Habitats Regulation Assessment - January 2023

Comment

Representation ID: 5511

Received: 17/03/2023

Respondent: Bellway Homes (Wessex) Ltd

Agent: Chapman Lily Planning

Bellway supports outcome of HRA. Some confusion Table 1 which references withdrawn Local Plans and Draft Reg 18 Local Plans. This questions how reliable the dataset used by the HRA is, considering that full weight cannot be attributed to draft Reg 18 Plans. Bellway appreciate that the HRA declares that the pre-submission plan supports a reduction in atmospheric pollution. Within Appendix A of HRA, it is considered that draft Policy H2 (incorporating Policies A4 and A5) has the potential for likely significant effects. Despite this, the HRA explains that the pre-submission plan contains positive measures that aim to mitigate or avoid the likelihood of significant adverse effects from reduced air quality and that policies NE21, T2, T3, NE1 form a protective framework to help reduce atmosphere pollution.
Bellway consider the draft HRA to be robust.

Comment

Representation ID: 5794

Received: 17/03/2023

Respondent: Kirdford Parish Council

Agent: Troy Planning + Design

Extensive representations on HRA in attachment covering Ebernoe Common SAC; Appropriate Assessment - Disturbance of Bat Flight Lines; Appropriate Assessment - Atmospheric Pollution; The Mens SAC and Water Neutrality.

Comment

Representation ID: 6009

Received: 03/05/2023

Respondent: Natural England

[RECEIVED LATE]
Atmospheric Pollution - Do not agree with many of the arguments currently used to conclude No Adverse Effect on Integrity (AEOI) for the following sites: Ebernoe Common Special Area of Conservation (SAC); The Mens SAC; Butser Hill SAC; Kingley Vale SAC; Duncton to Bignor Escarpment SAC. Not saying conclusion of No AEOI is incorrect but other evidence needs to be provided to support this.

Water Quality (including Nutrient Neutrality) - Solent sites: in relation to proposed site allocation at Highgrove Farm and nutrient mitigation land at Chilgrove Farm, local Nutrient Neutrality (NN) lead is satisfied with approach proposed. Happy to have discussion with CDC to understand and hopefully allay any remaining concerns about the Plan’s approach to NN; - Pagham Harbour: evidence still developing in relation to water quality situation at PH, may not be as simple as HRA currently makes it (stating there is no current issue with water quality and no requirement for specific mitigation). However, given Plan allocates limited (if any) development discharging to Pagham Harbour, general protection afforded by policies NE6 and NE16 may be sufficient to conclude No AEOI at this point in time.

Loss or Degradation of Functionally Linked Habitat
- Solent sites: functionally-linked land around Solent is well documented through Solent Wader and Brent Goose Strategy. Draft Local Plan proposes new development in four areas which potentially overlap with Solent functionally-linked land although there are no detailed site allocations at this point. Support general policy protection provided through policies NE5, NE6 and NE7 but advise wording in ‘Broad Location for Development’ policies for Chidham and Hambrook (A12) and Southbourne (A13) be strengthened to better reflect the mitigation hierarchy.