Chichester Local Plan 2021 - 2039: Proposed Submission

Support

Representation ID: 5037

Received: 16/03/2023

Respondent: Sussex Wildlife Trust

SWT supports the inclusion of Objective 1: Climate change, and Objective 2: Natural Environment. Since the 2018 preferred options consultation we have seen the royal assent of the Environment Act 2021, which supports nature’s recovery. Recognising the role that this plan and its policies can play in restoring the natural environment is fundamental for sustainable development, as per National Planning Policy Guidance ( NPPG) Paragraph: 003 Reference ID: 6-003-20140612

Support noted

Object

Representation ID: 5039

Received: 16/03/2023

Respondent: Sussex Wildlife Trust

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? Not specified

Plan should seek to demonstrate how delivery of Nature Recovery Network and more localised Local Nature Recovery Strategies are going to be incorporated in the spatial element of identifying allocations for development, consistent with s179 of NPPF 2021. Planning for nature’s recovery will be vital to support ambitions of plan. In relation to Objective 2: Natural Environment, it will be vital for the spatial element of the Plan to consider how this is achieved through its own actions and also policy hooks. This will enable the emerging Local Nature Recovery Strategy to work effectively with the Local Plan and be a key driver for nature’s recovery over the lifetime of the plan (NPPG Paragraph: 010). SWT is supportive of CDC already taking progressive action with the identification and inclusion of Strategic Wildlife Corridors, consistent with section 179 of NPPF 2021.

Biodiversity opportunity areas and nature recovery strategies are covered by the strategic natural environment policies, in particular Policy NE5 (Biodiversity and Biodiversity Net Gain).

Object

Representation ID: 5042

Received: 16/03/2023

Respondent: Sussex Wildlife Trust

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

SWT supports CDC’s decision to identify and map Strategic Wildlife Corridors although objects to policy on grounds that following further consultation on the Strategic Wildlife Corridors in 2021, there is a narrowing of the Pagham to Westhampnett Strategic Wildlife Corridor around the location of the proposed allocation of A8, Land East of Chichester - no information presented by CDC prior to Regulation 19 consultation or within draft Plan that provides justification for the narrowing. CDC to provide justification for amendment given previous submission of evidence and confirm if further amendments have been made to Strategic Wildlife Corridor network since 2021 consultation. Environment Act 2021 will require production of a Nature Recovery Network/Local Nature Recovery Strategy. Strategic Wildlife Corridors will be integral components of that local network (see NPPG Paragraph: 012). Other policies interact or overlay with the Strategic Wildlife Corridors; ie. Policy E3 Addressing Horticultural Needs. Suggest Policy NE4 makes it clear that not only should development protect and enhance features of Strategic Wildlife Corridors, but that it should also seek to restore them as per 179 of the NPPF 2021. Unclear what the definition of a sequentially preferable site is - CDC should clarify this.

Comment noted. The justification for the amendments to the corridors is set out in the Strategic Wildlife Corridors Background Paper.

The policy will be amended to remove the sequential test.

Modifications to Policy E3 are proposed which would ensure that there is no overlap of the proposed extension to the Runction HDA with the Westhampnett-Pagham Strategic Wildlife Corridor.

Object

Representation ID: 5043

Received: 16/03/2023

Respondent: Sussex Wildlife Trust

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? Not specified

Proposes changes to ensure consistency with the NPPF and NPPG. Proposes a more ambitious target for BNG for major development sites. Urges CDC to consider how BNG will be addressed for phased development.

We also ask if CDC has considered a more ambitious target for BNG on its major development sites? We draw CDC’s attention to the adopted biodiversity policy (DM18) within the Worthing Local Plan, which seeks to achieve 20% BNG on previously developed sites.

In Chapter 10 some allocations reference phased development, we encourage CDC to consider how BNG will be addressed in this approach in terms of delivery, to ensure that it comes forward in a proportionate and timely way.

Proposed changes noted. i) We will consider minor modifications as proposed at E. and 3e)i. to ensure consistency with NPPF and NPPG. ii) Whilst we would encourage biodiversity net gains above the mandatory requirement, including for major sites, we anticipate that viability constraints may hinder our increasing of the minimum percentage above 10% due to the cumulative impact of other developer contributions within the district. These contributions are inclusive of measures which offer biodiversity benefits and mitigations to impacts of development within the Local Plan Area. We therefore consider our position reasonable in that the legislated minimum BNG requirements would be imposed in conjunction with other biodiversity measures.
iii) We will consider the need for a biodiversity plan for each phase of a phased development within proposed guidance for developers. We will consider including a reference to this guidance within the supporting text

Support

Representation ID: 5044

Received: 16/03/2023

Respondent: Sussex Wildlife Trust

SWT supports the inclusion of this policy in the Chichester Local Plan as one of the mechanisms to fulfil the requirement of section 179 of the NPPF.

Support noted

Object

Representation ID: 5046

Received: 16/03/2023

Respondent: Sussex Wildlife Trust

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

We propose that in order to make the policy sound and effective, it should be more specific on referencing that impacts to ancient woodland and veteran trees can be both direct and indirect, as per Paragraph: 033 Reference ID: 8-03320190721 of Planning Policy Guidance.

Suggested amendment agreed.

Object

Representation ID: 5047

Received: 16/03/2023

Respondent: Sussex Wildlife Trust

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

SWT suggests that in order for the policy to be found sound it should include a further bullet point to recognise that development in the countryside must avoid impacts to the natural environment in line with policies in the Chichester Local Plan.

It is proposed that criterion 3 is amended to include reference to biodiversity and nature recovery networks.

Support

Representation ID: 5048

Received: 16/03/2023

Respondent: Sussex Wildlife Trust

We are really encouraged to see the supporting text for this policy and the policy itself state that saltmarsh creation and habitat restoration projects that are identified through project mechanisms will be included in the Infrastructure Business Plan. Capturing areas for habitat restoration and creation enables the integration of nature’s recovery in these more diverse and cross cutting strategies, which will help further embed the delivery of the Defra 25 Year Plan Paragraph: 009 Reference ID: 8-009-20190721

Support noted

Object

Representation ID: 5049

Received: 16/03/2023

Respondent: Sussex Wildlife Trust

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? Not specified

We question whether this could or should be a more ambitious roll back distance, given the sea level rises predicted. We seek clarity from CDC on whether the 16 or 25 metre clearance buffers are a rolling measurement to incorporate continual costal erosion, or if they are measured from a fixed point from the time of the plan publication?

The setback distances have been reviewed in discussion with Natural England and revisions proposed to the policy.

Support

Representation ID: 5050

Received: 16/03/2023

Respondent: Sussex Wildlife Trust

SW supports the inclusion of a policy that seeks to protect the Chichester Harbour Area of Outstanding Natural Beauty. This is consistent with the NPPF section 176 of the NPPF 2021.

Support noted