Chichester Local Plan 2021 - 2039: Proposed Submission
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Chichester Local Plan 2021 - 2039: Proposed Submission
Policy A13 Southbourne Broad Location for Development
Representation ID: 5071
Received: 16/03/2023
Respondent: Sussex Wildlife Trust
Legally compliant? Not specified
Sound? No
Duty to co-operate? Not specified
The information we have been able to obtain by looking at this plan does not enable SWT to give effective feedback on the impacts on biodiversity from development at this scale in this broad location. We are encouraged to see the supporting text acknowledging the importance of master planning when considering suitability of development in that location.
We feel that this policy is inconsistent with other policies in the draft Local Plan. While bullet point 9 references no adverse impacts to wildlife, it fails to acknowledge the requirement to leave biodiversity in a better state via the delivery of BNG.
Amend policy to acknowledge the addition of BNG to ensure the policy is consistent with national policy, 179b NPPF 2021:
9) Demonstrate that development would not have an adverse impact on the nature conservation interest of identified sites and habitats including the strategic wildlife corridors;. Deliver biodiversity net gain that
facilitates habitat connectivity.
See attached representation.
It is agreed that reference to BNG would be helpful but for consistency the wording should follow that used in the other housing site related policies.
Object
Chichester Local Plan 2021 - 2039: Proposed Submission
Policy A14 Land West of Tangmere
Representation ID: 5072
Received: 16/03/2023
Respondent: Sussex Wildlife Trust
Legally compliant? Not specified
Sound? No
Duty to co-operate? Not specified
SWT feels that this policy is inconsistent with other policies in the draft Local Plan and the NPPF. The policy fails to acknowledge the requirement to leave biodiversity in a better state via the delivery of BNG. As such, we recommend an amendment to this policy to acknowledge the addition of BNG to ensure the policy is consistent with national policy, 179b NPPF 2021.
Amend policy with an additional bullet point:
Ensure that development avoids harm to protected species and existing important habitat features; facilitates the achievement of a minimum of 10% biodiversity net gain; and facilitates the creation of high levels of habitat connectivity within the site and to the wider green infrastructure network and identified strategic wildlife corridors. This includes the provision of appropriate buffers as necessary in relation to important habitats which are being retained and/or created.
See attached representation.
Comment noted. The Local Plan contains the proposed policy NE5 Biodiversity and Biodiversity Net Gain, and is intended to be read in the round. Policy NE5 sets out the requirement for development proposals to deliver a minimum of 10% net gain in biodiversity
The development benefits from outline planning permission (resolution subject to completion of the Section 106) (ref 20/02783/OUT). The application has assessed the net gain of this development as at 12.97%.
Object
Chichester Local Plan 2021 - 2039: Proposed Submission
Policy A15 Loxwood
Representation ID: 5073
Received: 16/03/2023
Respondent: Sussex Wildlife Trust
Legally compliant? Not specified
Sound? Not specified
Duty to co-operate? Not specified
The information available in the consultation documents does not seem to define the area and as such, does not enable SWT to give effective feedback on the impacts on biodiversity from development at this scale in this broad location. We do note that that supporting policy wording requires impacts to biodiversity and protected sites to be avoided, and the delivery of Biodiversity Net Gain, in line with section 174 on the NPPF 2021.
However, we highlight that such a broad allocation policy does not enable important features that maybe present to be captured, and as such attention to this should be considered when the DPD allocation document is produced.
See attached representation.
Comment noted. Criteria 5 of Policy A15 requires that development avoids harm to protected species and important habitat features as well as facilitating biodiversity net gain and habitat connectivity. The Plan also includes specific policies to protect wildlife and require delivery of BNG which will all need to be considered as part of the Neighbourhood Plan site selection process
Object
Chichester Local Plan 2021 - 2039: Proposed Submission
Policy A16 Goodwood Motor Circuit and Airfield
Representation ID: 5074
Received: 16/03/2023
Respondent: Sussex Wildlife Trust
Legally compliant? Not specified
Sound? Not specified
Duty to co-operate? Not specified
This location does not appear to be defined in the policies map. However, we highlight that the area is adjacent to a Strategic Wildlife Corridor, to the east of the airfield, and as such any proposals coming forward in that area should seek to ensure that they support the function of the Strategic Wildlife Corridor.
