Chichester Local Plan 2021 - 2039: Proposed Submission
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Chichester Local Plan 2021 - 2039: Proposed Submission
Policy E10 Equestrian Development
Representation ID: 5861
Received: 17/03/2023
Respondent: Natural England
Following our advice given in November 2021 we are pleased to note the inclusion of an additional policy requirement (9) relating to consideration of biodiversity impacts and the provision of biodiversity net gain.
Summary of advice
While we have raised some queries and recommended some further modifications to certain policies we do not find the Plan unsound on any grounds relating to our remit.
Natural England has reviewed the Proposed Submission Local Plan and accompanying appendices together with the Habitats Regulations Assessment (HRA) and Sustainability Appraisal (SA). Our detailed comments on the policies and site allocations are provided as follows:
• Annex 1 - Chapter 2 – Vision and Strategic Objectives
• Annex 2 - Chapter 4 – Climate Change and the Natural Environment
• Annex 3 - Chapter 5 (Housing) and Chapter 6 – (Place-making, Health and Well-being)
• Annex 4 - Chapter 7 (Employment and Economy) and Chapter 8 (Transport and
Accessibility)
• Annex 5 - Chaper 10 – Strategic and Area Based Policies
Please note that we have not provided comments on all policies but those which have most influence on environmental issues. Natural England has no comment to make on the policies not covered in this response. Other than confirming that we have referred to it when considering our advice on specific policies and site allocations Natural England has no general comments to make on the SA.
Unfortunately due to unforeseen resourcing issues while we have reviewed the associated HRA we are not in a position to provide detailed comment on it as part of this response. We will rectify this as soon as possible and can confirm that we have seen nothing in it that raises any major concerns.
The Plan has many positive aspects including standalone policies on Green Infrastructure (GI) and
wildlife corridors and an incredibly extensive suite of natural environment policies more generally.
We are hugely appreciative of the opportunity that we were given to work with you on shaping key policies post-Regulation 18. However, we believe that the plan needs to go further in it’s recognition of coastal squeeze as a key issue for the district, should include policy hooks for the forthcoming Local Nature Recovery Strategy (LNRS) and make up to date references to both the Environment Act (2021) and the Environmental Improvement Plan (EIP, 2023). Given how recent the publication of the EIP is we would be happy to discuss with your authority how this could best be achieved but
we believe given the wealth of natural capital within Chichester District it is vitally important that this latest iteration of the Local Plan is set in its full policy and legislative context.
We have suggested a significant number of amendments and additions to both policies and
supporting text throughout the Plan. In our view these could all be taken forward as minor modifications but if they were all acted upon they would leave the Plan much stronger and more coherent in delivering for the natural environment, one of the three central tenets of genuinely
sustainable development as set out in the National Planning Policy Framework (NPPF 2021,
paragraph 8c).
See attachment for representations on paragraphs/policies.
Support noted
Support
Chichester Local Plan 2021 - 2039: Proposed Submission
Policy T1: Transport Infrastructure
Representation ID: 5862
Received: 17/03/2023
Respondent: Natural England
Natural England welcomes the extensive references across this policy (and policies T2 and T3) to reductions in car use, increased provision of sustainable transport choices and increased opportunities for active travel.
Summary of advice
While we have raised some queries and recommended some further modifications to certain policies we do not find the Plan unsound on any grounds relating to our remit.
Natural England has reviewed the Proposed Submission Local Plan and accompanying appendices together with the Habitats Regulations Assessment (HRA) and Sustainability Appraisal (SA). Our detailed comments on the policies and site allocations are provided as follows:
• Annex 1 - Chapter 2 – Vision and Strategic Objectives
• Annex 2 - Chapter 4 – Climate Change and the Natural Environment
• Annex 3 - Chapter 5 (Housing) and Chapter 6 – (Place-making, Health and Well-being)
• Annex 4 - Chapter 7 (Employment and Economy) and Chapter 8 (Transport and
Accessibility)
• Annex 5 - Chaper 10 – Strategic and Area Based Policies
Please note that we have not provided comments on all policies but those which have most influence on environmental issues. Natural England has no comment to make on the policies not covered in this response. Other than confirming that we have referred to it when considering our advice on specific policies and site allocations Natural England has no general comments to make on the SA.
