Policy NE16 Water Management and Water Quality

Amend requirement for no adverse impact to " minimise" adverse impacts.

This representation is made by SUEZ Recycling & Recovery Southern Ltd (SUEZ), who along
with SUEZ Recycling & Recovery UK Ltd forms part of the SUEZ group of companies within
the UK. This representation is made in response to the Chichester Local Plan 2021-2039
Proposed Submission consultation.

SUEZ Recycling & Recovery Southern Ltd are the landowner of part of the land subject to the
draft strategic site allocation ‘Land East of Chichester’ identified in draft Policy A8.

Strengthen policy wording to emphasise that 110 litres per person per day is the maximum rate.

Signposting of the Waterwise UK Water Efficiency Strategy to 2030 within policy or supporting text to provide greater encouragement of lower water efficiency rates in new development.

Expansion of supporting text to reference Pagham Harbour so all designated sites relevant to the plan which reply on water quality and water support are covered.

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.

See attachment.

Sustainability Appraisal Comments on Soundness

More action is needed to preserve and improve the quality of life of residents. Recently there has been increased flooding and release of sewage in the Chidham, Hambrook and Bosham areas. Wildlife is also suffering and pollution increasing through high levels of traffic.

Further work needs to make clear to the government the difficulties found by the Council in coping with large new housing developments. Current infrastructure is inadequate in many areas.

A representative of Southern Water recently stated at CDC Overview and Scrutiny committee that it would be able to start on improvements in 2025, a date that they would be available was not given. Southern Water is being put in an impossible position when they are unable to manage the current amount of wastewater but have a statutory duty to treat wastewater from a new development. Tankers should only be used for short periods in emergencies, they increase the carbon footprint, pollution and damage local roads. Water is being extracted from the River Ems to cope with increasing demand.

Roads are in poor condition and becoming overcrowded, with many more cars parking along narrow roads, so that the roads become one way. Closer inspection and management of roads is needed. Priors Leaze Lane in Hambrook and Southbourne is narrow and winds along the Ham Brook. The section running between Inlands Road and the Grain Store should be converted to a footpath and cycle track so that residents from Hambrook and Southbourne can safely travel on foot/cycle.

Any new development should provide 50% of affordable housing. Other districts have managed to make 100% of some developments affordable. The current affordable price should be agreed and statistics published to show that local people, young and old are buying/renting.

The importance of rare chalk streams has recently been mentioned by the WWF, the South Downs National Committee on Chalk Streams and in the West Sussex Wildlife Trust magazine. Care should be taken to protect the Ham Brook and Hairspring Watercress Farm (mentioned in the Doomsday Book).

REPRESENTATION TO THE PLANNING POLICY TEAM RE THE LOCAL PLAN MARCH 2023
Our interests in reading the Local Plan 2023 are namely:

The INFRASTRUCTURE NEEDED TO SUSTAIN SUBSTANTIAL DEVELOPMENT

YOU SAY: To work with infrastructure providers to ensure the timely delivery of key infrastructure to support delivery of new development. New development will be supported by sufficient provision of infrastructure to enable the sustainable delivery of the development strategy for the plan area.

Key infrastructure to support the Local Plan will include improvements to transport, open space and green infrastructure, education, health, water supply and removal, telecommunications, flood risk and coastal change management and the provision of minerals and energy Page 33
CAN YOU ACHIEVETHIS?

ROADS - already suffering with surface damage and from too high density of traffic

YOU SAY: A sustainable and integrated transport system will be achieved through improvements to walking and cycling networks and links to accessible public transport. Highway improvements will be delivered to mitigate congestion, including measures to mitigate potential impacts on the A27 through a monitor and manage process.
Page 33 CAN YOU ACHIEVETHIS?
MANAGEMENT OF SEWAGE TREATMENT AND DISPOSAL

YOU SAY: Sewerage undertakers will need to work with regulators to deliver improvements in wastewater infrastructure to support new development and to ensure adverse environmental impacts are avoided on internationally designated habitats. Improvements to water efficiency, conservation and storage capacity will be made.
Page 33 CAN YOU ACHIEVE THIS?
THE IMPACT SUBSTANTIAL DEVELOPMENT WILL HAVE ON OUR UNIQUE AND PRECIOUS ENVIRONMENT. INCREASING LIGHT POLLUTION.
YOU SAY: 12. Protect and enhance the existing biodiversity and important ecological corridor linking Chichester Harbour and the South Downs National Park.
Any development will need to: /

a. Provide multifunctional green infrastructure both across the site and linking development to the surrounding countryside and Chichester city;
b. Provide mitigation for any loss of watercourse habitat resulting from culverting for highway provision in the development;

c. Provide buffer zones to sensitive habitats such as ancient woodland; Page 223

CAN YOU ACHIEVE THIS?

We applaud the words written down on efforts regarded as essential for the conservation of the AONBs and SSSls of the Harbour. We applaud the efforts to maintain the wonderful view of the Cathedral from various aspects of the City.
But we have little faith of these foreseen problems being effectively dealt with.

If the stretch of the A259 from Southbourne (which is classified as a Settlement Hub) to Fishbourne, where we already experience serious impact in congestion and noise, is going to be allocated several thousand new houses by 2030, I cannot imagine how the road will be able to start coping with that increased density of traffic. Another several thousand x 1.5 average vehicles per house will be using this already regularly gridlocked road.
We would implore that you actually managed to achieve what you are setting out with this wordy document but we have little faith, in fact, do not believe, that our environment and the precious habitats and lives of our wonderful local flora and fauna will be enhanced or even upheld in the process and we therefore believe that this Local Plan is unsound.

Southern Water’s comments relate to the headed parts of this policy as follows, and we have suggested changes for the Water Supply and Water Efficiency sections of this policy, whilst we support the Water Quality and Wastewater section. We have uploaded this document to the consultation portal due to the limited space allowed for representations.

Water Supply

Southern Water supplies water to the north of Chichester District, to settlements within the Sussex North WRZ. Water resource planning is managed at regional scales by water companies through the production of Water Resources Management Plans (WRMPs) which are updated every 5 years. These plans set out how water companies will achieve secure water supplies for customers, whilst protecting the environment. New development sites allocated through local plans are taken into account as part of this process.

Moreover, it would not be necessary to include developments within the Sussex North WRZ in the requirements of criteria (a) and (b) of Policy NE16, as these will automatically be met where the development has complied with the requirements of Policy NE17.

Suggested amendment;

Development proposals outside the Sussex North Water Resource Zone will be permitted that demonstrate;

a) […]


Water Efficiency

Regarding criterion (b) of this policy’s Water Efficiency section, we would request a correction to the reference to our water resource zone, for consistency and accuracy, as follows;

‘… development in Southern Water’s Water Resource Supply Zone Sussex North..’

Water Quality and Wastewater

Southern Water supports this policy, in particular criteria (c) and (d) which relate to surface water and new infrastructure provision.

Add 'The uncertainty of these constraints, the reduced efficiency of SUDS in such low-lying areas and the current concerns about Chichester Harbour make it unlikely that there would be much further sustainable
Development.'

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.

WGPC supports this policy intent but had concerns relating to water supply and wastewater treatment as detailed in its submission for Policy H3.
In terms of wastewater, severe problems are already being experienced and additional housing has the potential to exacerbate these issues.
WGPC is concerned that Southern Water is not taking these concerns seriously, and capacity figures are based upon dry weather.