10.1

Site proposed for additional allocation - see attachment.

1 Introduction
1.1 This representation provides a response to the Regulation 19: Local Plan Consultation on
behalf of our client Spiby Partners. The submission covers the general principles of the
Local Plan but has a focus on Land east of Foxbridge Drive and south of the B2145,
Hunston. The land is shown on the attached plan HA Appendix 1: Site Location Plan, and
hereafter referred to as ‘the site’.
1.2 This representation will provide a written responses in relation to the Regulation 19 Local
Plan Consultation which directly relate to the promotion of our client’s land for future
development.
2 Comments on Specific Questions/Tests
2.1 In response to the national planning legislation, this Regulation 19 Local Plan
Consultation invites comments on three specific questions, and is the final consultation
phase, before the Regulation 19 version of the Local Plan is submitted for Examination.
2.2 This representation will respond on these specific questions, and then highlight how our
client’s site could help fulfil the full housing requirement for the District. This could be
through an allocation within the Local Plan or at least through the allocation of numbers
to the Parish, who in turn would select sites through a Neighbourhood Plan allocation.
Is the plan ‘sound’?
2.3 Paragraph 35 of the National Planning Policy Framework defines the tests for soundness
which requires the plan to be positively prepared, justified, effective and consistent with
National Policy. These matters will now be considered in further detail in relation to the
current consultation on the Regulation 19 version of the Local Plan.
Is the plan positively prepared and justified?
2.4 Policy S1: Spatial Strategy, sets out the spatial development strategy for the District and
how the Council will achieve sustainable growth over the plan period. Policy H1: Meeting
Housing Needs sets out the housing target in response to the strategy. Both policies have
been informed by the Sustainability Appraisal (SA) dated January 2023 and the Plan
objectives, which are set out at paragraph 2.5.2 of the SA and the Council’s HEDNA (April
2022).
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2.5 The SA discusses the potential growth scenarios and confirms two points:
(i) Standard method housing figure for Chichester (excluding South Downs National
Park) is 638 dwellings per annum, or 11,484 in total over the Plan period; and
(ii) The above figure is capped at 40% above the baseline need and that the
uncapped figure is significantly higher than this at 884 dwellings per annum (dpa).
2.6 Of particular note is that point ii. seeks to cap the overall housing increase by no more
than 40% above the previously adopted LP housing figure of 435 dpa. It should be noted
here that the 435 dpa figure within the 2015 Local Plan was below the identified need of
505 dpa. This reduced housing figure was accepted on the basis of an early review, but
this early review did not take place.
2.7 Policy H1 identifies the need for the Plan to make provision for at least 10,350 dwellings
within the plan figure, amounting to 575 dpa. This is lower than both the standard method
figure of 638 dpa and the previously consulted Preferred Approach figure of 650 dpa which
accommodated some unmet need from the South Downs National Park Authority.
2.8 This draft Local Plan seeks to constrain housing numbers due to an alleged capacity
concern along the A27 strategic road network and constraints on Waste Water Treatment
Works. The Council therefore arrive at a constrained housing figure by virtue of the
standard method ‘steps’ and also due to infrastructure capacity.
2.9 The Transport Study (January 2023) is the key document on which the Council rely to
constrain their housing figure to 535 dpa. On review of this document, it is clear that the
Council’s consultants undertook a sensitivity analysis as to whether the core scenario that
supports the 535 dpa position in the local plan could accommodate a higher level of
growth. The conclusion in paragraph 5.6.5 and 11.2.3 of the Transport Study notes that
700 dpa could be accommodated (in the southern plan area) by the mitigation proposed
for the 535 dpa, with some additional (as yet undesigned and not costed), mitigation
works.
2.10 Accordingly, the Council’s own evidence base has undertaken the assessment and
concluded that a higher growth figure could be accommodated on the A27, subject to
appropriate improvement works. Given the testing of the higher growth figure in the
Transport Study, the exceptional circumstances to constrain growth, as set out at
paragraph 60 on the NPPF, do not appear to exist and the Plan could be considered
unsound on this point alone.
2.11 As a result of the above, the SA does not consider a scenario where the Council would
meet its local housing need, nor a scenario where it exceeds its local housing need. This is
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of relevance given that the previous Local Plan underprovided against the OAN, and when
considering the scale of development expected for adjoining authorities, including the
highly constrained SDNP.
Given that it is not accepted that the A27 capacity matters present a ceiling in terms of
housing delivery, it is not accepted that the Plan and associated SA demonstrate that
reasonable alternatives have been considered. The plan is not therefore positively
prepared, nor is the approach to housing figures justified.
Effective?
2.12 On the basis of the 535 dpa figure, it is considered that the selected areas for growth and
figures are deliverable over the Plan period, however, as set out above, the plan area could
accommodate a greater level of growth.
2.13 It should also be noted that the Plan does rely on the delivery of Neighbourhood Plan
and/or Small Site Allocations DPD. This is set out under Policy H3 in the draft document.
This states the following in terms of delivery:
If draft neighbourhood plans making provision for at least the minimum housing numbers of
the relevant area have not made demonstrable progress the council will allocate sites for
development within a development plan document in order to meet the requirements of this
Local Plan.
2.14 The above is not precise and does not provide any clear timetable for delivery within the
Plan period. Whilst the comments are noted above that the Plan could be effective, the
Local Plan needs to give a clear timescale for completion of the Supplementary
Development Plan Documents in order to help ensure it is completed.
Is the plan consistent with National Policy?
2.15 On the basis of the comments above, the approach to selected sites for allocation based
on the 535 dpa figure is considered to be consistent, however, due to the lack of evidence
