The RSPB is supportive of measures in place to address the increase in nutrient inputs to Chichester and Langstone Harbours Special Protection Area (SPA)/Ramsar and Chichester Harbour SSSI. The RSPB agrees that while nitrogen originating from new development is not the only source, it is critical to ensure that new potential sources of nitrogen inputs do not further increase the nitrogen loads in Chichester Harbour. Securement of a nutrient neutrality scheme should be completed alongside additional catchment management measures and water quality improvement schemes to restore favourable condition in these ecosystems to enable the designated species to thrive in healthy waters.

Although supportive of the overall measures in place to address nutrient neutrality, the RSPB considers Policy NE19 needs to include further information regarding the current state of play for nutrient mitigation schemes in the district. The RSPB considers that strategic mitigation plans should be adopted in each catchment to model the optimum mix of catchment and nature-based solutions (CNBS), engineered and hybrid solutions. Although mitigation plans should be developed and delivered by a catchment operator (likely a water company), these mitigation plans should work closely with Local Authorities and strategic planning for districts in order to address nutrient neutrality holistically across the district and wider catchment areas.

Further, in addition to mitigation plans and information regarding any upcoming nutrient mitigation schemes available in the district, guidance should be included in Policy NE19 to provide more detail to aid development in implementing adequate mitigation measures to address nutrient neutrality when proposed to be fulfilled by their own means.

Without the above additional information regarding nutrient neutrality within the Local Plan document, the RSPB does not consider it possible to conclude that Policy NE19 is ‘sound’ as, in its current form, the policy does not show effective joint working on cross-boundary strategic matters surrounding nutrient neutrality.