Comment

Local Plan Review: Preferred Approach 2016-2035

Representation ID: 1830

Received: 07/02/2019

Respondent: Ms Paula Chatfield

Representation Summary:

Para 6.8 includes "It therefore offers good accessibility to the city by sustainable modes of travel" whereas para. 12.29 of the adopted Local Plan refers to good "potential" accessibility, which is accurate.
Para. 6.12 includes "The site does not present any major issues of flood risk." This is disputed.
The Plan fails to recognise in its own right and to protect a recorded chalk stream running mostly north-south towards the east of the site which comprises a specialist river habitat under the UK BAP rivers and streams habitat action plan and is also notable under the Water Framework Directive.

Full text:

Para 6.8 includes "It therefore offers good accessibility to the city by sustainable modes of travel" whereas para. 12.29 of the adopted Local Plan refers to good "potential" accessibility, which is accurate.
Para. 6.12 includes "The site does not present any major issues of flood risk." Although also in the adopted Local Plan (para. 12.30) this has always been disputed: its interesting hydrogeology means that springs can turn up in all sorts of places (including hillsides). Further I believe the area identified for sports pitches will require a significant increase in ground level in order to function and the consequent impacts, particularly on ecology, are not clear.
The Plan fails to recognise in its own right and to protect a recorded chalk stream running mostly north-south towards the east of the site which comprises a specialist river habitat under the UK BAP rivers and streams habitat action plan and is also notable under the Water Framework Directive. (It was indirectly referenced as a "water vole habitat" and as part of a
Biodiversity Opportunity Area in Appendix 1, para.s A.19 and A.21 of the previous Draft Local Plan.) I understand from Sussex Wildlife Trust that, even after a recording project in recent years, only 135km of Sussex chalk streams are known and these are both nationally and internationally unique and rare in their ecology . Local knowledge recognises a second chalk stream to the west and the site is criss-crossed with stream tributaries and ditches and subject to ephemeral spring points (a product of its hydrology) that all form part of this chalk stream habitat.