Objective 2: Natural Environment

We support these ambitions. However in reality it is unlikely that the proposed plan will be able to deliver these aspirations. The volume of housing proposed between Chichester and Emsworth (3,225), especially when combined with Havant Borough Council's strategic site at Southleigh (2,100 homes) will lead to an unprecedented level of development pressure on the AONB, SSSI/SPA designated site at Chichester Harbour. Inevitably the repercussions for waste water treatment (already at full capacity and storm discharging regularly) and additional recreational disturbance will further compound the challenges affecting the protected site, meaning that it is unable to recover from the current "Unfavourable Declining" condition assessment.

Reduce the overall number of housing from 10,350 to protect the designated sites.

Location of high levels of housing close to Chichester Harbour will not protect it from further damage and decline. In fact it will speed up the decline.

Areas, important in landscape terms (including importance to and separating adjoining developed areas) or those suitable for woodland and nature recovery should be identified and protected from inappropriate development through policies and proposals of the Plan.

The plan should identify key areas where these benefits will be sought. The objective should go beyond wildlife corridors.

Support – WGPC supports this approach but questions how it could be applied to Wisborough Green. Wisborough Green is a rural village, surrounded by designated sites rich in biodiversity. Building on greenfield sites in this location will not achieve gains, net or otherwise.

Include reference to landscape character.

The explanatory text is all about the low-lying land. The Council suggest that this text needs to reflect the whole objective and refer to 'landscape character'. Ideally this should be first, as it is the landscape character (geology, soils etc.) that underpins the important natural environment and designated sites being referenced.

The reference to achieving net gains in tree cover is welcome.
Policies in the Plan need to be in place to secure this objective.

Supports SOSCA's Submission as attached.

We suggest that Strategic Objective 2 (Natural Environment) be amended to include conserving and enhancing the South Downs National Park and its setting to reflect the duty of regard in Section 62 of the Environment Act 1995 and Paragraph 176 of the NPPF.

See attached representation.

Natural England advise the addtion of “and where relevant will be water neutral” to the final sentence in this objective in order to provide context for the inclusion of Policys NE16 and NE17.

Natural England advise the inclusion of the phrase “SuDS will be incorporated to manage run-off” at the end of this objective although we acknowledge and support its inclusion in Chapter 4 Policy NE15.

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.

Given the importance of landscape in the District and its location within the setting of the South Downs National Park, request new objective on Landscape is included
in Local Plan.

See attachment.

See attached.

The explanatory text is all about the low-lying land. The Council suggest that this text needs to reflect the whole objective and refer to 'landscape character'. Ideally this should be first, as it is the landscape character (geology, soils etc.) that underpins the important natural environment and designated sites being referenced.