Policy NE6 Chichester's Internationally and Nationally Designated Habitats

Cross reference to our response to NE5.
We support the inclusion and comprehensiveness of this policy, but argue that it is in effect incompatible with the levels of development proposed in the Plan, particularly relating to the east-west corridor between Chichester and Emsworth, along the boundary of the Chichester Harbour SSSI/SPA/SAC designated site. Any proposed mitigation measures must be deliverable, funded and monitored effectively, otherwise they will not have an impact in preventing further ecological deterioration of the Harbour.

We support this policy in full. In particular, we support greater protection of rare bats particularly Barbastelles which commute through our Parish to the AONB and need dark skies and lack of interference in their commuting routes.

An important Policy.

WGPC supports this policy intent.

Portsmouth Water support this policy.

Premier agree with the premise of Draft Policy NE6 and recognise the need to address water and nutrient neutrality issues. That said, Premier acknowledge the practical difficulties in guaranteeing nutrient neutral position for the lifetime of the development and suggest the ‘appropriate mitigation’ has regard for existing residents and the commercial viability of businesses and is proportionate to the scale of development proposed to ensure this doesn’t not render development unviable and to avoid overburdening local residents and businesses.
Premier recognise the unique qualities of the Chichester Marina’s location and the areas’ international and national designated habitats. With this is mind and factoring in Premier’s responsibilities as the long-term manager and steward of the Site, Premier is committed to protecting Chichester Marina’s sensitive habitats in the interests of protecting local wildlife.

We are supportive of this policy and the references to Water Neutrality and Nutrient Neutrality relating to the Sussex North Water Resource Zone and Chichester and Langstone Harbours Special Protected Area respectively. Proposals by developers to address these issues (such as creating wetlands or obtaining water supply from boreholes) may have requirements for environmental permits from us. Early engagement with us is encouraged to check whether such permits can feasibly be obtained for any such proposals.

See attached representation.

See attachment.

It is respectfully suggested that the policy be accompanied
by an inset map showing the respective zones of influence.

See attachment.

We would suggest you consider amending the title to “Internationally Designated Habitats” only and that
nationally designated sites are sufficiently covered under the relevant section of Policy NE5.

There are several instances including paragraph 4.27, the title of paragraph 4.31 and policy point a) where reference to the Arun Valley Ramsar site has been missed.

To avoid any confusion we would encourage reference to the Chichester and Langstone Harbours SPA as this is the correct, full name of the site (even though it is only the Chichester Harbour section that falls within the district).

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.

Wording of the Policy appears weakly drafted where it states that “due regard to the possibility that barbastelle and Bechstein’s bats will be utilising the site”. This wording should be strengthened. Policy requires ‘necessary surveys’ but it should be clear about what surveys are required. Policy should be clear about scale and form of buffers rather than leaving it completely open. Policy should require that proposals undertake bat surveys as early as possible and that surveys should provide evidence over sufficient time.

See attachment.

Premier agree with the premise of Draft Policy NE6 and recognise the need to address water and nutrient neutrality issues. That said, Premier acknowledge the practical difficulties in guaranteeing nutrient neutral position for the lifetime of the development and suggest the ‘appropriate mitigation’ has regard for existing residents and the commercial viability of businesses and is proportionate to the scale of development proposed to ensure this doesn’t not render development unviable and to avoid overburdening local residents and businesses.
Premier recognise the unique qualities of the Chichester Marina’s location and the areas’ international and national designated habitats. With this is mind and factoring in Premier’s responsibilities as the long-term manager and steward of the Site, Premier is committed to protecting Chichester Marina’s sensitive habitats in the interests of protecting local wildlife.

To provide an inset map showing the habitat zones of influence to accompany the policy.

See attachment.