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The Association's response to CDC 'preferred approach' consultation
Friday 25 January 2019

The document may be accessed at

http://www.chichester.gov.uk/CHttpHandler.ashx?id=31058&p=0

 

 

Requiring a rural parish to accept a significant housing allocation, when 84% of its land area is covered by the ever stricter  protection afforded by an AONB designation, was always going to place a severe distortion on the notion of respecting and enhancing the distinctive qualities of the settlement. This document is not Town or Village Planning; it is merely the allocation of open fields to a housing estate without any real regard to either the principles of sustainable development or notions of the ancient art of ‘place-making’. The former has been in recent times the entire justification of the role of state regulation and the latter was its original justification in the twentieth century. Both are spectacularly swept aside in this District-level document! We are left with a threadbare set of justifications for a bad decision.

 

The Bosham Association finds the ‘Preferred Approach’ document highly contradictory, expressing fine sentiments with respect to the principles of sustainable development, but then willfully ignoring them in the allocation of specific sites to housing estates (AL6 and 7.) Furthermore, it shows scant regard to the natural relationship that must be maintained between Downs and Harbour. These two areas, which ‘enjoy’ protective designations (National Park and Area of Outstanding Natural Beauty), are inextricably linked by geology, drainage, ecosystems, landscapes, and traditional land management. The background document on ‘Strategic Wildlife Corridors’ offers wafer thin connectivity to address these issues, aligned only as it is with narrow strips along the chalk streams . The ‘Sustainability Appraisal’ which is supposed to underpin the document is out of date in respect of the sewerage systems and fails to recognise the landscape assessments made by ‘terra firma Consultancy’ (Nov 2018) and an earlier one by Hankinson Duckett.

 

Moreover, the local plan review and conclusions were made before CDC had received the landscape assessment by Terra Firma.  This raises two points

1. The proposed allocation at Highgrove should be reviewed in the light of the Terra Firma assessment conclusions.  For example the character area in which the Highgrove site is located has been assessed as having a Medium/ low capacity.  The definition of this is

Medium / Low capacity (orange) – A low amount of development may be accommodated only in limited situations, providing it has regard to the setting and form of existing settlement and the character and the sensitivity of adjacent landscape character areas. In some cases no development would be acceptable and the reason for this is explained in the conclusion.

The final paragraph of the character area assessment states

It is possible that some built development may be accommodated within the existing cluster of buildings and potentially to the north of Broadbridge provided it is informed by further landscape and visual impact assessment and sensitively integrated into the landscape, respecting the historic settlement pattern and local distinctiveness.  Great care would be needed to be taken to avoid any landscape or visual harm ensuring the separate identities of the settlements are protected and considering valued views. (NB the Bosham Parish Neighbourhood Plan identifies valued views across Highgrove to the South Downs)

The proposed allocation at Highgrove is contrary to all of the above statements. 

2. The Terra Firma assessment reaches the same conclusions as the earlier Hankinson Duckett assessment and therefore carries greater weight.

 

 ‘The Preferred Approach’ merely acknowledges that “The site is relatively free from physical constraints, although there are landscape sensitivities associated with the openness of the site and the views into the site from surrounding areas.” (6.53) This is nothing less than a massive understatement because the site occupies the narrowest of gaps between the National Park and the Area of Outstanding Natural Beauty. The value of maintaining open countryside between (inter alia) Bosham and Fishbourne has been recognised by local people many times in the last five years when they have been given the opportunity to voice their views in an evidenced and documented manner. It was the basis of the strategic vision in the draft Bosham Parish Neighbourhood Plan, supported in a poll of over 450 local residents, expressed in no less than two planning applications for development at Highgrove Farm, attracting no less than 100 objections on these occasions. Furthermore, the allocation by CDC of the 50-unit site in the SW quarter was also opposed by the Parish Council and overwhelmingly by local people. The repudiation of site AL7 for housing development could not be more emphatic on grounds of evidence and popular choice.

 

A number of important policy principles derived from a fundamentally sound grasp of the spatial characteristics of the whole District are outlined in the ‘Preferred Approach’; and then duly ignored. This submission identifies just how wrong the selection of AL7 is, but many of the comments also apply to AL6.

