Chichester Local Plan 2021 - 2039: Proposed Submission

Support

Representation ID: 4369

Received: 16/03/2023

Respondent: Chichester Harbour Conservancy

Good to reference the AONB and NPPF.

Support and comment noted

Object

Representation ID: 4380

Received: 16/03/2023

Respondent: Chichester Harbour Conservancy

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? Not specified

Whilst the Conservancy cannot Object to the Wildlife Corridors, it is really disappointing that they are not more ambitious with greater geographical coverage. Given that the Council has set the parameters for considering future development proposals therein NE4, there was no need to restrict them in quite such a way. Where are the east-west links? Where are the corridors across the Manhood Peninsula, connecting Pagham Harbour, Medmerry and Chichester Harbour? What is proposed is a starter for 10, but we living in a biodiversity crisis, so I think we needed a bit more coverage than the proposed.

Comment noted. The Council considers that the policy is ambitious as it is the first proposed of its kind across the country. The width and coverage of the corridors needs to be based on technical information relating to location and presence of species. In the absence of further evidence it is not considered justified to widen corridors. The corridors have, in the first instance, been established to link functional habitat between and within the South Downs National Park and Chichester Harbour AONB, as the east-west corridor is the location subject to the greatest development pressure. This does not preclude the future identification of further wildlife corridors in this location, or elsewhere within the Plan area.

Object

Representation ID: 4396

Received: 16/03/2023

Respondent: Chichester Harbour Conservancy

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? Not specified

Excellent work. Just don't go too far in making it too prescriptive - otherwise we will not make progress in terms of addressing climate change. This is the key sentence, "All development proposals for a renewable energy generation scheme should, as far as is practicable, provide for the site to be reinstated to its former condition should the development cease to be operational, though having regard to any new habitats created on the site in the interim." As long as sites can be returned to their former use, we should be encouraging renewables (almost) as much as possible.

Comment noted and change made in supporting text recognising that development sites could be returned to original use if renewable technology no longer required

Object

Representation ID: 4398

Received: 16/03/2023

Respondent: Chichester Harbour Conservancy

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? Not specified

"Chichester Harbour Conservancy's Chichester Harbour AONB Management Plan (the Management Plan)." This factually incorrect. It is not the Conservancy's AONB Management Plan. We prepare it on behalf of the Local Authorities, and is therefore Chichester District Council's Management Plan for Chichester Harbour. The other LAs are WSCC, HCC and HBC.

Suggested change to reference to the AONB Management Plan agreed. Amendment also proposed in relation to paragraph 4.9 to include reference to character and setting of AONB.

Object

Representation ID: 4401

Received: 16/03/2023

Respondent: Chichester Harbour Conservancy

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

"Development will also be expected to make a positive contribution to the ecological network, providing biodiversity net gain on site, and where this is not achievable locally off-site." I do not know what "locally" means? It would be a concern if BNG for one site is located elsewhere in the District. Suggest you focus BNG on the Wildlife Corridors, the AONB, SSSIs, LNRs, NNRs, SACs, SPAs, Medmerry, etc. - the natural environment sites that need the help most.

Objection noted. Further to paragraph 4.20, Point 1. c) of Policy NE5 clarifies that local off-site provision should contribute towards strategic networks such as green infrastructure, wildlife corridors or nature recovery networks. It is considered this makes clear that BNG should be located where it is needed most, within strategically significant areas.

Support

Representation ID: 4406

Received: 16/03/2023

Respondent: Chichester Harbour Conservancy

This seems comprehensive. It is a shame that C. does not include the AONB as well, but I understand the reasons.

Support and comment noted.

Support

Representation ID: 4408

Received: 16/03/2023

Respondent: Chichester Harbour Conservancy

An important Policy.

Support and comment noted

Object

Representation ID: 4411

Received: 16/03/2023

Respondent: Chichester Harbour Conservancy

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? Not specified

I think you should reference the 2021 SSSI Condition Review of Chichester Harbour here.

Objection and proposed change noted. We will consider a minor modification to 4.34 to reference the condition review, which is also listed in the Local Plan evidence.

Object

Representation ID: 4413

Received: 16/03/2023

Respondent: Chichester Harbour Conservancy

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? Not specified

"They should also have regard to the Chichester Harbour AONB Management Plan." 1) I don't think it is enough to "have regard to". Please change to "meet the policy aims of..". I can have regard for someone else - but so what? It doesn't mean anything. Please tighten the wording up. 2) What does "They should" mean? Who is They? - Regardless, I think the sentence needs revising, but don't delete it.

Objection and proposed change noted. We recognise that the Government response to the Glover Landscape Review considers a strengthening of AONB management plan duties, but in the absence of anticipated guidance on this matter, any heightened status is undefined, bringing uncertainty in relation to interpretation. The use of proposed wording ‘have regard to the Chichester AONB Management Plan’ is considered to be consistent with current national guidance relating to the designation and management of AONBs, and is therefore considered appropriate in this context.

Object

Representation ID: 4444

Received: 16/03/2023

Respondent: Chichester Harbour Conservancy

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

"In order to protect the landscape, character, quality and tranquillity of the countryside it is essential to prevent inappropriate development." A Planning Barrister once told me that "inappropriate development" doesn't mean anything. I would recommend the term of replaced with something that has some sort of legal and/or recognised status.

“Inappropriate development” and “characteristics” are terms used within the NPPF. However, to emphasise the Harbours as separate entities, wording has been changed.