Policy NE14 Integrated Coastal Zone Management for the Manhood Peninsula

Point 6 should be replaced by a Policy which specifically identifies the routes etc. needed, safeguards them, and requires funding to allocated to them.

While there is a lot to support in this policy and we would agree with the following analysis in relation to active and sustainable travel;
"Poor road accessibility and problems of traffic congestion result from the limited road connections to the north, the junctions on the A27 Chichester Bypass, and increased traffic during the summer holidays and major events in the district. There are reasonably regular bus services serving Selsey, East Wittering and the other main settlements on the Peninsula, however, these are more limited in terms of evening and weekend services. Direct off-road cycle paths and pedestrian routes are also lacking. These problems of accessibility are further accentuated by the fact that the Peninsula relies strongly on Chichester city for employment, shopping, entertainment and other key facilities, which increases the need to travel."
there are no substantive policies to rectify this situation.

We support the continued inclusion of this policy and specific references to key Plans.

Revised NE14 proposed - see attached written representation doc for full wording. Proposed revisions include climate change adaptation and mitigation including designating an area of coastal change management and supporting development that is capable of long term defence by recognising managed retreat.

See attachments.

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.

In the second bullet of supporting paragraph 4.84 the incorrect reference to the “Chichester Harbour SAC/SPA/Ramsar sites” should be removed and replaced with the correct site name the “Chichester and Langstone Harbours SPA/Ramsar site”. The Solent Maritime SAC (which partially overlaps with the SPA/Ramsar) is correctly referenced later in the paragraph.

We would recommend that Policy Requirement 4 is expanded as follows: “All development proposals should seek to enhance the distinctive character of the Manhood Peninsula, having particular regard to the ecology (including the potential to contribute to any nature recovery networks), landscape and heritage of the area.

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.