Strategic Wildlife Corridors

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Support

Local Plan Review: Preferred Approach 2016-2035

Representation ID: 36

Received: 24/12/2018

Respondent: Karen Fielder

Representation Summary:

Support the concept of wildlife corridors but the wording of the policy is weak and may 'lack teeth' in practice.

Full text:

Support the concept of wildlife corridors but the wording of the policy is weak and may 'lack teeth' in practice.

Support

Local Plan Review: Preferred Approach 2016-2035

Representation ID: 201

Received: 18/01/2019

Respondent: Mrs Trish Mackinnon

Representation Summary:

There is a growing requirement for a Western Manhood Southern Coastal Wildlife corridor in addition to the Western and Northern corridors to the South Downs National Park that are under considration at the moment. It has been suggested that a Wildlife corridor could run from East Head to Medmerry so that areas which are identified to be rich in wildlife and especially animals and birds that are endangered species should not be isolated. These should include green fields, hedgerows, ditches ponds and woodland which offers habitat and natural animal hunting grounds.

Full text:

There is a growing requirement for a Western Manhood Southern Coastal Wildlife corridor in addition to the Western and Northern corridors to the South Downs National Park that are under considration at the moment. It has been suggested that a Wildlife corridor could run from East Head to Medmerry so that areas which are identified to be rich in wildlife and especially animals and birds that are endangered species should not be isolated. These should include green fields, hedgerows, ditches ponds and woodland which offers habitat and natural animal hunting grounds.

Attachments:

Object

Local Plan Review: Preferred Approach 2016-2035

Representation ID: 236

Received: 20/01/2019

Respondent: Mr Andrew Sabin

Representation Summary:

There is a rich and varied number of wildlife in Hunston and the surrounding areas but the proposed development in Hunston would have a serious negative impact on the current wildlife corridors. The canal already acts as a hard North/South border to wildlife movement and the proposed development would only further impede wildlife movement.

Full text:

There is a rich and varied number of wildlife in Hunston and the surrounding areas but the proposed development in Hunston would have a serious negative impact on the current wildlife corridors. The canal already acts as a hard North/South border to wildlife movement and the proposed development would only further impede wildlife movement.

Comment

Local Plan Review: Preferred Approach 2016-2035

Representation ID: 347

Received: 24/01/2019

Respondent: Sussex Bat Group

Representation Summary:

Comments made on Background Paper
- Appendices not available
- Concerns about crossing A27, A259, railway
- Data needs to be kept up to date
- Not all parts of plan area are equally covered by surveys

Full text:

General comments on Strategic Wildlife Corridors background paper

4.5 For more details on the methodology, please refer to appendices 1 - 3.

Section 4.5 refers to appendices 1 - 3, which do not appear to be available within the consultation version of this document.

4.8 The A259, the railway line and the A27 provide a barrier to some species of wildlife; anecdotally this can be seen from the roadkill whereby individual larger mammals, such as foxes, badgers and deer, have been unsuccessful in crossing. Others individuals will be more successful, particularly at night, and birds, insects and some species of bat will be less affected by these barriers. Evidence indicates that water voles and other mammals are crossing the A27 through culverts and under the bridges. In addition, where these barriers are particularly vegetated, they are providing a wildlife corridor, running east to west.

Wildlife corridors are designed to provide useable connectivity, encouraging and enabling wildlife to travel safely between otherwise isolated habitats and areas designated for protection or for endangered and/or protected species. Where significant barriers, such as main roads bisect these corridors, it is essential that adequate mitigation is put in place to enable wildlife to cross them easily and to avoid the creation of a "killing trap." It is unclear how this plan seeks to provide adequate facilities to support wildlife crossing the A27?

3.3 The presence of protected or rare species data observations within corridor areas indicates actual presence and use by the species named. However, not all areas of the Plan area are equally covered by surveys and many species are under-recorded. Similarly, other areas may have had a concentration of recording effort over time, resulting in an apparent cluster of records which, whilst it represents a true density of records, could be replicated in other areas if more surveying were to be undertaken.

