this is at capacity and that 2,500 houses in the Aldingbourne, Barnham and Eastergate area could not be supported in transport terms.

The environmental considerations of the preferred options put forward by PB covering options A and D are rather superficial and would not support any argument that one route is more or less environmentally damaging than any other.

The PB study does not cover the full costs of implementing the plan. The costs of the Route A link to the A27 at Crockerhill are not covered (this junction is already reaching capacity). This route will in any case not deal with east bound traffic movements, which will require a further northern route to link to the Fontwell Avenue/ Fontwell Roundabout at an additional cost of £10 Million in order to avoid putting north and westbound traffic onto the very narrow stretch of the B2233 at Nyton, which is used by pedestrians and cyclists but has no pavement. The effect and costs of the knock on effect of dealing with traffic flow from the other routes, including route D, and their connection to the A27 at Fontwell is not covered. The Villages Action group reject all of the A29 by pass routes/proposals.

The Fontwell roundabout is also at capacity and would require additional expenditure to resolve traffic flow onto the A27 and from the A27 South if the right hand turning to the B2233 from the West is closed.

The roundabouts at the War Memorial and Basmati Restaurant (previously the Labour in Vain) are historic local points surrounded by a number of listed buildings and would require substantial re-engineering, which is likely to cause considerable local opposition.

PB themselves acknowledge in Paragraph 4.3.2 the need for a broader scale economic modelling assessment at a later stage.

There is no overall clarity about how the proposal will be funded. Indeed the PB study itself acknowledges (appendix 6) that until a preliminary Business case is developed, a single recommended or preferred model for funding and repayment cannot be made.

As a consequence of the uncertainty of the overall scale of additional road improvements required, which might rise to £30 – 40 million, it is unclear how the wider infrastructure will be funded to support this development of 2,000 houses. E.g. Doctors surgery, school, water demand, drainage, flooding relief and sewerage capacity issues. The Draft Local Plan indicates that an Infrastructure Delivery Plan will be produced at the next stage of the Local Plan.

The publication of the Infrastructure Delivery Plan is critical. It is unlikely that the proposed housing developments will not meet the costs of providing the additional infrastructure and that additional infrastructure will not be provided, creating additional problems, or the infrastructure will have to be provided at public expense. We feel that given the potential scale of risk it would therefore be appropriate to seek assurances from the Councils 151 Officer that these risks and potential additional costs have been fully assessed and that no additional infrastructure costs will fall on Aruns taxpayers.

It will also not be acceptable for the District Council to simply leave water provision and sewerage provision to the Water Companies who will simply pass on the development costs to the customers. Costs must fall on any developers.

Proposals by the District and County as the Highway Authority should encourage north, east and west bound through traffic from Bognor to use the strategic road network and discourage traffic from the A29. For example:Change the road designation from A29 to B2924 Remove all through route destinations from the road signs on those roads and replace with local destinations. Add the through route destinations of London, Dorking, Horsham, Crawley & Gatwick Airport to east bound A259, A27 & A280 signage. Add London & Heathrow Airport destinations to west bound A259 and A27 signage.Place a 3-ton limit (except for access) on the B2924 (formerly A29) and B2233. Leave level crossings in place to discourage through usage.Place a 30 mph speed limit on both roads south of their junctions with the A27.Revised Satnav instructions, particularly for HGVs.

The Local Plan identifies the construction of a container rail link at Barnham. It is not clear why this policy is being proposed, and why in this location. It was understood locally that this proposal had been abandoned by Network Rail and we question whether ADC has checked that it is still part of Network Rail’s plans. This area is impossible to access for large vehicles via the existing road network without substantial improvements: A sheltered housing complex

for the elderly now abuts the railway access and there is a low bridge on the road to Yapton. If the rational for this was to improved rail link / freight movements from Bognor why not build it at Bognor?

Design

VAG welcomes much of the Design section. However, we would suggest that the Council develop a policy to identify and promote design improvements in key areas (villages, road, and townscapes) in conjunction with Parish councils and community groups.

We welcome the inclusion of climate change principles and targets for new development. However, these need to be set in the context of Arun’s current environmental footprint.

While there is reference to the need for energy efficiency and to renewable energy there is no clear policy requiring new housing, or housing adaptations and extensions, to incorporate any kind of energy conservation/renewable energy measures. This is a glaring omission, given that the text indicates that this is not an onerous burden on developers. The District is in a favourable location for a range of renewable power and heating technologies and it should be policy to refuse any development proposals which do not incorporate renewable energy as well as high standards of energy efficiency unless there are sound practical reasons for making an exception. Given the availability of FiTs and the Renewable Heat Incentive financial reasons are not sufficient reason to exclude this.

Green Infrastructure

We have not had time to look fully into the Green Infrastructure proposals and these represent initial views, which we may wish to comment further on at a later stage. However, we feel the Green Infrastructure section provides too simplified an approach and fails to integrate properly Historic, Biodiversity and Landscape issues across the district as a whole.