Unfortunately due to unforeseen resourcing issues while we have reviewed the associated HRA we are not in a position to provide detailed comment on it as part of this response. We will rectify this as soon as possible and can confirm that we have seen nothing in it that raises any major concerns.
The Plan has many positive aspects including standalone policies on Green Infrastructure (GI) and
wildlife corridors and an incredibly extensive suite of natural environment policies more generally.
We are hugely appreciative of the opportunity that we were given to work with you on shaping key policies post-Regulation 18. However, we believe that the plan needs to go further in it’s recognition of coastal squeeze as a key issue for the district, should include policy hooks for the forthcoming Local Nature Recovery Strategy (LNRS) and make up to date references to both the Environment Act (2021) and the Environmental Improvement Plan (EIP, 2023). Given how recent the publication of the EIP is we would be happy to discuss with your authority how this could best be achieved but
we believe given the wealth of natural capital within Chichester District it is vitally important that this latest iteration of the Local Plan is set in its full policy and legislative context.
We have suggested a significant number of amendments and additions to both policies and
supporting text throughout the Plan. In our view these could all be taken forward as minor modifications but if they were all acted upon they would leave the Plan much stronger and more coherent in delivering for the natural environment, one of the three central tenets of genuinely
sustainable development as set out in the National Planning Policy Framework (NPPF 2021,
paragraph 8c).
See attachment for representations on paragraphs/policies.
Support
Chichester Local Plan 2021 - 2039: Proposed Submission
Policy T2 Transport and Development
Representation ID: 5863
Received: 17/03/2023
Respondent: Natural England
Natural England welcomes the extensive references across this policy (and policies T2 and T3) to reductions in car use, increased provision of sustainable transport choices and increased opportunities for active travel.
Summary of advice
While we have raised some queries and recommended some further modifications to certain policies we do not find the Plan unsound on any grounds relating to our remit.
Natural England has reviewed the Proposed Submission Local Plan and accompanying appendices together with the Habitats Regulations Assessment (HRA) and Sustainability Appraisal (SA). Our detailed comments on the policies and site allocations are provided as follows:
• Annex 1 - Chapter 2 – Vision and Strategic Objectives
• Annex 2 - Chapter 4 – Climate Change and the Natural Environment
• Annex 3 - Chapter 5 (Housing) and Chapter 6 – (Place-making, Health and Well-being)
• Annex 4 - Chapter 7 (Employment and Economy) and Chapter 8 (Transport and
Accessibility)
• Annex 5 - Chaper 10 – Strategic and Area Based Policies
Please note that we have not provided comments on all policies but those which have most influence on environmental issues. Natural England has no comment to make on the policies not covered in this response. Other than confirming that we have referred to it when considering our advice on specific policies and site allocations Natural England has no general comments to make on the SA.
Unfortunately due to unforeseen resourcing issues while we have reviewed the associated HRA we are not in a position to provide detailed comment on it as part of this response. We will rectify this as soon as possible and can confirm that we have seen nothing in it that raises any major concerns.
The Plan has many positive aspects including standalone policies on Green Infrastructure (GI) and
wildlife corridors and an incredibly extensive suite of natural environment policies more generally.
We are hugely appreciative of the opportunity that we were given to work with you on shaping key policies post-Regulation 18. However, we believe that the plan needs to go further in it’s recognition of coastal squeeze as a key issue for the district, should include policy hooks for the forthcoming Local Nature Recovery Strategy (LNRS) and make up to date references to both the Environment Act (2021) and the Environmental Improvement Plan (EIP, 2023). Given how recent the publication of the EIP is we would be happy to discuss with your authority how this could best be achieved but
we believe given the wealth of natural capital within Chichester District it is vitally important that this latest iteration of the Local Plan is set in its full policy and legislative context.