5.66 In 2013 Chichester District Council, in partnership with Forest Research UK, undertook the Chichester District Green Infrastructure Mapping Project. This sought to identify and map the components of the local ecological networks in accordance with the NPPF. The results of this mapping work identified features such as hedgerows, treelines and woodland which are used as ecological corridors by species of bats and also ditches and rifes which are used by water voles. The ecological networks, in addition to high concentrations of species records and the location of priority habitats and designated sites, has enabled the Council to identify four strategic wildlife corridors which connect Chichester Harbour with the South Downs National Park (see Maps 5.1 and 5.2). These corridors do not stop at the plan area boundaries.

It is widely understood that the robustness of habitat network modelling, using a least-cost habitat network model, can vary significantly where they rely solely upon generic data. Data such as this is can be varied in age, accuracy, quality, distribution, quantity and other variable constraints. For example, data obtained from a recent review of UK species, for example found that only 28 out of 1245 species of conservation concern had published information on dispersal distances (Catchpole 2007 & 2006)i,ii.

Therefore, current and site-specific baseline survey data, together with a regular sustainable programme of monitoring will be fundamental to establishing the efficacy and sustainability of the proposed wildlife corridors.

5.67 The Council will apply an additional layer of planning restraint to the countryside protection policies within these strategic wildlife corridors to ensure that connectivity between the South Downs National Park and the Chichester Harbour AONB is maintained in the long term. Within the corridors it will be necessary to demonstrate that no land outside the corridor is available for development and the development will not have an adverse impact on the integrity of the corridor.
The converse effect of the introduction of wildlife corridors will see increasing pressure for development and the degradation of existing habitats adjacent to the proposed corridors. It is important to understand the effect that this will have upon wildlife corridors in the future. Where they exist, both edge and smaller island habitats are inextricably important areas to the future viability of the wildlife corridors. This is especially so, where corridors are linear and narrow or pass close to urban areas. The need for buffer strips to reduce the "edge effect" impact and planning constraints to control the management of adjacent land will be essential to avoid the impacts of habitat loss, increased disturbance through recreation, pollution, noise, artificial light-spill, invasion by non-native species and increased predation due to the concentration effect or from increases in rats, squirrels, cats and other predatory species.

Proposals should include plans for physical protection (where necessary), maintenance, restoration, the reintroduction of native populations (where appropriate) and enhancements, such as additional habitat creation.

Corridor specific comments on Strategic Wildlife Corridors background paper
Proposed Hermitage to Westbourne Strategic Wildlife Corridor
Concerns: Lack of crossing facility for A27, A259 and railway line.
Proposed Chidham/East of Nutbourne Strategic Wildlife Corridor

5.5 Alternatives considered: It is difficult to identify an alternative route which will maintain the connections between the various components of the local ecological network. The loss of the treelines, hedgerow and scattered trees connecting to the ancient woodland and LWS, could result in the degradation of their condition. East of the corridor are few ecological features, excluding the watercourse. [The corridor should extend eastward to include four areas of barn owl habitat and the chalk stream adjacent to Newells Lane. Extending south to cutmill Creek]. West of Nutbourne there are a number of ecological features but the close proximity of residential areas and proposed development, mean that the corridor may be too narrow to act as a suitable functional strategic corridor.

Concerns: Lack of crossing facility for A27, A259 and railway line.

Proposed Broadbridge to East Ashling Strategic Wildlife Corridor

5.6 The Chichester Harbour SPA connects to an area of wooded bat habitat, between the A259 and railway line, via watercourses and scattered trees. The proposed corridor follows the watercourses and water vole habitat between the railway line and A27, connecting to an area of woodland (bat habitat) north of the A27 and west of Ratham Lane. North of the A27, the network is extensive and the corridor could travel east or west but goes east to provide the shortest and most direct line to the SDNP boundary at Southbrook Road [Extend west along the south side of Southbrook road to link with the Hermitage to Westbourne Strategic Wildlife Corridor].

Concerns: Lack of crossing facility for A27, A259 and railway line.

Proposed West of Chichester to Fishbourne Strategic Wildlife Corridor

Concerns: Lack of crossing facility for A27, A259 and railway line.
Proposed Westhampnett to Pagham Harbour Strategic Wildlife Corridor
The corridor should avoid passing the glasshouses at Lagness, which emit considerable light pollution. This will act as a barrier to many species of bat and other nocturnally active creatures. The corridor is also dangerously narrow at this point.

