Policy P15 Open Space, Sport and Recreation

The Woodland Trust supports point 3 that there should be no adverse impact on biodiversity from development affecting open space.

We welcome the inclusion of natural greenspace in Table 6.3 – Minimum Open Space Quantity and Access Standards. However we note that the standard set (1ha within 600m) falls short of Natural England’s Accessible Natural Green Space Standard of accessible natural green space of 2ha within 300m, In addition, the Woodland Trust's Woodland Access Standard recommends 2ha of accessible woodland within 500m.
We request that the policy is applied as a minimum, and that higher provision is made where feasible.

WGPC supports this policy.

Support

Miller and Vistry are broadly supportive of this policy, having committed to deliver significant levels of new public open space on site. However, it is not clear from the policy what the expectations are in terms of which developments would be expected to provide indoor facilities. Given the complex nature and cost of providing indoor sports facilities, there should not be an expectation to provide such facilities unless they have formed part of the early masterplanning of the site. The West of Chichester development is masterplanned to provide space for indoor sport within the Community Building at the center of the site, along with suitable outdoor facilities.

See attached representation.

Recommend that reference to the provision of indoor facilities is removed from this policy. If onsite facilities are required, this should be agreed with the site promoter and set out in the site allocation.

See attachment.

See attachment.

Existing open space is ill-defined in the final part of draft Policy P15. It is respectfully suggested that this might more appropriately reference open space and playing fields identified on the proposals map (adding this if necessary).

See attachment.

Suggest either table 6.1 is re-worked with the benefit of further evidence, to include thresholds for on-site indoor space, or deleted, and left to be expressed in individual site allocation policies.

See attachment.

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.

See attachment.

Miller and Vistry are broadly supportive of this policy, having committed to deliver significant levels of new public open space on site. However, it is not clear from the policy what the expectations are in terms of which developments would be expected to provide indoor facilities. Given the complex nature and cost of providing indoor sports facilities, there should not be an expectation to provide such facilities unless they have formed part of the early masterplanning of the site. The West of Chichester development is masterplanned to provide space for indoor sport within the Community Building at the center of the site, along with suitable outdoor facilities.

We request that the policy is applied as a minimum, and that higher provision is made where feasible

The Woodland Trust supports point 3 that there should be no adverse impact on biodiversity from development affecting open space.

We welcome the inclusion of natural greenspace in Table 6.3 – Minimum Open Space Quantity and Access Standards. However we note that the standard set (1ha within 600m) falls short of Natural England’s Accessible Natural Green Space Standard of accessible natural green space of 2ha within 300m, In addition, the Woodland Trust's Woodland Access Standard recommends 2ha of accessible woodland within 500m.
We request that the policy is applied as a minimum, and that higher provision is made where feasible.