to demonstrate that the 535 dpa figure should be capped due to the A27 capacity points
raised, the draft Plan does not appear to meet the exceptional circumstances allowed for
at paragraph 61 of the NPPF to justify the alternative approach. The Plan as proposed is
therefore inconsistent with NPPF when read as a whole.
3 Duty to Cooperate
3.1 Paragraph 24 of the NPPF outlines the need for co-operation between local planning
authorities on strategic matters that cross administrative boundaries.
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3.2 The draft Plan does not address any need requirements in relation to unmet housing need
of neighbouring authorities. Nor does it contain evidence to suggest that these matters
have been discussed with the adjoining Authorities.
3.3 The housing figures presented do not account for unmet need from the South Downs
National Park Authority. Whilst a Statement of Common Ground has been referred to, it
has not been published and therefore it is not possible to determine whether the decision
not to make any provision for the National Park is sound.
3.4 Further, Arun District Council has confirmed that it will be objecting to the Plan as currently
proposed on the basis that it has a significant housing need. This is likely to be further
influenced by Chichester not meeting its own needs, a repeat of the 2015 situation which
resulted in Arun having to address some of this within its 2018 Local Plan.
3.5 If the Plan is to proceed on the basis of providing 575dpa as per Policy H1, this will amount
to a shortfall of 1,100 dwellings over the plan period. Without any Statements of Common
Ground, it is unclear as to how this shortfall will be addressed.
4 The Site and its suitability
4.1 The Site comprises approximately 4.25 hectares of agricultural land located to the south
of the B2145 and east of Foxbridge Drive. Agricultural access is taken from the B2145
which abuts the entirety of the northern boundary. The western boundary adjoins
residential property Oakdene and properties at Foxbridge Drive and Farm Close. The Site
is not located within or in close proximity to any land at risk of flooding, nor is it in
proximity to any heritage assets.
4.2 In policy terms, the Site is located outside but adjoining the settlement boundary to the
west and is otherwise unconstrained. The latest Housing Economic Land Availability
Assessment (HELAA) (2021) assessed the Site positively, with potential to deliver
approximately 80 dwellings in the medium term.
4.3 In terms of accessibility, the Site is sustainably located and well connected with the local
footpath and cycle network. There is a surfaced path that runs along the northern
boundary of the site, largely separated from the road behind a hedge. This is not a
designated footpath as it forms part of the National Cycle Network Route 2 however, it is
used as such as it connects into the tow path that runs along the Chichester Canal which
travels north into Chichester or south towards the sea. A footpath is also located along
the B2145, providing access to services within the village.
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4.4 The Tow Path travelling into Chichester is also part of National Cycle Network Route 2
which connects directly into the heart of the city. This then connects into other cycle
networks north into Kent and west towards Portsmouth and beyond.
4.5 Initial feasibility studies determine that approximately 3 hectares of the site could be
suitable for residential development. The area for development would be focused
around the western boundary whilst the remaining area would comprise formal and
informal open space alongside additional planting and a robust landscaping strategy that
will respect the Ancient Woodland at Hunston Copse whilst ensuring net biodiversity gain
and green infrastructure connectivity with the biodiversity corridors that have been
identified to the north and east. Creating a landscape buffer to the east will also create a
clear, defensible boundary to the village.
4.6 The allocation and development of this land would provide a number of benefits to the
local community;
➢ The Site is well-connected to local services and facilities, within walking distance
of the village facilities such as the Hunston Store and Post Office, pub, village hall,
playing fields and canoe club;
➢ Para GA4.1 specifically states that traffic issues continue to cause major concerns
within the parish. Being located north of the village with direct access onto the
B2145 means the site would minimise additional traffic through the village;
➢ Proposals would include additional footpaths north-south to ensure connectivity
away from the main road whilst linking with existing footpath 188 which runs
east-west around the site;
➢ The Site is not subject to any environmental designations or constraints and is
not liable to flooding;
➢ A suitable landscaping strategy would ensure net biodiversity gain and green
infrastructure connectivity with existing biodiversity corridors to the north and
east;
➢ A landscape buffer to the east would create a clear, defensible boundary to the
north-eastern edge of the village;
➢ Provision of formal and informal open space would be of benefit to residents
throughout the community and to the north of the village especially;
➢ The Site is not constrained and does not rely upon significant infrastructure
improvements in respect of delivery;
➢ Development proposals would include a mix of high-quality homes, with the
potential to include starter homes, bungalows suitable for the elderly and
affordable housing to meet the varying needs of the community; and
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➢ Any future development would make contributions to local facilities and
infrastructure.
5 Conclusion
5.1 Whilst we understand the approach the Council has taken in terms of the selection of
sites to meet the 535 dpa figures, this is significantly lower than the standard method
figure of 638 and previously consulted figure of 650 dpa. The conclusion in paragraph
5.6.5 and 11.2.3 of the Transport Study appears to be that 700 dpa could be
accommodated (in the southern plan area) by the mitigation proposed for the 535 dpa
scenario plus some additional mitigation at the Portfield roundabout.
5.2 The Council do not appear to have considered that the increased housing requirement
could assist with funding the necessary highway improvements and thus this should be
further reviewed by the Council in order to aim to meet the minimum of 638 dpa.
5.3 The Council have failed to provide sufficient justification for not meeting its housing need
in full and have not suitably considered unmet need from adjoining authorities. The latter
is particularly relevant given constraints of the National Park.