Concerns: Lack of crossing facility for A27, A259 and railway line.

Proposed Aldingbourne and Elbridge Rifes Strategic Wildlife Corridor

The corridor should avoid passing the glasshouses at East Hampnett, which emit considerable light pollution. This will act as a barrier to many species of bat and other nocturnally active creatures.

Concerns: Lack of crossing facility for A27, A259 and railway line.

Both Westhampnett to Pagham Harbour and the Aldingbourne and Elbridge Rifes are far too narrow!

Object

Local Plan Review: Preferred Approach 2016-2035

Representation ID: 579

Received: 05/02/2019

Respondent: Mr Pieter Montyn

Representation Summary:

-Largely arbitrary lines on maps not likely to serve the intention of corridors.
-need to evaluate need and locations of corridors

Full text:

Wildlife corridors S 30
-Nature professionals view long narrow corridors flanked by urbanisation and busy roads as only paying lip service, being harmful rather than beneficial. Wide corridors are preferable.Nature is not served by corridors drawn on maps following roads and railway lines
-The proposed corridor W of Chichester from Fishbourne along the S bend in the A27 to Hunters Race and Lavant, as well as that arbitrarily shown W of Oving and Tangmere along a stretch of the A27 and motor circuit/aerodrome buildings and New Road/Claypit Lane crossing are cases in point
-There could also be E to W corridors

Support

Local Plan Review: Preferred Approach 2016-2035

Representation ID: 865

Received: 02/02/2019

Respondent: Councillor Simon Oakley

Representation Summary:

Para 5.66, penultimate sentence. Replace "(see Maps 5.1 and 5.2)." with "and another connecting the SDNP with Pagham Harbour (see Policies Maps S30a and S30b).".

Para 5.67. After "AONB" insert "and Pagham Harbour SPA".

See also my comments on Policies Map S30b (Representation 861) which seek to enhance the East of City corridor.

Full text:

Para 5.66, penultimate sentence. Replace "(see Maps 5.1 and 5.2)." with "and another connecting the SDNP with Pagham Harbour (see Policies Maps S30a and S30b).".

Para 5.67. After "AONB" insert "and Pagham Harbour SPA".

See also my comments on Policies Map S30b (Representation 861) which seek to enhance the East of City corridor.

Support

Local Plan Review: Preferred Approach 2016-2035

Representation ID: 992

Received: 04/02/2019

Respondent: MS Sarah Cunliffe

Representation Summary:

The provision of robust Wildlife Corridors is critical so species can travel between habitats and maintain genetic diversity. Our wildlife cannot survive in isolation. As in-fill and urbanisation reaches a critical level in the Chichester area, I urge the planners to ensure the proposed Wildlife Corridors are given the due protection, and importance they deserve.

Full text:

I write to support the VITAL importance of Strategic Wildlife Corridors in the Strategic Plan.

I am a biologist and film-maker based in Chichester. We have made many films on the importance of wildlife, both globally and locally, including films on National Parks such as the South Downs NPA.
The amount of in-fill, and urbanisation going on in the Chichester area has reached a critical point. At no other time in our local history, have our wildlife and wild places been under such threat.

Natural areas protect homes from flooding, insects pollinate crops, healthy ecosystems purify water, wildlife is a massive asset for tourism and spending time outside in vibrant natural areas supports and protects public health.

The Chichester area's wildlife is massively under threat . It comes at a time when one in 10 of the UK's wildlife species are threatened with extinction and the numbers of the nation's most endangered creatures have plummeted by two-thirds since 1970. The abundance of all wildlife has also fallen, with one in six animals, birds, fish and plants having been lost. [Source - State of Nature Report produced by the UK's leading wildlife authorities.]

Together with historical deforestation and industrialisation, these trends have left the UK among the most nature-depleted countries in the world. I believe the Chichester area has reached the threshold where urgent measures are needed to plan and protect for our wildlife, and to provide living landscapes for the generations to come. The maintenance and provision of wildlife corridors is an absolutely critical part of this future-proofing.

