Draft Interim Policy Statement for Housing Development

2.3 With regards to sustainable locations, I would urge the Council to simply rule-out any new developments in Flood Zone 3.

https://flood-map-for-planning.service.gov.uk

I know that a site being in Flood Zone 3 does not necessary mean that no development is possible, but given the climate projections arguments will be made time and again that it is unsustainable.

4.5 In a similar point to the above, future housing development sites should be located well away from the water, to allow the rollback of the coast over the next 80 years. This will allow the creation of new saltmarsh habitat, which has been in severe international decline since records began.

Historic Extent of Saltmarsh at Chichester Harbour (source: Natural England)

1946 717.3 hectares

2016 295.5 hectares

Loss = 59%

Globally, saltmarsh is declining at a rate of about 50%, so it is actually doing worse at Chichester Harbour. That is mainly due to: i) water quality; ii) coastal squeeze, and; iii) climate change / sea level rise.

So in conclusion, sites shouldn’t just be located in relation to existing settlements, but also located with conservation and flood risk in mind.

4.6 The Conservancy has some concerns about density, with regards to the character or the area, flood risk, etc.

6.2 (5) The Conservancy absolutely welcomes the recognition of the importance of protecting long distance views between the AONB and the National Park. Whilst CDC has not cited the Priority Views Study, it could be added as relevant evidence.

6.2 (6) There is a reference to development “in or adjacent” to the Strategic Wildlife Corridors. It is a concern that this is being contemplated. The Conservancy would prefer to blanket protection within the Strategic Wildlife Corridors, and a commitment to a strong buffer zone around them. We would also draw your attention to the emergence of a wider and emerging Chichester Coastal Plan Nature Recovery Area, which will likely include the Strategic Wildlife Corridors, further embedding the good work that the Council started in this regard.

6.2(7) The Conservancy was disappointed that 17/03148/FUL (50 dwellings at Highgrove Farm) was approved in early 2019. This was because the determination relied on assurances from Southern Water about the capacity of waste water provision. Following a subsequent investigation into their practices, Southern Water then pleaded guilty to all 51 charges brought by the Environment Agency in March 2020. Furthermore, it was felt that the impact of the development on the landscape in this case was not given enough weight. Finally, and with a further 250 dwellings now proposed adjacent to the initial 50, there was a sense that the developers should have prepared a plan for the whole site in the first instance, rather than this piecemeal approach.

We would therefore urge the Council to prepare the emerging Local Plan to ensure such issues do happen again.

6.2 (8) There should be recognition that increased insulation in well-designed buildings can reduce overheating. It’s not just about renewable energy, there’s energy conservation to consider as well.

6.2 (9) The Conservancy would welcome Design and Access Statements that account for the needs of less mobile / disabled people.

6.2 (12)It would be a good idea to define what “Where appropriate” means.