4.16

Add an 8th wildlife corridor between the Medmerry managed retreat area (NE corner) and Pagham Harbour (RSPB facilities at The Ferry).

Fails to identify thge necessary 8th wildlife corridor, one between the Medmerry managed retreat area (NE corner) and Pagham Harbour (RSPB facilities at The Ferry).

The paragraph should be amended as follows:

4.16 The council has commissioned and undertaken significant habitat surveys, data collection and evidence gathering to enable the mapping of the proposed corridors. This has enabled the council to identify hedgerows, treelines, woodland, chalk streams, ditches and rifes which are used as ecological corridors by species of bats, birds and water voles. The ecological networks, in addition to high concentrations of species records and the location of priority habitats and designated sites, has enabled the council to identify seven strategic wildlife corridors which connect Chichester and Pagham Harbours with the South Downs National Park (as shown on the policies map). These corridors do not stop at the plan area boundaries and the council appreciates that no wildlife can be expected to have any regard to such corridors, and that it is appropriate to consider much wider corridors, including the entirety of the corridor between Chichester and Tangmere given that successive exercises have identified different corridors from time to time.

There is much to commend in this document and the supporting technical documents that accompany it, and I have listed in the appendix to this letter 26 such paragraphs and policies. I am happy for my support to be registered against these sections of your consultation document. There is also much upon which I must represent a concern, so I attach representations relating to 22 paragraphs or policies.

I am happy to participate in a hearing session, and I would flag at this stage that the common theme that links all of these representations is the need to safeguard the natural and built environment in and around Saxon Meadow, Tangmere from the risks of unsustainable development, I consider that the independent examiner should focus their review on the aspects of the local plan that relate to this matter.

Appendix 1: list of policies that I support
1. P14, 1.23, 1.24: Duty to cooperate
2. P24, para 2.30 "the council declared a climate emergency in July 2019"
3. P24, para 2.32 — "all proposal for new development should be considered in the context of a climate emergencV'
4, P30: Objective 2: natural environment: "development will achieve net gains in biodiversity'
5. P43, 4.1 "National policy promotes increasing energy efficiency, the minimisation of energy consumption and the development of renewable energy sources"
6. P43, 4.3: "Some renewable energy projects provide significant opportunities to enhance biodiversitV'
7. P53, Policy NE5: Biodiversity and Biodiversity Net Gain
8. P62, Para 4.42: Hedgerows and some types of woodlands are identified as a priority habitat
9, P62, Policy NE8: Proposals should have a minimum buffer zone of 15 metres from the boundary of ancient woodland or veteran trees to avoid rood damage (known as the root protection area)
10. P68, Policy NEIO: Criteria for Development in the Countryside - Does not prejudice viable agricultural operations or other viable uses
11. P80, Para 4.91: There are serious concerns about the impact of flooding, both in respect of current properties at risk but also the long-term management of the area.
12. 4.92: any development in the plan area must therefore have regard to flood and erosion risk.
13. 4.94: built development can lead to increased surface water run-off; therefore, new development should include SuDS to help cope with intense rainfall events
14. P81, Para 4.96: Environment Agency consent is required for any works within 16 m of tidal waters and 8m of fluvial watercourses in line with the Environmental Permitting Regulations 2016. This strip is required for access. The policy includes a setback requirement to ensure this access strip is not obstructed.
15. P80, 4.92, Any development in the plan area must therefore have regard to flood and erosion risk, now and in the future, by way of location and specific measures, such as additional flood alleviation, which will protect people, properties and vulnerable habitats from flooding. Recent changes to national guidance highlight the importance of considering flood risk from all sources, and this is particularly significant for the plan area as large parts of it are at risk from groundwater flooding, which needs to be recognised in development decisions alongside the well-established risks in relation to tidal, fluvial and surface water flooding. Appropriate mapping of all sources of flood risks is still evolving, and is likely to develop further over the plan period
16. P93, Policy NE20 Pollution: Development proposals must be designed to protect, and where possible, improve upon the amenities of existing and future residents, occupiers of buildings and the environment generally. Development proposals will need to address the criteria contained in, but not limited to, the policies concerning water quality; flood risk and water management; nutrient mitigation; lighting; air quality; noise; and contaminated land. Where development is likely to generate significant adverse impacts by reason of pollution, the council will require that the impacts are minimised and/or mitigated to an acceptable level within appropriate local/national standards, guidance, legislation and/or objectives.
17, P94, 4.127, Light pollution caused by excessive brightness can lead to annoyance, disturbance and impact wildlife, notably nocturnal animals. The design of lighting schemes should be carefully considered in development proposals to prevent light spillage and glare.
18. P94, 4.128, Dark skies are important for the conservation of natural habitats, cultural heritage and astronomy. The plan area includes three 'Dark Sky Discovery Site' designations, all located within the Chichester Harbour AONB; Eames Farm on Thorney Island, Maybush Copse in Chidham; and north of the John Q Davis footpath in West Itchenor. Development within or directly impacting these areas will be subject to particular scrutiny in terms of their impact on dark skies. The entire SDNPA area is also declared as an International Dark Sky Reserve. Development directly impacting this area will be subject to similar scrutiny.
19. P96, Policy NE22 Air Quality
20. P97, Policy NE-23 Noise
21. P142, Para 6.29, Amenity: Private space, shared space and the design quality and construction of communal spaces all contribute to amenity
22. P155-6, Policy P11:Conservation Areas "protecting the setting (including views into and out of the area)"
23, P55, Para 4.26 - The council is under a legal duty to protect designated habitats, by ensuring that new development does not have an adverse impact on important areas of nature conservation, and by requiring mitigation to negate the harm caused.
24. P58, Para 4.33 The council is under a legal duty to protect their designated bird populations and supporting habitats
25. P95, Para 4.129 The council has a duty to review and assess air quality within the district
26. P301, Conservation Area: An area of special architectural or historic interest, designated under the Planning (Listed Buildings & Conservation Areas) Act 1990. There is a statutory duty to preserve or enhance the character, appearance, or setting of these areas.

See attachment.