Chichester District is home to a wide variety of wildlife and habitats. To give but one example, I live in Chidham where we have internationally protected species such a water voles and greater crested newts and many species of rare bat. Species like this cannot survive in isolation. They do not recognise boundaries. To maintain healthy and vibrant wildlife, we need robust corridors so species can utilise them to travel between their habitats. We need healthy and protected corridors so genetic diversity can be maintained. And we need these pockets of wildlife to link to the National Park.

I urge the planners to ensure the proposed Wildlife Corridors are given the due protection, and importance they deserve. And to also to be far more aggressive with developers in ensuring our existing wild areas continue to be protected. We need living landscape's around us, not concrete jungles.

Object

Local Plan Review: Preferred Approach 2016-2035

Representation ID: 1263

Received: 06/02/2019

Respondent: North Mundham Parish Council

Representation Summary:

5.66 The wildlife corridor identified on Map 5.2 does not recognise Pagham Rife which is a key wildlife area of flood plain and reed beds penetrating northwards into North Mundham Parish. Ignoring this major migratory zone poses a threat to the integrity of the Pagham SPA.

Full text:

5.66 The wildlife corridor identified on Map 5.2 does not recognise Pagham Rife which is a key wildlife area of flood plain and reed beds penetrating northwards into North Mundham Parish. Ignoring this major migratory zone poses a threat to the integrity of the Pagham SPA.

Object

Local Plan Review: Preferred Approach 2016-2035

Representation ID: 1361

Received: 06/02/2019

Respondent: Mr David Leah

Representation Summary:

Support the principle but once they have been established they should be held.

Any developer can circumvent this policy.

Full text:

Halnaker resident.
Support he principle but once they have been established they should be held.

Any developer can circumvent this policy.

Support

Local Plan Review: Preferred Approach 2016-2035

Representation ID: 1422

Received: 07/02/2019

Respondent: Mr Len Gough

Representation Summary:

I believe that a wildlife corridor must be maintained in order to prevent some species south of the A27 from being denied access to their natural habitat.

Full text:

I believe that a wildlife corridor must be maintained in order to prevent some species south of the A27 from being denied access to their natural habitat.

Comment

Local Plan Review: Preferred Approach 2016-2035

Representation ID: 1788

Received: 07/02/2019

Respondent: Harbour Villages Lib Dems Campaign Team

Representation Summary:

5.64
We support strategic wildlife corridors. However the one in Fishbourne has already been desecrated by Whitehouse Farm and development on Clay Lane. We propose a new one running from Chichester Harbour through Beth wins Farm to the South Downs. This will require planting and developing.

Full text:

5.64
We support strategic wildlife corridors. However the one in Fishbourne has already been desecrated by Whitehouse Farm and development on Clay Lane. We propose a new one running from Chichester Harbour through Beth wins Farm to the South Downs. This will require planting and developing.

Object

Local Plan Review: Preferred Approach 2016-2035

Representation ID: 1823

Received: 07/02/2019

Respondent: Mr Bruce Brechin

Representation Summary:

I do not believe the wildlife corridors for west of Chichester as shown on map S30a is complete

Full text:

I do not believe the wildlife corridors for west of Chichester as shown on map S30a is complete

Comment

Local Plan Review: Preferred Approach 2016-2035

Representation ID: 2435

Received: 07/02/2019

Respondent: South Downs National Park Authority

Representation Summary:

Part of the CDC Plan area within key impact zones of draft Sussex Bat Special Area of Conservation Planning and Landscape Scale Enhancement Protocol - SDNPA would welcome opportunity to discuss work with CDC and Natural England.

Full text:

The SDNPA and all relevant authorities are required to have regard to the purposes of the South Downs National Park (SDNP) as set out in Section 62 of the Evironment Act 1995. The purposes are 'to conserve and enhance the natural beauty, wildlife and cultural heritage of the area' and 'to promote opportunities for the understanding and enjoyment of the special qualities of the national park by the public.' The Authority would appreciate reference to Section 62 being added to
paragraph 1.31 of the draft Plan.

