Object
Chichester Local Plan 2021 - 2039: Proposed Submission
Representation ID: 5834
Received: 17/03/2023
Respondent: Kirdford Parish Council
Agent: Troy Planning + Design
Legally compliant? No
Sound? No
Duty to co-operate? No
Question why d) specifies ‘greenfield’ sites. Is there an assumption that previously developed land cannot support commuting and foraging habitats? Policy makes no mention of Atmospheric Pollution despite this being highlighted in the HRA as having an impact on the Ebernoe SAC resulting from nitrogen deposition (arising from the A283) above the critical load for beech forest. Should be addressed in this policy and be specified as a requirement that needs to be assessed. If CDC is signed up to Protocol mentioned and it is not in ‘draft’ form, development proposals should be required to adhere to Protocol rather than just have ‘regard’ to it.
Wording of the Policy appears weakly drafted where it states that “due regard to the possibility that barbastelle and Bechstein’s bats will be utilising the site”. This wording should be strengthened. Policy requires ‘necessary surveys’ but it should be clear about what surveys are required. Policy should be clear about scale and form of buffers rather than leaving it completely open. Policy should require that proposals undertake bat surveys as early as possible and that surveys should provide evidence over sufficient time.
See attachment.