Chichester Local Plan 2021 - 2039: Proposed Submission

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Object

Chichester Local Plan 2021 - 2039: Proposed Submission

4.51

Representation ID: 4447

Received: 16/03/2023

Respondent: Chichester Harbour Conservancy

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Representation Summary:

I think 4.51 is technically incorrect. Chichester Harbour AONB has a list of special 'qualities' (as all AONBs and National Parks do), not 'characteristics'. Furthermore, I am not sure Pagham Harbour has the equivalent list at all.

Change suggested by respondent:

Revise the wording to ensure its accuracy, and try to avoid bundling Chichester Harbour and Pagham Harbour together - they are separate entities.

Full text:

I think 4.51 is technically incorrect. Chichester Harbour AONB has a list of special 'qualities' (as all AONBs and National Parks do), not 'characteristics'. Furthermore, I am not sure Pagham Harbour has the equivalent list at all.


Our response:

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

Object

Chichester Local Plan 2021 - 2039: Proposed Submission

4.63

Representation ID: 4498

Received: 16/03/2023

Respondent: Chichester Harbour Conservancy

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? Not specified

Representation Summary:

..." who manage Chichester Harbour for nature conservation and landscape." Reword to: "for landscape, the occupation of leisure and recreation, and the conservation of nature." This version is technically correct. Also, you might want to mention Coastal Partners here.

Change suggested by respondent:

..." who manage Chichester Harbour for nature conservation and landscape." Reword to: "for landscape, the occupation of leisure and recreation, and the conservation of nature." This version is technically correct. Also, you might want to mention Coastal Partners here.

Full text:

..." who manage Chichester Harbour for nature conservation and landscape." Reword to: "for landscape, the occupation of leisure and recreation, and the conservation of nature." This version is technically correct. Also, you might want to mention Coastal Partners here.


Our response:

Change accepted

Object

Chichester Local Plan 2021 - 2039: Proposed Submission

4.65

Representation ID: 4501

Received: 16/03/2023

Respondent: Chichester Harbour Conservancy

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? Not specified

Representation Summary:

"...Since 'the' designation of the SSSI in 1970, almost half..."

Change suggested by respondent:

"...Since 'the' designation of the SSSI in 1970, almost half..."

Full text:

"...Since 'the' designation of the SSSI in 1970, almost half..."


Our response:

Additional word not considered necessary

Support

Chichester Local Plan 2021 - 2039: Proposed Submission

Policy NE11 The Coast

Representation ID: 4504

Received: 16/03/2023

Respondent: Chichester Harbour Conservancy

Representation Summary:

Good policy.

Full text:

Good policy.


Our response:

Support noted

Object

Chichester Local Plan 2021 - 2039: Proposed Submission

4.75

Representation ID: 4550

Received: 16/03/2023

Respondent: Chichester Harbour Conservancy

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Representation Summary:

The 25 metres rule is likely inadequate. I don't know if this is based on the advice from Natural England, however with sea level rise and increased storminess with climate change, the future rate of erosion will be greater than 0.1m per year. The minimum should be 50m, with a policy preference for 100m. I suspect someone has underestimated the future rate of erosion.

Change suggested by respondent:

Change to 50m.

Full text:

The 25 metres rule is likely inadequate. I don't know if this is based on the advice from Natural England, however with sea level rise and increased storminess with climate change, the future rate of erosion will be greater than 0.1m per year. The minimum should be 50m, with a policy preference for 100m. I suspect someone has underestimated the future rate of erosion.


Our response:

Additional text is proposed to para 4.76
to clarify that the National Coastal Risk Management work of the Environment agency is also a consideration.

Support

Chichester Local Plan 2021 - 2039: Proposed Submission

4.79

Representation ID: 4551

Received: 16/03/2023

Respondent: Chichester Harbour Conservancy

Representation Summary:

Please note that the CHaPRoN partnership will be preparing new Shoreline Defence Guidelines in 2023, with reference to Chichester Harbour AONB. It would be good if the Council could cite this emerging document, and maybe even consider it as a SPD in due course.

Change suggested by respondent:

Add a reference to emerging Shoreline Defence Guidelines and consider adopting them as SPD in future.

Full text:

Please note that the CHaPRoN partnership will be preparing new Shoreline Defence Guidelines in 2023, with reference to Chichester Harbour AONB. It would be good if the Council could cite this emerging document, and maybe even consider it as a SPD in due course.


Our response:

As the guidelines are still being drafted it is not considered necessary to refer to them here

Object

Chichester Local Plan 2021 - 2039: Proposed Submission

4.80

Representation ID: 4553

Received: 16/03/2023

Respondent: Chichester Harbour Conservancy

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Representation Summary:

There's that "inappropriate development" phrase again. I would change it to "...particularly vulnerable to visual intrusion from urbanisation, both within or adjacent to the boundary."

Change suggested by respondent:

Change "inappropriate development" to "urbanisation".

Full text:

There's that "inappropriate development" phrase again. I would change it to "...particularly vulnerable to visual intrusion from urbanisation, both within or adjacent to the boundary."


Our response:

Agreed

Object

Chichester Local Plan 2021 - 2039: Proposed Submission

4.81

Representation ID: 4555

Received: 16/03/2023

Respondent: Chichester Harbour Conservancy

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? Not specified

Representation Summary:

Ok, so I would change the word "produced" to "published" in the two instances it is mentioned. The Management Plan was subject to a consultation period of 8 weeks. There are now 19 Planning Principles, not 18. And please keep in mind that the Management Plan expires on 1 April 2024, when it will be replaced by a light touch 12 month Plan. The new 5 year Management Plan will commence from 1 April 2025. Finally, CHaPRoN is working to replace the outdated Sustainable Shorelines: General Guidance document this year.

Change suggested by respondent:

Change produced to published and update references.

Full text:

Ok, so I would change the word "produced" to "published" in the two instances it is mentioned. The Management Plan was subject to a consultation period of 8 weeks. There are now 19 Planning Principles, not 18. And please keep in mind that the Management Plan expires on 1 April 2024, when it will be replaced by a light touch 12 month Plan. The new 5 year Management Plan will commence from 1 April 2025. Finally, CHaPRoN is working to replace the outdated Sustainable Shorelines: General Guidance document this year.


Our response:

Agreed

Object

Chichester Local Plan 2021 - 2039: Proposed Submission

Policy NE13 Chichester Harbour Area of Outstanding Natural Beauty

Representation ID: 4556

Received: 16/03/2023

Respondent: Chichester Harbour Conservancy

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? Not specified

Representation Summary:

Thank you very much including this policy. My only comment is to suggest the 25m is pushed back to 50m.

Change suggested by respondent:

Increase 25m to 50m.

Full text:

Thank you very much including this policy. My only comment is to suggest the 25m is pushed back to 50m.


Our response:

Criterion 6 has been removed from this policy as the setback is covered in NE12 (where amendments are proposed).

Object

Chichester Local Plan 2021 - 2039: Proposed Submission

4.90

Representation ID: 4931

Received: 17/03/2023

Respondent: Chichester Harbour Conservancy

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? Not specified

Representation Summary:

I would mention and explain coastal squeeze here, and cross reference the SSSI Condition Review for Chichester Harbour.

Change suggested by respondent:

I would mention and explain coastal squeeze here, and cross reference the SSSI Condition Review for Chichester Harbour.

Full text:

I would mention and explain coastal squeeze here, and cross reference the SSSI Condition Review for Chichester Harbour.


Our response:

The Council agree that coastal squeeze is an important issue, but given that this is already addressed in policy NE11 there is considered to be no merit in making additional reference to it in the supporting text of NE15

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