We have suggested a significant number of amendments and additions to both policies and
supporting text throughout the Plan. In our view these could all be taken forward as minor modifications but if they were all acted upon they would leave the Plan much stronger and more coherent in delivering for the natural environment, one of the three central tenets of genuinely
sustainable development as set out in the National Planning Policy Framework (NPPF 2021,
paragraph 8c).
See attachment for representations on paragraphs/policies.
Noted.
Support
Chichester Local Plan 2021 - 2039: Proposed Submission
Policy T3 Active Travel - Walking and Cycling Provision
Representation ID: 5865
Received: 17/03/2023
Respondent: Natural England
Natural England welcomes the extensive references across this policy (and policies T2 and T3) to reductions in car use, increased provision of sustainable transport choices and increased opportunities for active travel.
Summary of advice
While we have raised some queries and recommended some further modifications to certain policies we do not find the Plan unsound on any grounds relating to our remit.
Natural England has reviewed the Proposed Submission Local Plan and accompanying appendices together with the Habitats Regulations Assessment (HRA) and Sustainability Appraisal (SA). Our detailed comments on the policies and site allocations are provided as follows:
• Annex 1 - Chapter 2 – Vision and Strategic Objectives
• Annex 2 - Chapter 4 – Climate Change and the Natural Environment
• Annex 3 - Chapter 5 (Housing) and Chapter 6 – (Place-making, Health and Well-being)
• Annex 4 - Chapter 7 (Employment and Economy) and Chapter 8 (Transport and
Accessibility)
• Annex 5 - Chaper 10 – Strategic and Area Based Policies
Please note that we have not provided comments on all policies but those which have most influence on environmental issues. Natural England has no comment to make on the policies not covered in this response. Other than confirming that we have referred to it when considering our advice on specific policies and site allocations Natural England has no general comments to make on the SA.
Unfortunately due to unforeseen resourcing issues while we have reviewed the associated HRA we are not in a position to provide detailed comment on it as part of this response. We will rectify this as soon as possible and can confirm that we have seen nothing in it that raises any major concerns.
The Plan has many positive aspects including standalone policies on Green Infrastructure (GI) and
wildlife corridors and an incredibly extensive suite of natural environment policies more generally.
We are hugely appreciative of the opportunity that we were given to work with you on shaping key policies post-Regulation 18. However, we believe that the plan needs to go further in it’s recognition of coastal squeeze as a key issue for the district, should include policy hooks for the forthcoming Local Nature Recovery Strategy (LNRS) and make up to date references to both the Environment Act (2021) and the Environmental Improvement Plan (EIP, 2023). Given how recent the publication of the EIP is we would be happy to discuss with your authority how this could best be achieved but
we believe given the wealth of natural capital within Chichester District it is vitally important that this latest iteration of the Local Plan is set in its full policy and legislative context.
We have suggested a significant number of amendments and additions to both policies and
supporting text throughout the Plan. In our view these could all be taken forward as minor modifications but if they were all acted upon they would leave the Plan much stronger and more coherent in delivering for the natural environment, one of the three central tenets of genuinely
sustainable development as set out in the National Planning Policy Framework (NPPF 2021,
paragraph 8c).
See attachment for representations on paragraphs/policies.
Support noted
Support
Chichester Local Plan 2021 - 2039: Proposed Submission
10.1
Representation ID: 5867
Received: 17/03/2023
Respondent: Natural England
Natural England has reviewed all proposed housing and employment site allocations using our inhouse mapping system and greatly appreciate your authority sharing the shapefiles with us to make this possible. We do not object to any of the site allocations.
We note that where relevant policies include requirements relating to the natural environment (including protected sites), wildlife corridors, Biodiversity Net Gain, GI, SuDs, waste water/nutrient neutrality and protected landscape considerations and fully support this approach.