We have reviewed the publicly available Local Plan documents and provided comments in the attached letter, in relation to the transport implications of the plan for the safety and operation of the SRN.
Our comments include issues to resolve, comments, requests for further information and recommendations. A brief summary of our main comments are:
- the reliance on the delivery of the A27 Chichester bypass improvements project.
- the requirements for new, additional, and adapted processes and assessments, especially in assessing Transport Assessments, mandating Travel Plans and monitoring traffic associated with new developments.
- collaborative working between agencies in combination with a robust monitor and manage policy.
We hope our comments assist.
To date National Highways have worked collaboratively with Chichester District Council (the Council) and West Sussex County Council (WSCC) and we will continue to work with the Council and other key stakeholders. We look forward to continuing to participate in future consultations and discussions.
Once you have had the opportunity to digest all the representations received, we would welcome a meeting to run through all the transport related matters and agree how to progress any required evidence gathering or other work.

Background

National Highways has been appointed by the Secretary of State for Transport as strategic highway company under the provisions of the Infrastructure Act 2015 and is the highway authority, traffic authority and street authority for the strategic road network (SRN).

National Highways is responsible for operating, maintaining, and improving the Strategic Road Network (SRN) i.e., the Trunk Road and Motorway Network in England, as laid down in Department for Transport (DfT) Circular 01/2022 (Strategic Road Network and the delivery of sustainable development).

The SRN is a critical national asset and as such we work to ensure that it operates and is managed in the public interest, both in respect of current activities and needs as well as in providing effective stewardship of its long-term operation and integrity.

Our responses to Local Plan consultations are guided by relevant policy and guidance including the National Planning Policy Framework (2021) (NPPF):

• Transport issues should be considered from the earliest stages of plan-making and development proposals so that the potential impact of development on transport networks can be addressed (para 104).

• The planning system should actively manage patterns of growth such that significant development is focused on locations which are or can be made sustainable, through limiting the need to travel and offering a genuine choice of transport modes. (para 105).