Duty to Cooperate

As set out in our previous response, the SDNPA has a set of six strategic cross-boundary priorities.
I would like to take the opportunity to again highlight these which provide a framework for ongoing Duty to Cooperate discussions:
* Conserving and enhancing the natural beauty of the area.
* Conserving and enhancing the region's biodiversity (including green infrastructure issues).
* The delivery of new homes, including affordable homes and pitches for Gypsies, Travellers and Travelling Showpeople.
* The promotion of sustainable tourism.
* Development of the local economy.
* Improving the efficiency of transport networks by enhancing the proportion of travel by sustainable modes and promoting policies which reduce the need to travel.

Conserving and enhancing the natural beauty

We welcome the requirement in policies S26 (Natural Environment) and DM28 (Natural Environment) to ensure that development proposals have no adverse impact on the openness of views and setting of the SDNP. It is noted that a substantial amount of new homes are proposed on the A259 corridor between Emsworth and Chichester. This is a sensitive stretch of land in the coastal
plain between the coast, the south coast railway and the A27. This corridor provides the connection, including intervisibility, between the protected landscapes of the South Downs National Park and Chichester Harbour AONB, for example views of the channels within the Harbour from the Trundle and Stoke Clump.
We note the intention of identifying settlement gaps and look forward to seeing the evidence base and the proposed gaps in the Regulation 19 iteration of Chichester Local Plan Review 2035, particularly as to how they will contribute to safeguarding the relationship between the SDNP and Chichester Harbour AONB. We would welcome the opportunity to work with CDC on this matter.

Locations identified for development

Development in the CDC Local Plan Review 2035, particularly along the A259 (policies AL7 Highgrove Farm Bosham, AL9 Fishbourne Parish, AL10 Chidham and Hambrook Parish, AL13 Southbourne Parish) corridor, have the potential to deliver a significant cumulative adverse impact on the setting of the National Park and its important relationship with the Chichester Harbour AONB.
We consider that the policy wording for the A259 corridor Strategic Site Allocations could be more robust and proactive with regard to conserving and enhancing the National Park. In particular, it could provide more active direction to applicants in order to ensure adverse impacts are minimised locally, and in relation to the National Park. For example, with regard to green infrastructure, each of the
A259 Strategic Site Allocation policies (AL7, AL9, AL10 and AL13) include a criteria requiring the provision of green infrastructure, and we would suggest this could be re-worded as follows: 'Identify opportunities are taken for and secure the expansion and provision of multifunctional green infrastructure into the wider countryside and protected landscapes of the South Downs National Park, and Chichester Harbour AONB, including between settlements and facilities.'

Reference to considering and minimising impact on the SDNP in each of the A259 Strategic Site Allocation policies (AL7, AL9, AL10 and AL13) is welcomed, for example criterion 5 of policy AL9:
Fishbourne Parish. However, this could be usefully re-worded to ensure that developers do not create a scheme and only consider the impact afterwards. Wording to direct people to 'respect and respond to the National Park landscape, its setting and purposes prior to development design' avoids the risk of relying upon ill-informed and inappropriate mitigation measures This matter could also be usefully
addressed in relevant Strategic and Development Management policies elsewhere in the Local Plan concerning design, landscape, and the South Downs National Park. We would be happy to work with CDC on this matter.

We note Strategic Policy S32, which requires proposals for housing allocations and major development sites to be accompanied by a site-wide design strategy. We would strongly encourage masterplans and development briefs for each allocation (or settlement where the sites are to be allocated through a Neighbourhood Plan) to come ahead of applications and demonstrate positive design interventions which respond directly to landscape/SDNP sensitivities. We would be happy to be involved in shaping these as consultees in order to achieve the best quality scheme. These interventions could be written in to the policy wording.

