Policy H13 Accommodation for Gypsies, Travellers and Travelling Showpeople

It needs to be made clear that this is in terms of its scale and not location.

Clarify 'dominance'

Criteria 1 refers to well related but this is not explained in any details

We support the specific criteria in this policy to ensure that sites avoid locations where there are significant constraints including flood risk (criteria 2).

See attached representation.

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 all cases, proposals for gypsy, traveller and travelling showpeople’s accommodation are expected to contribute to relevant access management strategies to mitigate recreational disturbance to SPAs in accordance with Policy NE6 (Chichester’s Internationally and Nationally Designated Habitats), and Policy NE7 (Development and Disturbance of Birds in Chichester, Langstone and Pagham Harbours and Solent and Dorset Coast SPAs, and Medmerry Compensatory Habitat)”

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.

We would argue that other locations than Westbourne with lower intensities of such use should be sought to meet this need.

The Parish Council supports the vision and overall strategic objectives of the Local Plan 2021-2039.

Spatial strategy:

Westbourne is identified as a Service Village and there is a given allocation for new development of 30 dwellings. In general terms this seems like a reasonable level of new growth that can be accommodated. However, the plan recognises that in the general area the scope for new development between the National Park boundary and the A27 is limited outside of Southbourne due to physical and environmental constraints. Given these limited opportunities to find land for new development around the village, which was confirmed in the Neighbourhood Planning process recently completed, the scope for Westbourne to take further development is very limited. The Parish Council would urge the District Council to see this quantity of 30 as a maximum target. We would ask the District Council to confirm that it would not suggest a new strategic development being brought forward in the allocations plan for Westbourne as the constraints of the National Park setting and other countryside policies severely limit the scope for further development.

Policy H4, affordable housing policy:
The existing policy only requires on-site provision of affordable housing for 10 or more dwellings. The proposed changes to require commuted sum payments in defined rural areas on sites for between six to nine dwellings is supported. However, this as drafted currently excludes Westbourne. Westbourne Parish Council would urge the District Council to ensure that this policy applies to Westbourne as it has limited opportunity for larger sites which makes it difficult to bring forward affordable housing and there is a clear need for more affordable housing in the Parish.

Policies H12 and H13:

The Plan indicates that there is a high level of unmet need generally for Gypsy’s Travellers and Show People. The high levels of existing and unauthorised pitches in Westbourne is also mentioned in the Plan. The neighbouring parish of Southbourne is also mentioned as a location with high levels of pitches and unmet need. The relevant extract on the approach to meeting this need is as follows. “the council has had to utilise a wide range of options for meeting this need. This entails providing pitches on the strategic housing allocation sites, supporting increases in the density of pitches on existing authorised sites which have been assessed as being acceptable in principle for additional pitches, and allowing pitches to come forward on a case-by-case basis. The council will also consider allocating additional pitches via the forthcoming Allocations DPD.”

Westbourne Parish Council is concerned to avoid intensification of the authorised and unauthorised Gypsy and Traveller and Showman’s Pitches located within the Parish. Westbourne already has one of the highest concentrations of such uses anywhere in the District and further intensification will have an adverse impact on the balanced and cohesive community that we seek to protect. We would argue that other locations with lower intensities of such use should be sought to meet this need.

The site in Cemetery Lane at Greenacre is identified as a location for an additional four pitches. There have been many enforcement issues in this area with unauthorised pitches and unauthorised industrial and commercial development, and further increases in the quantity of pitches will exacerbate the situation to the detriment of the balanced and cohesive community that the Parish Council seeks to protect and enhance.