• Planning policies should be prepared with the active involvement of highways authorities and other transport infrastructure providers so that strategies and investments for supporting sustainable transport and development patterns are aligned. (para 106).

• In terms of identifying the necessity of transport infrastructure, NPPF confirms that development should only be prevented or refused on highways grounds if there would be an unacceptable impact on highway safety, or the residual cumulative impacts on the road network would be severe. (para 111).

• Planning policies and decisions should support development that makes efficient use of land, taking into account the availability and capacity of infrastructure and services – both existing and proposed – as well as their potential for further improvement and the scope to promote sustainable travel modes that limit future car use. (para 124).

In relation to the tests of soundness set out at paragraph 35 of the NPPF, in the context of transport, these are interpreted as meaning:

a) Positively prepared - has the transport strategy been prepared with the active involvement of the highway authorities, other transport infrastructure providers and operators and neighbouring councils?
b) Justified – Is the transport strategy based on a robust evidence base prepared with the agreement in partnership, or with the support of the highway authorities?
c) Effective – Does the transport strategy and policy satisfy the transport needs of the plan and is it deliverable at a pace which provides for and accommodates the proposed progress and implementation of the plan?
d) Consistent with national policy – Does the transport strategy support the economic, social, and environmental objectives of the Plan and the NPPF/NPPG?

We will be concerned with proposals that have the potential to impact on the safe and efficient operation of the SRN; in this case, the A27 trunk road (Chichester Bypass and its junctions) which is the main access route in the Chichester area. We have particular interest in any allocation, policy or proposals which could have implications for the A27 and the wider SRN network. We are interested as to whether there would be any adverse road safety or operational implications for the SRN. The latter would include a material increase in queueing or delay or reduction in journey time reliability during the construction or operation of the development set out in the plan.

National Highways is a key delivery partner for sustainable development promoted through the plan-led system, and as a statutory consultee we have a duty to cooperate with local authorities to support the preparation and implementation of development plan documents.

In accordance with national planning and transport policy and our operating licence, we are entirely neutral on the principle of development as it is for the local planning authority to determine whether development should be allocated or permitted; albeit it must comply with national policy on locating development in locations that are or can be made sustainable. Therefore, while always seeking early and fulsome engagement with local plans and/or developers, we will simply be assessing the transport and related implications of plans or proposals and agreeing any necessary transport improvements and relevant development management policy.

In progressing Local Plans, we will seek to agree the following:
• Assessment tools and methodology
• Baseline Assessment i.e., to demonstrate that the assessment tool accurately reflects current transport conditions
• Comparator case assessment i.e., to forecast the transport conditions that would occur in the absence of the plan
• Forecast modelling i.e., to forecast the transport conditions that would arise with the plan in place, this will include an assessment at the end of the Plan period; and, if required, at full build out if that occurs after the end of the Plan period
• Outputs and outcomes of modelling, demonstrating, as appropriate, what transport infrastructure is necessary to support the plan o It should be noted that a suite of transport modelling tools may be required. This includes strategic modelling covering an area at least one major junction beyond the district boundary, localised network modelling where several links/junctions are close together and/or individual junction modelling
o A DMRB (Design Manual for Roads and Bridges) compliancy assessment may also be required for certain highway features, such as
Merge/Diverge assessment at Grade separated junctions, link capacity assessments, and others.
• The design of any necessary transport infrastructure, to an extent suitable for establishing deliverability during the plan period at the time that it becomes necessary for the purpose of ensuring that unacceptable road safety impacts or severe operational impacts do not arise as a result of development. This may be to at least General Arrangement design stage or preliminary design stage. Whichever degree of detail is agreed, the products must be in full compliance with the DMRB.
• Industry standard transport intervention costings.
• The delivery/funding mechanisms for necessary transport interventions. It should not be assumed that National Highways will have any responsibility to identify or deliver necessary transport interventions.
• If considered appropriate, a “Monitor & Manage” (M&M) framework, aimed at managing the pace of development in line with the pace of funding and delivery of necessary highway interventions in a manner which responds to the realworld impacts of development may be agreed for inclusion in the plan subject to the adequacy of risk control measures included therein. This can include the move from a ‘predict & provide’ style of delivery to ‘a vision & validate’ style. o Any M&M framework must be based on a “worst case scenario” whereby necessary mitigation is understood, as well as setting out the desired alternative scenario. It must set out details of responsibility, funding and governance of the framework together with the methodology for determining the timing for any mitigation delivery while remaining clear on the fallback position where identified mitigation or desired alternatives are not ultimately achievable. It must be translated into development management plan policy and policy relating to development allocations.