There is an opportunity for allocation policies to seek to deliver the joining up of existing, and/or improvements to, the network of RoW (Equestrians, Cyclists and Pedestrians) to enable and encourage access into the National Park in accordance with the National Park's Second Purpose.
Further comments on specific allocations:
* Policy AL1 (Land West of Chichester) - We welcome the consideration of the Centurion Way in criteria 10. However, we would ask for stronger policy wording to explicitly state that development must not adversely affect, and preferably enhance usability of, Centurion Way connecting Chichester with the SDNP.
* We note that Policy AL4 (Land at Westhampnett/NE Chichester) still refers to Lavant Valley greenspace but we query if this is likely to be secured now based on planning applications submitted. We would suggest that criteria 12, last sentence, could also refer to securing offsite improvements/upgrades for cycleway links
* Policy AL6 (Land South-West of Chichester (Apuldram and Donnington Parishes)) should address the important opportunity to secure a safe off-road connection between the Centurion Way and Salterns Way as the two flagship and largely safe off-road multi-user trails linking Chichester with (respectively) SDNP and Chichester Harbour AONB. We would welcome the opportunity for further dialogue and joint working on this matter with CDC.
* We welcome criterion 5 of policy AL14 (Land West of Tangmere). It is a sensitive site due to the impact on clear views of the site from important locations in the SDNP such as the Trundle and Halnaker Hill. We therefore ask that criterion 5 is expanded to emphasise and address the sensitivity of the site
Specific wording comments on other policies/paragraphs:

We have the following comments on the following specific paragraphs:
* Para 2.29 (challenges and opportunities facing the Plan Area): We suggest that the 7th bullet point should say 'Protect and enhance the character of the area including the Chichester Harbour AONB and the setting of the SDNP'.
* Policy S20 (Design): As mentioned above regarding the A259 Strategic Site Allocation policies, we consider that the wording of this policy could be more proactive by including wording to direct people to 'respect and respond to the National Park landscape, its setting and purposes prior to development design'.
* Policy S25 (The Coast): Paragraph 5.44: We suggest adding 'serves to provide important scenic views from the water across to the SDNP which should be conserved'.
* Policy S26 (Natural Environment): We suggest deleting reference to 'openness' and to include reference to views from and to the National Park.
* Policy S32 (Design Strategies for Strategic and Major Development Sites): We suggest that the policy requires such design strategies to be informed by landscape character and the sites landscape context. We also suggest that criteria h. includes a requirement to state maximum building heights.
* Policy DM17 (Stand-alone Renewable Energy): The policy requirement for demonstrating no significant adverse impact upon landscape or townscape character is welcomed. We request reference is also made specifically of views of the SDNP.
* Policy DM19 (Chichester Harbour AONB): We request criterion three also identifies the relationship by way of intervisibility between the AONB and SDNP.
* Policy DM22 (Development in the Countryside): Further to comments on the A259 Strategic Site Allocation policies and S20 (Design), we consider that the wording of this policy could be more proactive by including wording to direct people to 'respect and respond to the National Park landscape, its setting and purposes prior to development design'.
* Policy DM23 (Lighting): The reference to the South Downs International Dark Skies Reserve is welcomed. However, proposals that aren't immediately adjacent to the Reserve may have significant adverse impact, for example due to the site's particular visibility within the landscape or sky glow; we suggest that wording is amended to reflect this.
* Policy DM32 (Green Infrastructure): We suggest that this policy could benefit from specifically citing that green infrastructure should be 'multifunctional'. We also recommend reference to opportunities to make better green infrastructure connections in line with Lawton Principles of 'bigger, better, more joined up', to ensure these spaces can function and therefore deliver benefits.

Conserving and enhancing the region's biodiversity (including green infrastructure).

The SDNPA welcomes the approach taken by CDC to identify green infrastructure and habitats networks as cross boundary issues in paragraph 1.26 of the Plan. The SDNPA looks forward to continuing to work with CDC on green infrastructure matters particularly as your Plan is progressed to pre-submission.

We note that an open space study has been prepared and this could be linked up with other work into a wider green infrastructure approach incorporating the identified strategic wildlife corridors, areas for natural flood management, PROW and connections between the settlements, protected landscapes and the stations, landscape views/settlement gaps and some land management guidelines
for these really important areas. This would be particularly useful to inform development proposals in the A259 corridor.

Policy SD30 - Strategic wildlife corridors

The SDNPA very much welcomes and supports the inclusion into policy of wildlife corridors which traverse the district connecting the two protected landscapes of the Chichester Harbour AONB and the SDNPA.

It is important to note that there is no corresponding policy within South Downs Local Plan, currently at examination, to continue protection of the wildlife corridors within the SDNP. We have concerns that it is unlikely to be sufficient for the corridors just to reach the SDNP boundary. We also note that several of the corridors appear to be quite narrow, especially to the east of the City, and we query whether they are substantial enough to perform the intended function.

