Chichester Local Plan 2021 - 2039: Proposed Submission
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Chichester Local Plan 2021 - 2039: Proposed Submission
2.54
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
See attached representation.
Object
Chichester Local Plan 2021 - 2039: Proposed Submission
3.5
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.
SWT wants this section of the draft plan to demonstrate more clearly how the spatial strategy is enabling nature’s recovery. The plan should seek to demonstrate how the delivery of the Nature Recovery Network and the more localised Local Nature Recovery Strategies are going to be incorporated in the spatial element of identifying allocations for development. This would be consistent with section 179 of the National Planning Policy Framework (NPPF) 2021.
See attached representation.
Object
Chichester Local Plan 2021 - 2039: Proposed Submission
Policy NE4 Strategic Wildlife Corridors
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.
SWT proposes an amendment to policy bullet point 2:
2. The development will not have an adverse impact on the integrity and function of the wildlife corridor and protects, enhances and restores its features and habitats.
See attached representation.
Object
Chichester Local Plan 2021 - 2039: Proposed Submission
Policy NE5 Biodiversity and Biodiversity Net Gain
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.
We propose the following amendments to the policy:
Within bullet point e), SWT proposes the addition of the word protected to priority, so that it will be consistent with NPPG Paragraph: 016 Reference ID: 8-016-20190721. With the amendment it would now read:
e) Protected and Priority Habitats and Species.
Point 3 e, we seek the removal of the term where possible at the end of the sentence. This will make it consistent with section 179 of the NPPF 2021. The new bullet point would read as follows;
e) Outside of designated sites:
Development proposals should identify and incorporate opportunities to conserve, restore and recreate priority habitats and ecological networks. Development proposals should take opportunities to contribute and deliver on the aims and objectives of the relevant biodiversity strategies where possible.
See attached representation.
Support
Chichester Local Plan 2021 - 2039: Proposed Submission
Policy NE7 Development and Disturbance of Birds in Chichester and Langstone Harbours, Pagham Harbour, Solent and Dorset Coast Special Protection Areas and Medmerry Compensatory Habitat
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.
See attached representation.
Object
Chichester Local Plan 2021 - 2039: Proposed Submission
Policy NE8 Trees, Hedgerows and Woodlands
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.
This could be addressed by the following amendment to the policy bullet point 2:
2. Development resulting in the direct or indirect loss or deterioration of……
See attached representation.
Object
Chichester Local Plan 2021 - 2039: Proposed Submission
Policy NE10 Development in the Countryside
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.
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.
See attached representation.
Support
Chichester Local Plan 2021 - 2039: Proposed Submission
Policy NE11 The Coast
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
See attached representation.
Object
Chichester Local Plan 2021 - 2039: Proposed Submission
Policy NE12 Development around the Coast
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?
See attached representation.
Support
Chichester Local Plan 2021 - 2039: Proposed Submission
Policy NE13 Chichester Harbour Area of Outstanding Natural Beauty
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.
See attached representation.