We appreciate that in a number of cases our advice
on specific site allocations at the statutory Regulation 18 stage has been incorporated into these requirements.
We further note that a number of the policies A2 (Chichester City), A12 (Chidham and Hambrook), A13 (Southbourne) and A15 (Loxwood) simply allocate broad locations for development at this stage with further detail on specific sites to come via either a Neighbourhood
Plan or an updated Site Allocations document. This makes it difficult to provide detailed advice on potential impacts at this stage but the policy requirements provided thus far appear reasonable.
Summary of advice
While we have raised some queries and recommended some further modifications to certain policies we do not find the Plan unsound on any grounds relating to our remit.
Natural England has reviewed the Proposed Submission Local Plan and accompanying appendices together with the Habitats Regulations Assessment (HRA) and Sustainability Appraisal (SA). Our detailed comments on the policies and site allocations are provided as follows:
• Annex 1 - Chapter 2 – Vision and Strategic Objectives
• Annex 2 - Chapter 4 – Climate Change and the Natural Environment
• Annex 3 - Chapter 5 (Housing) and Chapter 6 – (Place-making, Health and Well-being)
• Annex 4 - Chapter 7 (Employment and Economy) and Chapter 8 (Transport and
Accessibility)
• Annex 5 - Chaper 10 – Strategic and Area Based Policies
Please note that we have not provided comments on all policies but those which have most influence on environmental issues. Natural England has no comment to make on the policies not covered in this response. Other than confirming that we have referred to it when considering our advice on specific policies and site allocations Natural England has no general comments to make on the SA.
Unfortunately due to unforeseen resourcing issues while we have reviewed the associated HRA we are not in a position to provide detailed comment on it as part of this response. We will rectify this as soon as possible and can confirm that we have seen nothing in it that raises any major concerns.
The Plan has many positive aspects including standalone policies on Green Infrastructure (GI) and
wildlife corridors and an incredibly extensive suite of natural environment policies more generally.
We are hugely appreciative of the opportunity that we were given to work with you on shaping key policies post-Regulation 18. However, we believe that the plan needs to go further in it’s recognition of coastal squeeze as a key issue for the district, should include policy hooks for the forthcoming Local Nature Recovery Strategy (LNRS) and make up to date references to both the Environment Act (2021) and the Environmental Improvement Plan (EIP, 2023). Given how recent the publication of the EIP is we would be happy to discuss with your authority how this could best be achieved but
we believe given the wealth of natural capital within Chichester District it is vitally important that this latest iteration of the Local Plan is set in its full policy and legislative context.
We have suggested a significant number of amendments and additions to both policies and
supporting text throughout the Plan. In our view these could all be taken forward as minor modifications but if they were all acted upon they would leave the Plan much stronger and more coherent in delivering for the natural environment, one of the three central tenets of genuinely
sustainable development as set out in the National Planning Policy Framework (NPPF 2021,
paragraph 8c).
See attachment for representations on paragraphs/policies.
Support noted
Object
Chichester Local Plan 2021 - 2039: Proposed Submission
Policy A8 Land East of Chichester
Representation ID: 5868
Received: 17/03/2023
Respondent: Natural England
Legally compliant? Not specified
Sound? Yes
Duty to co-operate? Not specified
We have been given to understand that the Pagham to Westhampnett Strategic Wildlife Corridor (Policy NE4) has been modified and narrowed (presumably to take account of allocation A8 and potentially also A7) at some point between the technical consultation that was run for the wildlife corridors in 2021 and the publication of this pre-submission plan. We would welcome a conversation
with your authority to explore whether this is correct.
We note that Requirement 6 of Policy A8 does require buffering of this corridor. However, given that our Regulation 18 advice (in 2019) was that some of the corridors were already rather narrow (particularly to the east of Chichester), thus limiting their value, we are concerned at the possibly that one of these corridors has been further reduced in order to accommodate development.
If this is genuinely the case we would like to see the red-line boundary for the allocation site pushed back and the corridor restored to its original
extent.