Further detail on the above can be provided by National Highways.

While ideally all the above should be agreed prior to the Submission of the Local Plan for examination, we recognise that this is not always possible. However, all parties should work towards all matters being agreed and reflected in a Statement of Common Ground (SoCG) by the start of the Local Plan Examination at the latest. Ideally the SoCG between the Council and National Highways would be prepared well in advance of plan submission in order to guide resource input and to track progress towards final agreement on all relevant matters starting from the earliest plan iterations until the final version is agreed.

It is acknowledged that Government policy places much emphasis on housing delivery as a means for ensuring economic growth and addressing the current national shortage of housing. The NPPF is very clear that:
“Strategic policy-making authorities should establish a housing requirement figure for their whole area, which shows the extent to which their identified housing need (and any needs that cannot be met within neighbouring areas) can be met over the plan period.”

However, new DfT C1/22 and the NPPF are equally clear that any development, including housing delivery, must be tempered by the requirement to ensure that the associated transport demand can be accommodated without unacceptable impacts on the safety of the SRN or severe impacts on the operation of the SRN including reliability and congestion. Therefore, as necessary and appropriate, any plan and/or development must be accompanied by suitable mitigation in the right places at the right time, that is to the required design standards and is deliverable in terms of land availability, constructability and funding.

We would also draw your attention to the then Highways England document ‘The Strategic Road Network, Planning for the Future: A guide to working with National
Highways on planning matters’ (September 2015). This document sets out how National Highways intends to work with local planning authorities and developers to support the preparation of sound documents which enable the delivery of sustainable development. https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachmen t_data/file/461023/N150227_-_Highways_England_Planning_Document_FINAL-lo.pdf

Responses to Local Plan consultations are also guided by National Planning Policy Framework (NPPF) revised on 20 July 2021 which sets out the government’s planning policies for England and how these are expected to be applied.

Updated Circular (01/2022)
It should be noted that since the start of the Local Plan consultation process, on the 23 December 2022, the Department for Transport released a new circular on the ‘Strategic road network and the delivery of sustainable development’ (Circular 01/2022), which replaces all of the policies in Circular 02/2013 of the same name. These representations take account of the new circular and the requirements in terms of the Local Plan evidence base and process.

We request that the Local Plan is prepared in line with all aspects of the new circular. Particularly, the principles of sustainable development (paragraphs 11 to 17), new connections and capacity enhancements (paragraphs 18 to 25), and engagement with plan-making (paragraphs 26 to 38).

Regulation 18 submission
In our Regulation 18 submission we noted several matters including:
• The need to mitigate the adverse impacts of strategic development traffic to the A27 Chichester Bypass and its junctions at Portfield Roundabout, Bognor Road Roundabout, Whyke Roundabout, Stockbridge Roundabout and Fishbourne Roundabout and Oving junction.
• The need to identify a mechanism to calculate contributions towards the delivery of the previously agreed Local Plan A27 improvements
• The need to confirm the number of dwellings needed within the plan period
• The need to establish National Highways acceptance of the traffic model reference and future case scenarios
• The need to confirm costs, viability, and funding associated with mitigating the safety and congestion impacts of the development included within the plan.

Local Plan context
This Local Plan (Chichester Local Plan 2021 – 2039), prepared by the Local Planning Authority (LPA) Chichester District Council, sets out the vision for future development in the district and will be used to help decide on planning applications and other planning related decisions including shaping infrastructure investments.

The draft sets out how the district should be developed over the next 18-years to 2039 including for the full Plan period (1 April 2021 to 31 March 2039) the total supply of
- 10,359 dwellings
- 114,652 net additional sqm new floorspace
Minus the completions this is equivalent to around 530 dwellings and 6,150 sqm of floorspace a year.

National Highways Representations
To date National Highways have worked collaboratively with Chichester District Council (the Council) and West Sussex County Council (WSCC) and we will continue to work with the Council and other key stakeholders.