For example, Para 17.0.6 Explains that the green infrastructure framework includes the additional typologies of Beaches and Coastal areas and features such as rifes and twittens. But key features, such as the majority of the Aldingbourne and Lidsey rifes and the stretch of woodland that abuts the Rife through Nyton, lie outside the Green Infrastructure areas. These represent important wildlife and landscape features in their own right and we feel that protection of these needs to be strengthened.

The concepts of ‘Sense of place’ and Historic Landscape Character were also omitted from the original landscape study so that there is no basis for understanding and driving this initiative forward in the Green Infrastructure areas nor across the District as a whole.

“Policy DM 27 Protection of Landscape Character – - The historic character and development pattern of settlements is respected, taking into account their distinct identity and setting. This cannot be effectively implemented because there is no historic landscape Character Assessment in place to support it. - Either individual or cumulative development does not lead to actual or perceived coalescence of settlements or undermine the integrity or predominately open and undeveloped character of the area. Presumably this policy does not apply to Barnham and Eastergate which would be overwhelmed by 2,000 houses.

The policy also fails to identify the need for the assessment of the historic aspect of landscape Character.

There is also no policy towards promoting tranquillity in its broadest sense, covering both noise and light pollution and maintaining the integrity of the landscape.

Conservation and Archaeological Heritage

No assessment has been made of the Historic Landscape Character of the District so there is no clear basis for identifying historic landscape / heritage assets.

There is only one Area of Special Character in the 3 villages yet there are a considerable number of listed buildings. Local village histories have been produced which set the local historical context. There are arguably further areas in the District, including the 3 villages, which qualify as Areas of Special Character. Policy DM32 needs amending to provide a more pro-active policy in this respect.

Policy SP22 states the Council will take a “pro-active stance towards heritage assets which are at risk”. However, in our view this is not enough. The Arun to Chichester Canal runs south of Barnham, Eastergate and Aldingbourne, of which parts survive. It is an example of a heritage asset which we have not seen identified in the Plan which could contribute to improving wildlife and provide a recreational asset for people from Bognor. We suggest this policy is extended not only to heritage assets which are at risk but also those with potential to provide recreational, tourism or other public benefit.

Natural Environment:

Key sites have been identified but it is not clear evidence of an assessment of the impact of development on these ‘Natura 2000 sites’ and the mitigation measures that might need to be put in place other than Pagham Harbour. There is no mention of climate change in this section though this might have been covered in the Green Infrastructure Report which we have not yet had the time to review and will wish to reserve or position on this.

Whilst mention is made in the text to other policy areas the Natural Environment, Biodiverstity could be better integrated with Landscape issues within the Plan overall.

Water

It was a criticism of the Regional Plan that the region lacked much of the critical infrastructure to deal with the level of development and in particular the Housing figures proposed. A key issue was the lack of water as a natural resource. The Arun Local Plan acknowledges that the area is identified as an ‘Area of Serious Water Stress’ yet a significant level of housing is proposed that will exacerbate an already stressed problem. Portsmouth Water score 39 in the Environment Agencies final classification of Water Stress, the 5th most stressed company area in England.

The Draft Local Plan identifies in Par 20.1.9 that “the Chichester Chalk Catchment Abstraction Management Strategy which covers the majority of Western Arun is assessed as being ‘over licensed’, which means that if existing licences were used to their full allocation they would have the potential to cause unacceptable environmental impacts at low flows. Yet the plan does not identify the impact of building between 6,000 to 8,000 houses, but simply supports the general principle of encouraging water efficiency.

Policy DM 39 states that development will be permitted where :sufficient water supplies can be provided in time to serve the development and;provision of a water supply is not considered detrimental to existing abstraction, river flows, water quality, fisheries amenity or nature conservation.

The policy proposes that all new development is water efficient and … must meet a water efficiency standard of 105 litres per person per day reducing to 80 litres / day by 2016. The cost implications of achieving water efficiency standards of 80 litres / day could reach £2,000 per home.

The Arun Infrastructure and Funding Study 2006 indicates that (Page 144 par 7); a range of comments from the Environment Agency; “Water resources are finely balanced between meeting the demands on existing abstractions and the need to protect river flows to meet environmental and other in-stream requirements. There is a general presumption against any further consumptive abstraction from the chalk aquifer and from rivers during the summer.

The sustainability of abstractions and their impact on river flows will be reassessed in line with the requirements of the Water Framework Directive to bring all water bodies up to good status. Water bodies already identified by the Environment Agency as not meeting the desired status are; Lower Arun (BlackDitch) – moderate status, Aldingbourne Rife (Lower) – poor status and Lidsey Rife – bad status.

The Environment Agency note there is a trend of rising demand from existing households in addition to the projected demand for water to supply future development. As a minimum they require all new development to meet water efficiency standards of 105 liters / head / day (as required by Code for Sustainable Homes level 3) moving to 80/liters/head/day (level 5) after 2016.