Summary of advice
While we have raised some queries and recommended some further modifications to certain policies we do not find the Plan unsound on any grounds relating to our remit.
Natural England has reviewed the Proposed Submission Local Plan and accompanying appendices together with the Habitats Regulations Assessment (HRA) and Sustainability Appraisal (SA). Our detailed comments on the policies and site allocations are provided as follows:
• Annex 1 - Chapter 2 – Vision and Strategic Objectives
• Annex 2 - Chapter 4 – Climate Change and the Natural Environment
• Annex 3 - Chapter 5 (Housing) and Chapter 6 – (Place-making, Health and Well-being)
• Annex 4 - Chapter 7 (Employment and Economy) and Chapter 8 (Transport and
Accessibility)
• Annex 5 - Chaper 10 – Strategic and Area Based Policies
Please note that we have not provided comments on all policies but those which have most influence on environmental issues. Natural England has no comment to make on the policies not covered in this response. Other than confirming that we have referred to it when considering our advice on specific policies and site allocations Natural England has no general comments to make on the SA.
Unfortunately due to unforeseen resourcing issues while we have reviewed the associated HRA we are not in a position to provide detailed comment on it as part of this response. We will rectify this as soon as possible and can confirm that we have seen nothing in it that raises any major concerns.
The Plan has many positive aspects including standalone policies on Green Infrastructure (GI) and
wildlife corridors and an incredibly extensive suite of natural environment policies more generally.
We are hugely appreciative of the opportunity that we were given to work with you on shaping key policies post-Regulation 18. However, we believe that the plan needs to go further in it’s recognition of coastal squeeze as a key issue for the district, should include policy hooks for the forthcoming Local Nature Recovery Strategy (LNRS) and make up to date references to both the Environment Act (2021) and the Environmental Improvement Plan (EIP, 2023). Given how recent the publication of the EIP is we would be happy to discuss with your authority how this could best be achieved but
we believe given the wealth of natural capital within Chichester District it is vitally important that this latest iteration of the Local Plan is set in its full policy and legislative context.
We have suggested a significant number of amendments and additions to both policies and
supporting text throughout the Plan. In our view these could all be taken forward as minor modifications but if they were all acted upon they would leave the Plan much stronger and more coherent in delivering for the natural environment, one of the three central tenets of genuinely
sustainable development as set out in the National Planning Policy Framework (NPPF 2021,
paragraph 8c).
See attachment for representations on paragraphs/policies.
Comment noted. This comment appears to relate primarily to the Westhampnett-Pagham Strategic Wildlife Corridor. See response to representation 6109.
Object
Chichester Local Plan 2021 - 2039: Proposed Submission
Policy A12 Chidham and Hambrook
Representation ID: 6010
Received: 03/05/2023
Respondent: Natural England
Legally compliant? Not specified
Sound? Not specified
Duty to co-operate? Not specified
[RECEIVED LATE]
Requirement 6 in policy A12 (Chidham and Hambrook) currently goes straight to “successfully mitigate” while requirement 10 in policy A13 (Southbourne) states “Provide mitigation to ensure the avoidance of adverse effects on the SPA, SAC and Ramsar site at Chichester Harbour.” Policy A18 (Thorney Island) is better as it states “Proposals must avoid adverse impacts on the Chichester Harbour AONB/SAC/SPA and Ramsar designations.” Suggest that all policies require development proposals to ‘avoid, and if necessary mitigate, any adverse effects…’
Advise wording in ‘Broad Location for Development’ policies for Chidham and Hambrook (A12) and Southbourne (A13) be strengthened to better reflect the mitigation hierarchy. Suggest that all policies require development proposals to ‘avoid, and if necessary mitigate, any adverse effects…’
See attachment.
