Support
Chichester Local Plan 2021 - 2039: Proposed Submission
Representation ID: 5867
Received: 17/03/2023
Respondent: Natural England
Natural England has reviewed all proposed housing and employment site allocations using our inhouse mapping system and greatly appreciate your authority sharing the shapefiles with us to make this possible. We do not object to any of the site allocations.
We note that where relevant policies include requirements relating to the natural environment (including protected sites), wildlife corridors, Biodiversity Net Gain, GI, SuDs, waste water/nutrient neutrality and protected landscape considerations and fully support this approach.
We appreciate that in a number of cases our advice
on specific site allocations at the statutory Regulation 18 stage has been incorporated into these requirements.
We further note that a number of the policies A2 (Chichester City), A12 (Chidham and Hambrook), A13 (Southbourne) and A15 (Loxwood) simply allocate broad locations for development at this stage with further detail on specific sites to come via either a Neighbourhood
Plan or an updated Site Allocations document. This makes it difficult to provide detailed advice on potential impacts at this stage but the policy requirements provided thus far appear reasonable.
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.