Object

Sustainability Appraisal - Local Plan Preferred Approach

Representation ID: 2096

Received: 06/02/2019

Respondent: Mr John Auric

Representation Summary:

Object on grounds that SA is questionable on whether option has positive or negative impacts on ie; biodiversity; disadvantages not mentioned in relation to potential increase in population from allocation of 1250 dwellings in Southbourne; lack of information on railway infrastructure for Southbourne dealing with potential increase in passengers from new developments.

Full text:

4.4.2 and Table 3 4.6.4 , 4.7.3 Sustainability Appraisal 010

This Sustainability Appraisal is full of highly subjective notions which leads its impact assessments to be generally questionable ie on whether an option has a positive or negative impact on eg biodiversity.
In para 4.4.2 who were the "further discussions" with to cause scenario 1a to be added ?
Para 4.6.4. in trying to justify the allocation of 1250 dwellings to Southbourne, it talks of the "potential advantages" but does not mention the obvious disadvantages in almost doubling the population of this village. What provisions will the plan make eg to ensure that the Southbourne railway station is capable of handling possibly a doubling of passenger traffic.? The answer is that it can't because investment in the railway network is outside it's jurisdiction. I would only support an option that shares any new housing more evenly between settlements which is more likely to limit the obvious damage that is going to be caused to natural habitats by this Local Plan review.

What improvements or changes would you suggest?

As above.

003 Housing and Econ Devt

This document appears to rely for it's conclusion of new housing numbers on the unbridled continuation of economic growth levels through the Plan period to 2035[par a 1.17].I believe that this is an unsustainable model on which to plan the future for our children and grandchildren.
There is no attempt that I can see to apply some sort of sensitivity analysis to the single end figure of 609 dwellings per annum so that lower numbers could be chosen as a preferred option. There are many factors which could influence housing numbers over the long Plan period so it would seem sensible to start with lower numbers to try and reduce the inevitable negative impact on natural habitats that any increase in human numbers will cause.

What improvements or changes would you suggest? As stated above

5.5 in particular Strategic Wildlife Corridors Background Paper

Whilst supporting the concept of Wildlife Corridors in the Plan [why was this not done 20 years ago ?] I do object to the removal from the Plan Review of the Chidham/East of Nutbourne Wildlife Corridor. If the Southbourne Neighbourhood Plan Review [SNPR] wishes to give more priority to natural habitats then it can devise policies which avoid "the close proximity of...proposed development" cited in paragraph 5.5.
Glossary - Wildlife Corridors are not defined in the Glossary and should be included.

What improvements or changes would you suggest? As stated above.

All but especially sub-areas 82 and 83 Landscape Capacity Study - 007

Apart from it being a useful inventory of landscape types in Chichester District, this document appears to me a rather pointless exercise in Planning fudge. For example on page 496 in is saying that development could be accommodated etc etc at the same time as avoiding any "landscape or visual harm " This sort of language is found all over this document and givers too many opportunities for misunderstanding or misinterpretation.
It would have been helpful to have page numbers for the sub-areas. As it is the location of sections is prolonged.

What improvements or changes would you suggest?

Avoid attempts to give facile conclusions and recommendations.

Paras 5 and 7 various Natural Environment

Para 5.51 [Strategic Policies] suggests the Council will only object to development that causes "significant harm" to the function of the natural environment but there is no definition of this phrase
7.168 Is stating that "providing open space, sport and recreation is part of "protecting and enhancing the natural environment" This is not true as these are all man-made features designed for humans, not for nature.
Para 7.189 and others mention "priority habitats" but I can see nowhere in the Plan Review that identifies the 21 types of these habitats mapped in Sussex* either by list or on a map of the District.These important habitats are often overlooked when development applications are made [eg ref 16/03569/OUT] and this Plan is a good opportunity to draw the public's attention to those in their area.
Para 7.189 refers to a Map 5.1 but gives no easy reference to where this can be found ?
Note: *Sussex Biodiversity Record Centre records these as "Habitats of Principal Importance" - which designation is correct ?
Glossary issues: Priority Habitats are missing and should be included in the Glossary in the Plan Review.