Agree amend wording of criterion 6
Object
Chichester Local Plan 2021 - 2039: Proposed Submission
Policy A13 Southbourne Broad Location for Development
Representation ID: 6011
Received: 03/05/2023
Respondent: Natural England
Legally compliant? Not specified
Sound? Not specified
Duty to co-operate? Not specified
[RECEIVED LATE]
Requirement 6 in policy A12 (Chidham and Hambrook) currently goes straight to “successfully mitigate” while requirement 10 in policy A13 (Southbourne) states “Provide mitigation to ensure the avoidance of adverse effects on the SPA, SAC and Ramsar site at Chichester Harbour.” Policy A18 (Thorney Island) is better as it states “Proposals must avoid adverse impacts on the Chichester Harbour AONB/SAC/SPA and Ramsar designations.” We would suggest that all policies require development proposals to ‘avoid, and if necessary mitigate, any adverse effects…’
Advise wording in ‘Broad Location for Development’ policies for Chidham and Hambrook (A12) and Southbourne (A13) be strengthened to better reflect the mitigation hierarchy. Suggest that all policies require development proposals to ‘avoid, and if necessary mitigate, any adverse effects…’
See attachment.
It is agreed that the wording of the criterion should be clarified as suggested.
Support
Chichester Local Plan 2021 - 2039: Proposed Submission
Policy NE2 Natural Landscape
Representation ID: 6108
Received: 17/03/2023
Respondent: Natural England
Natural England supports this policy particularly in respect of criteria 1 and 2, which seek to protect and enhance the views and distinctive landscape character in and around the coast and nationally designated sites, including Chichester Harbour AONB and South Downs National Park, and their settings.
Natural England welcome reference to our guidance on Landscape Character Areas (para 4.7) and our guidance assessments of development proposal on agricultural land (para 4.8). We welcome the requirements that development proposals must meet the criteria contained in other relevant policies on landscape.
Summary of advice
While we have raised some queries and recommended some further modifications to certain policies we do not find the Plan unsound on any grounds relating to our remit.
Natural England has reviewed the Proposed Submission Local Plan and accompanying appendices together with the Habitats Regulations Assessment (HRA) and Sustainability Appraisal (SA). Our detailed comments on the policies and site allocations are provided as follows:
• Annex 1 - Chapter 2 – Vision and Strategic Objectives
• Annex 2 - Chapter 4 – Climate Change and the Natural Environment
• Annex 3 - Chapter 5 (Housing) and Chapter 6 – (Place-making, Health and Well-being)
• Annex 4 - Chapter 7 (Employment and Economy) and Chapter 8 (Transport and
Accessibility)
• Annex 5 - Chaper 10 – Strategic and Area Based Policies
Please note that we have not provided comments on all policies but those which have most influence on environmental issues. Natural England has no comment to make on the policies not covered in this response. Other than confirming that we have referred to it when considering our advice on specific policies and site allocations Natural England has no general comments to make on the SA.
Unfortunately due to unforeseen resourcing issues while we have reviewed the associated HRA we are not in a position to provide detailed comment on it as part of this response. We will rectify this as soon as possible and can confirm that we have seen nothing in it that raises any major concerns.
The Plan has many positive aspects including standalone policies on Green Infrastructure (GI) and
wildlife corridors and an incredibly extensive suite of natural environment policies more generally.
We are hugely appreciative of the opportunity that we were given to work with you on shaping key policies post-Regulation 18. However, we believe that the plan needs to go further in it’s recognition of coastal squeeze as a key issue for the district, should include policy hooks for the forthcoming Local Nature Recovery Strategy (LNRS) and make up to date references to both the Environment Act (2021) and the Environmental Improvement Plan (EIP, 2023). Given how recent the publication of the EIP is we would be happy to discuss with your authority how this could best be achieved but
we believe given the wealth of natural capital within Chichester District it is vitally important that this latest iteration of the Local Plan is set in its full policy and legislative context.
We have suggested a significant number of amendments and additions to both policies and
supporting text throughout the Plan. In our view these could all be taken forward as minor modifications but if they were all acted upon they would leave the Plan much stronger and more coherent in delivering for the natural environment, one of the three central tenets of genuinely
sustainable development as set out in the National Planning Policy Framework (NPPF 2021,
paragraph 8c).