Against this background the construction of an additional 6,000 – 8,000 new homes therefore appears unsustainable and the proposed efficiency measure probably unattainable. This point is also not effectively addressed in the Sustainability Study

The Sustainability Study’s assessment of Water Resources against the Strategic Housing and Parish and Town allocations states “This will not have a direct impact but will have a significant indirect negative impact through increasing pressure on supplies although this is indeterminate at this stage”. This is a less than credible assumption because it will certainly have a direct impact, because each house will use water.

Waste Water Treatment is also discussed in the Arun Infrastructure and Funding Study 2006. In relation to Waste Water Treatment at Lidsey WWTW :

This WWTW serves Yapton, Barnham, Westergate, Eastergate, walberton, Fontwell, Slindon, Norton, Flansham and Middelton on Sea. The current number of dwellings is circa 8,500.

Circa 10% increase in utilisation of the WWTW would be likely to trigger consent review with the EA. Works capacity and environmental constraints in the receiving water course would be necessary. Whilst land is available to accommodate additional plant capacity, options for disposal of the increase in wastewater would depend on discharge consent standards set by the EA, perhaps necessitating discharge to the sea, or transfer of treated waste to another location.

In relation to costs Page 155 Para 8 indicates that;

In terms of infrastructure cost differences between the options*, the most significant primary cost difference is the works required to the WWTWs. Even through these costs are likely to be funded through the regulatory process, the cost of overcoming the environmental constraint for Option 3 should be avoided if possible.

The option 1 ‘Urban Extension’ and Option 2 ‘Ford’ would require works to Ford WWTW, possibly with a budget of say £20 million, whereas Option 3 ‘Expansion of Inland Settlements’ would also require works to Lidsey WWTW, possibly with a similar or even larger budget due to the probable need for transfer of treated wastewater to another location.

It is considered most unlikely that the regulator will sanction the cost of works to both WWTWs within the same AMP period, 2015 -2020, which is what would be required for Option3. Furthermore, there is limited environmental capacity in the receiving water courses downstream of Lidsey WWTW, with competing demand within the environmental capacity from proposed development at Chichester. It is considered highly probable that development at Chichester will be given higher priority over the expansion of Inland Settlements within Arun District. Accordingly, Option 3 is not recommended as it is most unlikely that this option will deliver the required growth.”

(* Options here relates to 1,2,3 in the original 2009 Arun Plan. Option 3 includes 2,500 houses proposed in the Aldingbourne, Barham Eastergate area)

The observations of the 2009 Infrastructure and Funding Study are equally relevant in considering the current Draft Local Plan in that upgrading the Lidsey site is expensive (£25 Million at 2009 costs), raises key environmental concerns over water discharge and the likely hood of additions costs of transferring waste water, competing for resources against WWTW works at Ford and Chichester.

Flooding is a key area of concern within the District and there is also an increasing flood risk associated with the development. While developers would propose the construction of balancing ponds to deal with excess water from new housing, the villages of Aldingbourne, Eastergate and Barnham have suffered a number of serious flood incidents in recent years and would expect any development to provide the finance to remedy these problems. Communities towards the coast suffered serious flooding in the summer 2012, a warning of the possible implications of climate change for the area. There are also insurance implications given the current lack of agreement between the Government and the insurance industry on flood risk policies.

Infrastructure Provision and Implementation:-

The proposed Infrastructure Deliver Plan will provide much needed clarity to the production of a Local Plan in identifying the scale of infrastructure required, the costs and the deliverability of key aspects of the Plan. An Infrastructure and Funding Study was produced by Arun in 2009 to accompany an earlier Plan. Option 3 of that study considered the construction of 2,500 Houses in the Barnham, Eastergate Area. Based on a re-evaluation of those costs which included Education, Heath care, Emergency Services, Community Facilities Open Space Transport and Utilities these costs now exceed £90,000,000.

£20,213,851Education£3,280,000Health Care£2,125,000Emergency Services£1,950,000Community facilities£1,400,000 " "

£1,985,000Open Space£30,000,000Transport*£30,000,000Utilities (Lidsey)**£90,953,851Total

* reflects the current £20 Million costs associated with current road option D, up from £14M in the original study, plus an additional 10M to cover the additional road improvements, which is likely to be an underestimate).

** Reflects the £30 Million cost of infrastructure costs at Lidsey. An increased of £5M on 2009 costs to reflect inflation).

In terms of overall cost the proposal is unfeasible. These significant infrastructure costs will not be met by developer contributions alone so the scheme would appear is undeliverable unless Local Government / Central Government or the Utility Companies provide additional funding, which will fall ultimately on local tax payers. At a time of financial stringency public bodies should not be increasing their expenditure or exposing their residents to additional direct or indirect taxation.

Conclusions

In moving forward to the next stage we trust that Arun District Council will pick up the threads of greater community engagement. We hope ADC will also allocate time and resources to the Parish Councils to ensure the effective development of Neighbourhood Plans in parallel with the evolution of the Local Plan, as a means of engaging the community in a developing a future vision and building capacity to take forward the effective implementation of the Local and Neighbourhood Plans.

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