Habitats Regulation Assessment - January 2023
Comment
Sustainability Appraisal and Habitats Regulation Assessment
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 Some confusion Table 1 which references withdrawn Local Plans and Draft Reg 18 Local Plans.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.
See attachment.
Comment
Sustainability Appraisal and Habitats Regulation Assessment
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.
See attachment.
Comment
Sustainability Appraisal and Habitats Regulation Assessment
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.
See attachment.
Comment
Sustainability Appraisal and Habitats Regulation Assessment
Representation ID: 6507
Received: 28/05/2024
Respondent: CPRE Sussex
Agent: CPRE Sussex
RECEIVED LATE: Lack of coverage of Pagham Harbour issues, likely to have same status as condition of Chichester Harbour; nothing in plan re; Sidlesham WwTW already at capacity; A27 work paused for 3 years according to Government announcement; no substance to water neutrality issue - almost impossible to reduce water consumption below 110 lppd until at least 2050.
Lack of coverage of the Pagham Harbour issues. Natural England has a draft report on the extant condition within Pagham Harbour but there is a deficit of survey data available and so conclusions and recommendations cannot be made yet. More work is required but it should be noted that the two Harbours are linked by a rife.
Pagham Harbour is likely to have the same status as the pollution concerns as found in the Natural England report on the condition of Chichester Harbour has but unlike the proposals at Thornham WWTW where Southern Water accepts immediate work is needed (immediate is still probably 5 years away) with phasing of any development up to 10 years int the plan nothing appears for in the plan for the Sidlesham WSTW which serves much of the Manhood Peninsula and is already working at capacity.
Proposed work on the A27 is paused for 3 years according to Government announcement last week and the dropping of junction improvements around Worthing seem to point to abandonment of the western A27.
The Water neutrality issue appears to have no substance as it would be almost impossible to reduce water consumption below 110 ltrs ppa day at least until 2050 –
Reference: Southern Water’s own ‘Water 100’ plans.