Policy P5 Spaces and Landscaping

Paragraph 4 of Policy P5 needs to add the consideration of climate change adaption measure including the the Dark Sky policy directive from The South Downs National Park, as a design aspiration so that all lighting is designed to be sensitive to the needs of nature.
Para 8 needs to conserve planting already in place and build developments around hedges and trees that are already established as per new directive ; Creating healthy and sustainable places for West Sussex.
Without these additions the policy is unsound as it is unsustainable.

Paragraph 4 of Policy P5 needs to add the consideration of climate change adaption measure including the the Dark Sky policy directive from The South Downs National Park, as a design aspiration so that all lighting is designed to be sensitive to the needs of nature. So that it is only lit for the minimum length of time for safety and all lights face downwards and do not detract from flight corridors of any airborne species, not does the lighting dazzle or infringe on non human activities in a way disadvantages the activities of wildlife.
Para 8 needs to conserve planting already in place and build developments around hedges and trees that are already established as per new directive from West Sussex ; Creating healthy and sustainable places for West Sussex. The aspiration from the Vision statement where Item 6 is Thriving and Accessible Natural Environments. Cutting down the natural environment to replant it afterwards doesn't work. The photo on page 10 is of the cathedral in Chichester as seen from the Bishops Palace Gardens, with its established trees. Emulate this beautiful garden that was established at the same time as the cathedral and we start well.

The Woodland Trust supports this policy. In particular, we welcome policy to prioritise the use of locally native species and the retention of existing trees (point 8), for to connecting existing green infrastructure corridors and seek to create new ones (point 9), supporting appropriate new tree planting (point 10) and wildlife passages (point 11).


We recommend setting a tree canopy cover target to support the Council’s Climate Emergency Action Plan. The Woodland Trust supports the UK Committee on Climate Change’s recommended increase in UK woodland cover from the current 13% of land area to at least 19% by 2050.

WGPC supports this policy intent.

See above.

As with Policies P2 and P4, whilst the principles of providing attractive, well landscaped space is supported, the policy is overly detailed and prescriptive, relating to matters more appropriately included in a design guide rather than planning policy. It is also considered the policy replicates points made in policies 2 and 4 in particular.
See representation report

Amending the reference to green infrastructure to green/blue infrastructure as per our comments for Policy P1.

We support this policy as drafted, save for amending the reference to green infrastructure as per our comments for Policy P1. The expectation for development to integrate climate change adaption measures in point 4 is positive.

P5, para.8 add "and hedgerows" after "existing trees".
P5, para. 10 add "and transpiration" after "solar shading" (before "benefits").

Legally compliant/duty to co-operate - don't know.
Sound: we broadly support this Policy but, for consistency with other parts of the Plan and completeness, suggest a couple of tweaks.

See attachment.

See attachment.

See attached representation.

It is recommended that this be addressed with an amendment to follow the recommendations of the PPG.

1 Henry Adams LLP act on behalf of Barratt David Wilson (Client) in respect of Land at
Maudlin Farm (the Site). These representations respond to the Regulation 19 Consultation version of the Chichester Local Plan 2021-2039 (Feb 2023), which identifies the site as a Strategic Development allocation through Policy A11 Highgrove Farm, Bosham.

1.2 In this context, our response is focused on the following matters;
 The development strategy, settlement hierarchy and distribution of development,
 The overall amount of new housing required within the new plan period, and
 The strategic allocation proposed at Bosham in Policy A11.

1.3 The Site is subject of a live application which was submitted over 2 years to the Council, following publication of an Interim Housing Statement, which encouraged applications on suitably located sites, including those comprising draft allocations. The Council are yet to determine this application. This submission is accompanied by the design and access statement (Appendix 1) submitted with the live application for the site which focuses on the site opportunities and constraints alongside the design considerations.

In summary, the Client supports the allocation of Highgrove Farm, Bosham for residential
development. The technical work and accompanying design and access statement demonstrate that the site is capable of delivering 300 dwellings during the course of the plan period.

6.2 The Client would however request that amendments be made to the wording of the policy to allow for a level of flexibility so that any future development can be aligned with what is appropriate to deliver to meet local needs.

Amend P5 to follow recommendations of PPG.

See attachment.

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 recommend setting a tree canopy cover target to support the Council’s Climate Emergency Action Plan. The Woodland Trust supports the UK Committee on Climate Change’s recommended increase in UK woodland cover from the current 13% of land area to at least 19% by 2050.

The Woodland Trust supports this policy. In particular, we welcome policy to prioritise the use of locally native species and the retention of existing trees (point 8), for to connecting existing green infrastructure corridors and seek to create new ones (point 9), supporting appropriate new tree planting (point 10) and wildlife passages (point 11).


We recommend setting a tree canopy cover target to support the Council’s Climate Emergency Action Plan. The Woodland Trust supports the UK Committee on Climate Change’s recommended increase in UK woodland cover from the current 13% of land area to at least 19% by 2050.