Chichester Local Plan 2021 - 2039: Proposed Submission

Object

Representation ID: 5051

Received: 16/03/2023

Respondent: Sussex Wildlife Trust

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? Not specified

SWT asks if this policy sufficiently reflects the impacts of water use by commercial interests, including the horticultural industry. Sustainability and water management must be addressed by all sectors of development.

The first part of the policy, relating to water supply and the 3rd part about water quality and wastewater applies to all forms of development. Criteria a) under the second part of the policy requires non residential uses to achieve 3 credits in BREEAM which is in line with the requirements agreed for the Sussex Resource Zone North. No specific change is suggested to address this point so the change sought is unclear.
The suggested wording change to insert “and operation” into the policy is agreed and can be made as a minor mod.

Object

Representation ID: 5052

Received: 16/03/2023

Respondent: Sussex Wildlife Trust

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? Not specified

With the offsetting schemes or alternative water supplies, will a guarantee for the lifetime of the development be required as part of the water neutrality statement? We do not feel the policy or the supporting text makes that requirement clear. SWT does recognise that the offsetting scheme is still emerging and that the supporting literature around this topic is considerable.

Work on SNOWS (Sussex North Offsetting Water Scheme) remains on-going and further details will emerge as this work progresses. Natural England has worked jointly with the affected authorities to identify an appropriate mitigation strategy.

Object

Representation ID: 5053

Received: 16/03/2023

Respondent: Sussex Wildlife Trust

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? Not specified

On a practical note, when considering the presentation of this policy against the information provided in the Water Neutrality Policy, the Water Neutrality Policy seems to indicate a degree of direction in terms of what the local authority requires as part of the planning application, for example a water neutrality statement. However, this type of detail is not set out in the Nutrient Neutrality Policy, and we question if it might be useful to those applying this policy to their application to have set out in policy the information required for submission.

Information requirements will be set out in the Local List which can be more readily updated if requirements change.

Support

Representation ID: 5054

Received: 16/03/2023

Respondent: Sussex Wildlife Trust

SWT supports the inclusion of a policy relating to pollution. Further to this, given the complexity of the issues relating to the broad topic of pollution, we welcome the approach to provide more specific detail on the range of potential pollution pathways.

Support and comment noted

Support

Representation ID: 5055

Received: 16/03/2023

Respondent: Sussex Wildlife Trust

SWT supports the inclusion of this policy, which recognises the need to ensure lighting does not impact protected sites and species. This is consistent with NPPG Paragraph: 006 Reference ID: 31-006-20191101 and 185 c of the NPPF 2021.

Support noted

Support

Representation ID: 5056

Received: 16/03/2023

Respondent: Sussex Wildlife Trust

SWT supports the inclusion of a Green Infrastructure Policy and its recognition of the multifunctional benefits that Green Infrastructure can deliver when delivered strategically. This is consistent with section 175 of the NPPF 2021.

Support and comments noted

Support

Representation ID: 5057

Received: 16/03/2023

Respondent: Sussex Wildlife Trust

SWT is encouraged to see the inclusion of bullet point 3 in this policy. We feel it recognises the role of open space, including that of space for sport and recreation, in terms of potential for ecological benefits. This is consistent with Paragraph: 001 Reference ID: 37-001-20140306

Support Noted.

Object

Representation ID: 5058

Received: 16/03/2023

Respondent: Sussex Wildlife Trust

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Having looked at the information presented in the consultation, this policy appears to propose an extension to the Runcton Horticultural Development Needs on top of the East of the City Wildlife Corridor. Neither Policy E3 addressing Horticultural Need, nor indeed Policy N4 Strategic Wildlife Corridors, seem to address how these two policies have the opportunity to interact positively for the benefit of biodiversity. We would suggest that this policy more clearly reflects that it overlays a Wildlife Corridor and as such must recognise the requirements of policy NE 4 Strategic Wildlife Corridors when proceeding.

Strategic Wildlife Corridors are referred to at criterion 9 of policy E4. However, the policy will be strengthened with regard to the protection of the Strategic Wildlife Corridors.

Support

Representation ID: 5059

Received: 16/03/2023

Respondent: Sussex Wildlife Trust

We support this policy, identifying that it has scope to highlight opportunities for Green Infrastructure and Biodiversity Net Gain as per paragraph 174 & 175 of the NPPF.

Support noted

Object

Representation ID: 5060

Received: 16/03/2023

Respondent: Sussex Wildlife Trust

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? Not specified

The consultation document does not seem to provide a map to identify the area defined by this allocation, so it is difficult for SWT to give specific feedback on impacts to biodiversity.
We are encouraged to see the policy requirements acknowledge under bullet point 5, the need to avoid impacts on biodiversity, and the potential for the area to deliver gains for biodiversity.

Comment noted. Agree that reference should be made to delivering green infrastructure.