See attachment for representations on paragraphs/policies.
Support and comment noted
Object
Chichester Local Plan 2021 - 2039: Proposed Submission
Policy NE4 Strategic Wildlife Corridors
Representation ID: 6109
Received: 17/03/2023
Respondent: Natural England
Legally compliant? Not specified
Sound? Yes
Duty to co-operate? Not specified
While Natural England strongly supports this policy, we would also like to propose the following modifications to make the policy even stronger:
Given the importance of the area for bats we would encourage reference in the supporting text to the Draft Sussex Bat Special Area of Conservation Planning and Landscape Scale Enhancement Protocol (2018).
Point 1. should be expanded to state “There are no sequentially preferable sites available outside the wildlife corridor that also do not compromise the integrity and connectivity of sites, as identified through the LNRS”
We would query whether the policy could be more explicit about development that could impact the corridors given that the potential for impact is likely to vary significantly depending on the scale and nature of the development in question. What exactly is “close proximity?” We would certainly appreciate a discussion with you about how this policy will be applied in practice to development management applications.
The final sentence should be expanded to “All proposals for new development (with the exception of householder applications) within or in close proximity to wildlife corridors should take opportunities available in order to extend and enhance those corridors and have regard to opportunities identified in nature recovery strategies.
Summary of advice
While we have raised some queries and recommended some further modifications to certain policies we do not find the Plan unsound on any grounds relating to our remit.
Natural England has reviewed the Proposed Submission Local Plan and accompanying appendices together with the Habitats Regulations Assessment (HRA) and Sustainability Appraisal (SA). Our detailed comments on the policies and site allocations are provided as follows:
• Annex 1 - Chapter 2 – Vision and Strategic Objectives
• Annex 2 - Chapter 4 – Climate Change and the Natural Environment
• Annex 3 - Chapter 5 (Housing) and Chapter 6 – (Place-making, Health and Well-being)
• Annex 4 - Chapter 7 (Employment and Economy) and Chapter 8 (Transport and
Accessibility)
• Annex 5 - Chaper 10 – Strategic and Area Based Policies
Please note that we have not provided comments on all policies but those which have most influence on environmental issues. Natural England has no comment to make on the policies not covered in this response. Other than confirming that we have referred to it when considering our advice on specific policies and site allocations Natural England has no general comments to make on the SA.
Unfortunately due to unforeseen resourcing issues while we have reviewed the associated HRA we are not in a position to provide detailed comment on it as part of this response. We will rectify this as soon as possible and can confirm that we have seen nothing in it that raises any major concerns.
The Plan has many positive aspects including standalone policies on Green Infrastructure (GI) and
wildlife corridors and an incredibly extensive suite of natural environment policies more generally.
We are hugely appreciative of the opportunity that we were given to work with you on shaping key policies post-Regulation 18. However, we believe that the plan needs to go further in it’s recognition of coastal squeeze as a key issue for the district, should include policy hooks for the forthcoming Local Nature Recovery Strategy (LNRS) and make up to date references to both the Environment Act (2021) and the Environmental Improvement Plan (EIP, 2023). Given how recent the publication of the EIP is we would be happy to discuss with your authority how this could best be achieved but
we believe given the wealth of natural capital within Chichester District it is vitally important that this latest iteration of the Local Plan is set in its full policy and legislative context.
We have suggested a significant number of amendments and additions to both policies and
supporting text throughout the Plan. In our view these could all be taken forward as minor modifications but if they were all acted upon they would leave the Plan much stronger and more coherent in delivering for the natural environment, one of the three central tenets of genuinely
sustainable development as set out in the National Planning Policy Framework (NPPF 2021,
paragraph 8c).
See attachment for representations on paragraphs/policies.
Support noted. Agree the inclusion of reference to the Draft Sussex Bat Special Area of Conservation Planning and Landscape Scale Enhancement Protocol. The policy will be modified to remove the sequential test part.