We note the detailed evidence outlined in the background paper and the SDNPA would like to work with CDC on the continued development of the strategic wildlife corridors, in particular with regard to their connection points with the National Park and how we can work together on robustly delivering this strategic cross boundary objective.

Ebernoe Common, The Mens, and Singleton & Cocking Special Areas of Conservation

The SDNPA has been working together on technical advice to facilitate sustainable development within proximity Ebernoe Common, The Mens, and Singleton & Cocking Special Areas of Conservation, which are designated for their populations of Bechstein and barbastelle bats. The draft Sussex Bat Special Area of Conservation Planning and Landscape Scale Enhancement Protocol was published in 2018 in the Core Document Library as part of the South Downs Local Plan Examination. The Protocol is based on published data which identifies key impact zones, one of 6.5km and one of 12km, around each of the three SACs. It also sets out avoidance, mitigation, compensation and enhancement measures to inform and be addressed by development proposals. Parts of the Chichester District Local Plan area are within these key impact zones. These zones have been incorporated into policy SD10 of the South Downs Local Plan and the policy has not been modified by the Inspector as a result of the examination in public. The SDNPA would welcome the opportunity for further discuss with CDC and Natural England on this work.
Solent Recreation Mitigation Partnership

Both CDC and the SDNPA are members of the Solent Recreation Mitigation Partnership (SRMP) (also known as Bird Aware Solent) which has provided a strategic mitigation solution to address potential harm to the protected habitat at Chichester Harbour and ensuring compliance with the Habitats Regulations. We note that the SRMP mitigation solution is reflected in Policy DM30 and we look forward to continuing to work with CDC and other members of the SRMP on this matter.
With regard to paragraph 7.185 we suggest reference to the Medmerry Realignment be a new bullet point: 'Medmerry realignment, which is intertidal habitat created in 2013 to compensate for historic losses across the Solent to SSSI and Natura 2000 sites'.
We also suggest the following wording amendment to paragraph 7.187: '...This is particularly relevant to Chichester and Langstone Harbour and Pagham Harbour and the impact of recreational pressure on the birds that use these Special Protection Areas. Any negative impacts that the development may have should will be weighed against the benefits of the proposal. This may include looking at whether the assets are surplus to requirements, if the proposal impacts on a small area or corridor or if a wider need exists for the development and there is no alternative location....'

The delivery of new homes, including affordable homes and pitches for Gypsies,
Travellers and Travelling Showpeople

Policy S4: Meeting Housing Needs
The SDNPA welcomes the uplift to the housing target to address unmet need arising in that part of the SDNP within Chichester District (estimated at 44 dpa at the time the last Statement of Common Ground was agreed in April 2018). The provision of 41 dpa broadly meets this need.
We note that the Objectively Assessed Need is calculated only for the area outside the SDNP using the 'capping' method set out in the Government's standard methodology (the currently adopted target of 435 dwellings per annum plus 40% = 609) - this is helpful as it makes a clear distinction between the assessed need for Chichester District Local Plan area and that for the SDNPA, notwithstanding
the Duty to Cooperate.

Policy S5: Parish Housing Requirements 2016-35
We support identification of parish specific housing requirements providing certainty to local communities. This is the same approach as we have taken in the South Downs Local Plan.

Affordable housing
We note that there is a need for 285 affordable homes per annum (source: HEDNA) which underlines the need for a strong policy which seeks to maximise affordable housing delivery. This high level of need is common to the wider sub-region and is an issue relevant to the wider housing market area.
The SDNPA supports CDC's approach of taking opportunities arising from new residential development to contribute to the supply of affordable housing, to meet local needs in terms of type and tenure (paragraph 4.35). In this respect, it is important that the whole plan viability testing currently being undertaken should fully reflect Planning Practice Guidance on viability, such that as high as possible a percentage of affordable housing is sought. We also support the positive approach to Community Land Trusts (CLTs) as a mechanism for delivering affordable housing (paragraph 4.45). Chichester District Council may also wish to note that SDNPA has, subject to main modifications consultation, received the go-ahead from its Local Plan Inspector for unmodified inclusion of Strategic Policy SD28: Affordable Housing in the South Downs Local Plan. This includes a lower threshold than that advised in Government policy, and also seeks on-site affordable housing from small sites below the 11 threshold stipulated in Government policy.

