We would also strongly advise that the policy requirements are amended / expanded as follows (a
number of these points were made previously in our non-statutory response dated 7th February 2022):

Policy Requirement 2 to include the following additional wording “The development provides recreational opportunities (requiring a coastal location), that do not adversely affect…”

Policy Requirement 6 to include the following additional wording “Where relevant, the development would result in improvements to or redistribution of moorings, marine berths or launch on demand facilities (dry berths) in the harbours whilst also ensuring that any small-scale loss of mudflat within the designated sites is compensated for. Small-scale but cumulative losses of mudflat habitat within the harbours is an issue and beyond this policy
wording we would appreciate the opportunity to work with your authority to find a strategic way to address it.

Inclusion of an additional requirement “Wherever possible the development secures opportunities for the enhancement/creation/restoration of coastal/wetland habitats (guided by any local nature recovery strategy) and contributes to Biodiversity Net Gain.

Inclusion of an additional requirement “Undeveloped areas on low lying land around Chichester Harbour are prioritised for opportunities that actively restore coastal habitats or works with natural processes to address climate impacts and loss of biodiversity”

Inclusion of an additional requirement “The development can demonstrate consideration of
and adaptation to future climate scenarios and their potential impacts, including (but not limited to) shading, surface water flooding, wind- blown sand, wave-driven shingle.

Policy paragraph to be expanded as follows “Replacement buildings will be permitted unless there is evidence that the existing or demolished property has been damaged as a result of the effect of wind and waves. Replacement buildings should be set further back in line with NCERM erosion prediction and coastal flooding and should not hinder coastal processes with regard to designated sites if applicable.

Policy Requirement b. (in relation to boatyard and marina sites) to include the following additional wording “Harm nature conservation (particularly in relation to loss of mudflat), landscape or heritage interests;

Summary of advice
While we have raised some queries and recommended some further modifications to certain policies we do not find the Plan unsound on any grounds relating to our remit.
Natural England has reviewed the Proposed Submission Local Plan and accompanying appendices together with the Habitats Regulations Assessment (HRA) and Sustainability Appraisal (SA). Our detailed comments on the policies and site allocations are provided as follows:
• Annex 1 - Chapter 2 – Vision and Strategic Objectives
• Annex 2 - Chapter 4 – Climate Change and the Natural Environment
• Annex 3 - Chapter 5 (Housing) and Chapter 6 – (Place-making, Health and Well-being)
• Annex 4 - Chapter 7 (Employment and Economy) and Chapter 8 (Transport and
Accessibility)
• Annex 5 - Chaper 10 – Strategic and Area Based Policies
Please note that we have not provided comments on all policies but those which have most influence on environmental issues. Natural England has no comment to make on the policies not covered in this response. Other than confirming that we have referred to it when considering our advice on specific policies and site allocations Natural England has no general comments to make on the SA.
Unfortunately due to unforeseen resourcing issues while we have reviewed the associated HRA we are not in a position to provide detailed comment on it as part of this response. We will rectify this as soon as possible and can confirm that we have seen nothing in it that raises any major concerns.
The Plan has many positive aspects including standalone policies on Green Infrastructure (GI) and
wildlife corridors and an incredibly extensive suite of natural environment policies more generally.
We are hugely appreciative of the opportunity that we were given to work with you on shaping key policies post-Regulation 18. However, we believe that the plan needs to go further in it’s recognition of coastal squeeze as a key issue for the district, should include policy hooks for the forthcoming Local Nature Recovery Strategy (LNRS) and make up to date references to both the Environment Act (2021) and the Environmental Improvement Plan (EIP, 2023). Given how recent the publication of the EIP is we would be happy to discuss with your authority how this could best be achieved but
we believe given the wealth of natural capital within Chichester District it is vitally important that this latest iteration of the Local Plan is set in its full policy and legislative context.
We have suggested a significant number of amendments and additions to both policies and
supporting text throughout the Plan. In our view these could all be taken forward as minor modifications but if they were all acted upon they would leave the Plan much stronger and more coherent in delivering for the natural environment, one of the three central tenets of genuinely
sustainable development as set out in the National Planning Policy Framework (NPPF 2021,
paragraph 8c).

See attachment for representations on paragraphs/policies.