We have undertaken a review of the Chichester Local Plan 2021-2039 proposed submission version and accompanying evidence documents, our comments are set out in the tables below (following pages). [see table within attachment]

Summary

We have reviewed the publicly available Local Plan documents and provided comments above in relation to the transport implications of the plan for the safety and operation of the SRN. We understand that other technical information is available, but this was not presented as part of this consultation.
Chichester, and the A27, are already heavily congested, infrastructure in the existing Local Plan remains undelivered and the growth set out in the new Plan will further increase travel demand.
As presented, satisfying the transport needs of the plan is clearly reliant on the delivery of the A27 Chichester bypass improvements project. The A27 Chichester bypass improvements project is one of 32 pipeline schemes being considered for possible inclusion in National Highways third Road Investment Strategy (RIS3) covering 1 April 2025 to 31 March 2030.
On 9 March 2023 the UK Transport Secretary ensured record funding would be invested in the country’s transport network, sustainably driving growth across the country while managing the pressures of inflation. The announcement cited the A27 Arundel Bypass as being deferred from RIS2 to RIS 3 (covering 2025-2030). The transport secretary also identified a number of challenges to the delivery of the road investment strategy and cited the benefit of allowing extra time to ensure schemes are better planned and efficient schemes can be deployed more effectively.
At present, there is no commitment by DfT to carry out the A27 Chichester bypass improvements project. Until the A27 Chichester bypass improvements project is published in the RIS3, consented and a decision to invest is made it cannot be assumed to be a committed project.
We note that the Plan does not address any uncertainty of delivery of the A27 Chichester bypass improvements project and we strongly recommend that there is either no reliance placed on RIS3 to realise capacity for growth in the Plan or that contingency measures are included to cover the eventuality that RIS3 funding is not forthcoming within the plan period. It is not clear that the potential impact of development on transport networks can be addressed in the absence of the A27 Chichester bypass improvements project.
Achieving net zero, reducing emissions reduction, acting on climate, and supporting thousands of new homes and new employment developments will be problematic with existing processes. New, additional, and adapted processes and assessments will likely be required, especially in assessing Transport Assessments, mandating Travel Plans and monitoring traffic associated with new developments. We acknowledge that change is complex, expensive, and time-consuming, especially for smaller district level Councils. But the hard work will deliver benefits for the Council and residents in the longer-term.
National Highways seeks to continue working with the Council and WSCC to progress coordinated and deliverable packages of interim mitigation measures and alternative transport solutions while a long-term strategic solution is considered by government. This must however be in combination with a robust monitor and manage policy that appropriately manages the risk of unacceptable road impacts resulting from new housing
and other development over the Plan period.

We have been in discussion with Chichester District Council regarding their proposed Monitor and Manage Strategy. At present, we do not consider the current strategy to be robust and we seek further information and detail especially on who, when and when monitoring and management will be undertaken. Developments in the right places and served by the right sustainable infrastructure delivered alongside or ahead of occupancy must be a key consideration when planning for growth in all local authority areas. Any M&M framework must be based on a “worst case scenario” whereby necessary transport mitigation is understood, as well as setting out the desired alternative scenario. It must set out details of responsibility, funding and governance of the framework together with the methodology for determining the timing for any mitigation delivery while remaining clear on the fallback position where identified mitigation or desired alternatives are not ultimately achievable. The M&M framework must set out that the alternative to mitigation not being delivered is that development does not proceed where that development would give rise to unacceptable road safety risk or severe cumulative impacts on the road network in the absence of that mitigation. The M&M framework must be translated into development management plan policy and policy relating to development allocations.
As we have reiterated throughout our comments, we welcome the opportunity to work with you to address these outstanding matters and we will continue to liaise over submitted Transport Assessment, Travel Plan policy and Monitor and Manage Policy to help to work towards a viable plan.
We hope our comments assist.
We look forward to continuing to participate in future consultations and discussions. Please do continue to consult us as the Plan progresses so that we can remain aware of, and comment as required on, its contents.
Once you have had the opportunity to digest all the representations received, we would welcome a meeting to run through all the transport related matters and agree how to progress any required evidence gathering or other work.

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.

Policies applicable to allocations or general developments should specify the minimum standard each should meet in terms of Plan objectives and developers required to provide demonstrable evidence in support.

Recent history suggests new developments have been site-centric providing ‘lip-service’ to wider economic, social and environmental needs. Policies applicable to allocations or general developments should specify the minimum standard each should meet in terms of Plan objectives and developers required to provide demonstrable evidence in support.