 

The identification of AL6&7 as sites proposed for coalescence with neighbouring historic areas threatens that which is upheld in 7.162 namely “Chichester District itself can be divided into four locally distinctive character areas: (and then inter alia)

4. The Coastal Plain framed with the backdrop of the South Downs to the north. Characterised by a flat, open more exposed landscape with remnants of woodland and small villages connected by a network of narrow winding lanes and minor roads

Furthermore  para 7.163 states that “Within these character areas there are also several views and vistas, which should be protected in the design and layout of new development. These include views inter alia “Towards Chichester Cathedral” and “Towards the South Downs from the Coastal Plain

Therefore, the selection of AL7 compromises two groups of views which policy professes to protect, the views are both east/west and north/south reciprocating! We are indeed in Alice in Wonderland!

 

So what of the distinct villages surrounding the free-standing cathedral city of Chichester? The Development Strategy states:

The starting point for housing development at Service Villages is that in principle, they are suitable places to accommodate new housing. However, consideration has been given to other factors in determining whether a settlement is a suitable location for additional housing growth, including infrastructure capacity, the existence of suitable sites and consultation responses”.

We shall see how much heed is paid to all three points but especially the last. Having failed to heed any of the previous consultation responses on this site, we have little confidence that the District means what they say.

 

Bosham is designated a ‘service village’, but has already ‘landed’ a ‘hub’ function, namely St Wilfrid’s Hospice by decision of the Planning Committee overruling the recommendations of professional officers. Moreover the experience over the last five years is that the District Council fails to heed ‘consultation responses’ as was evidenced by the Neighbourhood Plan process, the ‘premature’ planning application for Highgrove, the ‘strategic allocation’ by CDC Cabinet and most recently the actual planning application for 50 houses at Highgrove. All of these proposals attracted overwhelming opposition and all these popular local sentiments have so far been ignored. It does therefore not bode well for this current ‘consultation’.

 

The CDC current sustainability strategy states: “The Local Plan Review strategy has been shaped by a range of factors including (inter alia):

Environmental constraints – avoiding flood risk areas, protecting environmental designations, landscape quality, the historic environment and settlement character”. We shall show that each of these elements have been belittled or ignored in the rush to find a big site for a big builder in the Parish of Bosham.

 

Policy S26: Natural Environment states inter alia:

Ensuring there is no adverse impact on the openness of views in and around the coast, designated environmental areas and the setting of the South Downs National Park. See Policies DM19, DM20 and DM28.” Yet the Chichester Harbour Conservancy, The South Downs National Park and the Chichester Harbour Trust among others have all expressed either strong objections or severe reservations about the allocation of this site being chosen for a housing estate.

 

Policy DM19: Chichester Harbour Area of Outstanding Natural Beauty (AONB) states inter aliaEither individually or cumulatively, development does not lead to actual or perceived coalescence of settlements or undermine the integrity or predominantly open and undeveloped, rural character of the AONB and its setting;

 

Policy S26: Natural Environment states inter aliaConsidering the quality of the agricultural land, with the development of poorer quality agricultural land being preferred to the best and most versatile land.” In addition the proposed site  for development (ASL7) was recorded by MAFF in 1995 as having land of ‘good’ or ‘very good’ quality (The fieldwork was conducted at an average density of 1 boring per hectare. A total of 16 borings and one soil pit were described.) Why are we losing this valuable agricultural land when food security is a rising concern?

 

Policy DM28 is worth quoting in full:

Natural Environment The impact of proposals will be carefully assessed to ensure the protection, conservation and enhancement of the landscape of the Plan area. Planning permission will be granted where it can be demonstrated that all the following criteria have been addressed:

“1. There is no adverse impact on: 

The openness of the views in and around the coast, designated environmental areas and the setting of the South Downs National Park; and 

       The tranquil and rural character of the area.

“2. Development recognises distinctive local landscape character and sensitively contributes to its setting and quality;

“3. Proposals respect and enhance the landscape character of the surrounding area and site, and public amenity through detailed design;

“4. Development of poorer quality agricultural land has been fully considered in preference to best and most versatile land; and

“5. The individual identity of settlements, actual or perceived, is maintained and the integrity of predominantly open and undeveloped land between settlements is not undermined.

Yet we have the decision of the Planning Committee of 19/12/18, which although challenged, decided to ignore all these considerations and give consent to the first 50 houses on the Highgrove site.

 

Let us remind ourselves on the significance of this 1.2km stretch between the Downs NP and the Harbour AONB, a deer, fox, badger, water vole, field mouse, hedgehog and the like currently have to hazard a main rail line and a four-lane trunk road. Avians like buntings, finches, siskins, longtailed tits, warblers, wrens, gold crests use the hedges as corridors. Habitat fragmentation stares us in the face and all for the sake of failing to protect a kilometre-wide separation.