Policy S7: Meeting Gypsies, Travellers, Travelling Showpeoples' Needs
The SDNPA supports the principle of the policy and whilst noting the significant need arising. It is not clear whether the intention is to allocate sites to meet the need in a separate DPD. Paragraph 4.49
refers to 'the forthcoming DPD' and policy S7 to sites being allocated in a Site Allocation DPD 'where there is a shortfall in provision'. Has this work already been triggered by the scale of need? The policy and associated text could be clearer on this matter.
We would like to highlight that there is limited capacity within the National Park to allocate sites for Gypsies and Travellers through DtC, given significant landscape constraints. We suggest that the coastal authorities and SDNPA continue to work closely with regards addressing the need.

Improving the efficiency of transport networks by enhancing the proportion of travel by sustainable modes and promoting policies which reduce the need to travel
The SDNPA supports in principle Policy S23 (Transport and Accessibility). In particular, we support emphasis on encouragement of use of sustainable modes. We suggest explicit support in the text for improving links into the National Park, particularly by sustainable and active transport modes.
Allocation policies should also should seek to deliver the joining up of existing, and/or improvements to, the network of Public Rights of Way.

SDNPA notes reference in the policy to a coordinated package of improvements to the A27 Chichester Bypass, as well as to a new road from the Fishbourne roundabout. The SDNPA would urge that any such schemes be fully assessed, including streetlighting, for potential adverse impacts on landscape where there is a relationship with the National Park and its setting. Any such impact will
need to be mitigated, and opportunities taken to enhance green infrastructure networks and public rights of way networks. CDC may wish to consider whether the Policy S23 should include additional wording to reflect these principles.

Centurion Way
The SDNPA supports the reference to Centurion Way in paragraph 7.185 in relation to Green Infrastructure & resistance to dissection of green movement corridors. There are opportunities to improve these links, for example, suggest explicit reference to protecting and enhancing the Centurion Way. The reference to Salterns Way is also supported. Centurion Way and Salterns Way are two flagship off-road routes for the SDNP and AONB respectively and do not currently benefit
from safe off-road connection. The SDNPA would strongly support policy to secure this connection and would welcome opportunities to discuss this further and work jointly with CDC on this strategic issue.

With regard to Strategic Policy S14 (Chichester City Transport Strategy) we request that the SDNP is included in the penultimate bullet point as a destination for strategic cycle routes.

Transport evidence
We would highlight that the transport assessment carried out to inform the South Downs Local Plan.
This indicated a potential severe impact on the Petersfield Road / Bepton Road / Rumbolds Hill junction in Midhurst of additional development in the town, in the context of junctions already becoming overcapacity due to background traffic growth, for example, . arising from strategic development in neighbouring planning authorities.
A review of the CDC Transport Study of Strategic Development indicates significant traffic growth arising from Scenario 1 (the preferred strategy). It is not clear from the study how this will impact on the A286 towards Midhurst, which in turn could have a critical impact on junction capacity at Midhurst.
SDNPA may seek further assurance that such potential impacts have been looked at, and appropriate mitigation sought.
Other comments
Page 16 - Local Plan area map: Request clarification whether the Local Plan area includes the following two properties, as not clear from the Local Plan Area map: Stedlands Farm, and The Stable/Little Stedlands, Haslemere GU273DJ
We would like to wish you well in the progression of your Local Plan and would welcome further discussion and joint working on the strategic cross boundary matters raised.

Attachments:

Comment

Local Plan Review: Preferred Approach 2016-2035

Representation ID: 2950

Received: 07/02/2019

Respondent: MR William Sharp

Representation Summary:

The whole section on Strategic Wildlife Corridors is missing acknowledgement that some of these corridors could be substantially improved.

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Support

Local Plan Review: Preferred Approach 2016-2035

Representation ID: 3175

Received: 04/02/2019

Respondent: Mrs Sarah Sharp

Representation Summary:

These corridors link the AONB with SDNPA. It they were not maintained wildlife would have no ability to travel between areas which would limit the gene pool and species would become weaker and die out.

Full text:

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