4.18

The proposed site at Highgrove in policy A11 needs to be removed from the local plan.

The ’strategic wildlife corridors’ referred to are in fact small scale local ones that connect along very small chalk streams of undoubted ecological value including millstreams, but their width and length touching upon the boundaries of SDNP and CHAONB but not interpenetrating them suggests a minimalist approach. When neighbouring Arun are contemplating a wildlife corridor stretching from Clymping Beach to the Ashdown Forest (“Weald to Waves”), the ambition of the CDC plan appears paltry. On one site (Highgrove) the Sussex Biodiversity Record lists in excess of one hundred bird species records alone.

Bellway question whether para 4.18 should state ‘it will be necessary to demonstrate that land within the corridors will not be available for development. Land outside of the corridors will need to demonstrate that it will not have
an adverse impact on the integrity of the corridor?’

See attachment.

Text change to paragraph 4.18:

The Council will apply an additional layer of planning restraint to the countryside protection policies within these strategic wildlife corridors to ensure that connectivity between the South Downs National Park and the Chichester Harbour AONB and Pagham Harbour is maintain in the long term. If a significant
adverse impact on the function of the corridor resulting from a development cannot be avoided (through locating on an alternative site with less harmful impacts), adequately mitigated, or, as a last resort, compensated for, then it will not be permitted.

The wording as drafted fails the NPPF soundness tests, on the basis that: (a) Ecology-led masterplannning can ensure development is accommodated within the SWCs while fully maintaining the functional elements of the corridors; (2) The policy as drafted is also wholly inconsistent within NPPF paragraph 180, it that it only provides for development avoidance measures within the SWCs; and (3) The ‘integrity’ test element of the policy relates to undertaking Appropriate Assessments. The protection afforded within the policy wording must be proportionate to the locally important status of the designation.