When Julian Glover expresses the hope that these protective designations will form the hubs of networks, there has to be a rural fabric upon which the networks can function. Continuous urban sprawl is not conducive. A bad decision on AL7 cannot be undone and a vital strand of our biodiversity is unravelled forever. Harbour and Downs habitats will be divorced forever.

What is the cultural value of the Villages-City-Downs-Harbour matrix? Allocating AL7 will tear the view betwixt the ancient yews of Kingley Vale, the beech of Stoke Clump and our harbour lands and will destroy it forever. The freestanding City of Chichester set amidst distinctive surrounding villages will be replaced by sprawl already mockingly called ‘Emschester’. Is this to be the legacy of District Planning in this decade?

 

Back in 2013 the CDC assessment (SHLAA) of the site threatened development over all 16.8 ha (41 acres) with 265 houses which by 2014 the village had rated 11th out of 11 potential sites. CDC is now proposing 300 houses plus a two-form entry primary. Such a school would cost about £8m and there is no supporting evidence of the need for it. Better space standards on the existing single-form entry primary is desirable as is a dedicated recreation area. This could be more conveniently addressed at lower cost, less disruption, whilst maintaining the geographical centrality of the school site within the village by finding an alternative site for the existing recreation ground. Yet, to our knowledge, no landowners have been approached.

 

Instead, we know from previous proposals that Barratts want to allocate a space on which others could build and pay for a school at the extreme NE of the site next to the railway line.  This site would be almost as far as possible from the historic core of the village, whose heritage value has hitherto benefitted so many pupils at the school since 1896 when it first occupied its present site. It is one of the features of our local acculturation that makes village identity distinctive. It is a location from which most homes, as well as church, manor, mill and quay can be reached on foot, a centre for sorties from school.

 

The ultimate embarrassment of the document must be the statement that after a peripheral estate of 300 houses is completed, irreversibly narrowing the gap between distinctive villages, the District Council will consider introducing a policy to prevent ’gap-filling’! It says:

“5.42 The countryside also performs an important role in providing a setting for the plan area’s settlements. Maintaining the individual identities of communities is an important priority for the Council. The most obvious way of achieving this is keeping them this is keeping them physically separate from each other and areas outside of the plan area e.g. Emsworth to the west and the Coastal West Sussex Urban Belt to the east. Development over recent years has tended to cause some merging of settlements. The Council considers that designating areas between settlements as countryside gaps to be kept free of urbanising development may be an appropriate way of seeking to prevent further loss of local identity. A study of the potential for introduction of gaps between various settlements across the plan area is currently underway. Should the results of this study support the case for introducing such gaps, then this provision will be included within the next iteration of this Plan.”

 

So what to make of that? What words best describe the CDC approach? Contradictory, confused, disingenuous, devious, insincere, hum-bug, perfidious?

 

Did the District consider all the options? Well no, not really. One option that seems privileged in ‘The Preferred Approach’ was addressed in the revamped sustainability appraisal

The new sustainability appraisal notes:

4.6.5 Option 2 - Focus on the East / West Corridor Here the vast majority of new development is focussed to the west of the City along the A259 and railway corridor, with no provision at Tangmere or Hunston and very limited development on the Manhood Peninsula. This reduces some of the negative impacts of Option 1 on the Manhood (as does Option 1A) but without some of the advantages that come from a more even distribution around (and close to) Chichester City. The additional 750 homes near to the railway line will help mitigate the additional distance to travel into Chichester City for some, but not all households. There is also an increased risk of impacts due to the development becoming out–of-scale to the existing form and facilities of the settlements and also cumulative landscape and biodiversity impact as the settlements in this area begin to coalesce leaving smaller gaps between them.[Emphasis added]

This observation has been ignored or disregarded. One starts to wonder why these background documents have been commissioned at public expense, when they are steadfastly ignored.

 

The sustainability appraisal re-states that the Headroom at Harts Farm WWTW is still 400 despite the council being notified that since this figure was estimated in 2013, there have been a further 148 connections and an additional 50 with the approval of 50 units at Highgrove Farm. The details of the consented connections since 2013 are listed below for connection to the Harts Farm WwTW:

Bosham Hoe and Smugglers Lane 90 with a potential of another 30

Westwinds, Station Road /Arnold Way  4

Spindlewood, Bosham Lane 1

Oyster Mews, Bosham Lane 4

(St) Benedict’s, Bosham Lane 2

Whitwell House, Taylors Lane 1

South of Harbour Way. Taylors Lane 2

Fire Station Site, Critchfield Road 3

Church Farm Meadow, Bosham Lane 5

Next to Sailaway, Main Road 1

St. Wilfrid’s Hospice – equivalent of 25

East Ashling 10

Total additions consented 148

Highgrove consent 19/12/18 - 50

On this basis, there could only be a maximum headroom of 200 unless Southern Water makes yet another revision of their evidence base as they did at the last moment for the application considered on 19/12/2018. Reliability of their methodologies is being sorely tested. Moreover, this takes no account of the state of the groundwater, the porosity of the sewer-pipes and the infiltration of storm water into the whole system necessitating discharges (under licence) of untreated sewage into Chichester Harbour. The SA takes no account of this documented and ever-present threat to a precious environment, which is supposedly protected under SSSI, RAMSAR, SNC and SPA designations. There are also bathing water directives that have to be considered.

 

The SA simply lacks detailed knowledge of groundwater and drainage conditions. This leads it to state blithely that SuDS systems are appropriate when they are not. In particular, it ignores the very high watertables, which exist on land to the east of Ratham Lane and on Highgrove Farm fields. Yet the developers had in their possession a report (Land at Highgrove Farm, Main Road, Bosham

Flood Risk Assessment Aug 2014 for Barratt Homes by www.paulbashamassociates). Among its conclusion were the following:

8.6 The Landmark Flood Data shows that there is the possibility of a very high water table. This was borne out by a site visit, where standing water was observed in the south-west corner. Considering this, infiltration is unlikely to be suitable for draining the site.

8.7   Given that infiltration is unlikely to be suitable, a drainage strategy has been prepared based on positively draining all hard surfaced areas, restricting the outflow to greenfield run-off rates, and attenuating the excess water within oversized pipes, a cellular storage system with the central area of POS, and a balancing pond in the south-west corner. Due to the level nature of the site, surface water has to be pumped from the cellular storage system to the remainder of the system further south.

8.8   Outfalls into the ditch will be restricted via Hydrobrakes to existing greenfield run-off rates – 5.11l/s for a 1 in 1 year storm, 13.8l/s for a 1 in 30 year event, and 19.1l/s for a 1 in 100 year event. A complex Hydrobrake system will manage these outfalls.

 

The Sustainability Appraisal undertaken by CDC to underpin the Plan Review also ignores the landscape consultant assessment (Terra Firma) of the Highgrove site as having the following type of sensitivity (to quote again):

Medium / Low capacity (orange) – A low amount of development may be accommodated only in limited situations, providing it has regard to the setting and form of existing settlement and the character and the sensitivity of adjacent landscape character areas. In some cases no development would be acceptable and the reason for this is explained in the conclusion

 

The justification for a new two-form entry primary school – what is the evidence of need? There are no scheduled annexes to justify this assertion.  The Bosham Parish Neighbourhood Plan team extensively canvassed ideas for a replacement school and canvassed alternative more central sites. At that time, staff and parents were content with the existing single-form entry school and its current location in the heart of the village and within walking distance of all the historic built assets of the medieval core. A new school at Highgrove would be car-dependent adding to congestion as is evidenced already with the current school parking/drop-off problems in Walton Lane and the intense traffic congestion surrounding larger schools e.g. the Bourne Community School in Manor Road/Park Road, Southbourne. In addition, a primary school adjacent to a busy railway line is far from desirable. Furthermore should the existing school site become redundant, and then it will surely go for more housing (which has not been counted contributing toward the Objective Assessment of Housing Need). It would be far better to address the question of bespoke playing fields and environmental education through the conversion of the current recreation ground to exclusive school use. It would then be possible to allocate of a new recreational area to replace it whilst at the same time addressing the net shortage of public recreational space for size of the Bosham’s population, which was identified in the Neighbourhood Plan.

 

In conclusion, when we turn back to the criterion used in the original Bosham Parish Neighbourhood Plan for the selection of suitable sites for housing we find that the Highgrove proposal scores amongst the worst of sixteen sites surveyed in the Neighbourhood Plan preparation. What were those criteria? They were:

 

1. Bio-diversity

2. Flood/Sewerage Risk

3. Transport

4. Landscape & Heritage

5. Village character

6. Best use of land,

7. Employment and economy,

8. Energy and climate change, mitigation.

9. Access and provision of services,

 

Thus we see that not only does the Highgrove site spectacularly fail on many objective criteria, but it also fails to make a contribution to that vital concept of good town and country planning, that of place-making, being instead a mere land allocation for a peripheral housing estate. The District Council may be exercising its power in this matter under the provisions of the Town and Country Planning Act, but what it is doing is manifestly not town and country planning.