Propose additional policy requirement to A16/A17:
• Ensure that development avoids harm to protected species and existing important habitat features; facilitates the achievement of a minimum of 10% biodiversity net gain; and facilitates the creation of high levels of habitat connectivity within the site and to the wider green infrastructure network and identified strategic wildlife corridors. This includes the provision of appropriate buffers as necessary in relation to important habitats which are being retained and/or created.
See attached representation.
Location is on policies map.
The Local Plan contains the proposed policy NE5 Biodiversity and Biodiversity Net Gain, and is intended to be read in the round. Policy NE5 sets out the requirement for development proposals to deliver a minimum of 10% net gain in biodiversity
Object
Chichester Local Plan 2021 - 2039: Proposed Submission
Policy A18 Thorney Island
Representation ID: 5075
Received: 16/03/2023
Respondent: Sussex Wildlife Trust
Legally compliant? Not specified
Sound? Not specified
Duty to co-operate? Not specified
SWT was expecting this policy to acknowledge the potential for this area to be delivering a habitat creation scheme in the form of coastal realignment in the south western edge of the barracks . Also, given the coastal policies presented in the plan, does CDC not feel these should be referenced within the policy in order for it to be consistent with spatial aspirations of the plan.
See attached representation.
The policy and pre-text have been strengthened in relation to references to habitat creation schemes. With regard to reference to coastal policies, Paragraph 1.12 points out that the plan should be read as a ‘whole’ and policies will not be applied in isolation
Object
Chichester Local Plan 2021 - 2039: Proposed Submission
Policy A17 Development within the vicinity of Goodwood Motor Circuit and Airfield
Representation ID: 5076
Received: 16/03/2023
Respondent: Sussex Wildlife Trust
Legally compliant? Not specified
Sound? Not specified
Duty to co-operate? Not specified
This location does not appear to be defined in the policies map. However, we highlight that the area is adjacent to a Strategic Wildlife Corridor, to the east of the airfield, and as such any proposals coming forward in that area should seek to ensure that they support the function of the Strategic Wildlife Corridor.
Propose additional policy requirement to A16/17:
• Ensure that development avoids harm to protected species and existing important habitat features; facilitates the achievement of a minimum of 10% biodiversity net gain; and facilitates the creation of high levels of habitat connectivity within the site and to the wider green infrastructure network and identified strategic wildlife corridors. This includes the provision of appropriate buffers as necessary in relation to important habitats which are being retained and/or created.
See attached representation.
Location is on policies map.
This is not an allocation policy. Other policies offer protection to species and habitats and require biodiversity net gain including NE5 Biodiversity and Biodiversity Net Gain. NE4 protects the Strategic wildlife Corridors
Object
Chichester Local Plan 2021 - 2039: Proposed Submission
Policy A19 Land at Chichester Business Park, Tangmere
Representation ID: 5077
Received: 16/03/2023
Respondent: Sussex Wildlife Trust
Legally compliant? Not specified
Sound? Not specified
Duty to co-operate? Not specified
There is no information to support the suitability of this location for development in relation to impacts on biodiversity. We note that this policy is short in nature and does not give any detail of requirements that would be sought if development proceeded in this location. Just to the north of the allocation boundary, our mapping shows us that there is a field with a water body and considerable wooded edge habitat. Therefore, we suggest that CDC considers if the policy needs detail included that makes it consistent with policy relating to impacts on biodiversity 174 NPPF 2021
See attached representation.
Comments noted. Site under construction
Object
Chichester Local Plan 2021 - 2039: Proposed Submission
Policy A20 Land South of Bognor Road
Representation ID: 5078
Received: 16/03/2023
Respondent: Sussex Wildlife Trust
Legally compliant? Not specified
Sound? Not specified
Duty to co-operate? Not specified
In section 10.83 of the supporting text, Chichester Gravel Pits and Leythorne Meadow is referenced as an SNCI. This needs to be amended to LWS (Local Wildlife Site).
Support inclusion of bullet point 7 in policy which should recognise the sensitivities of surrounding habitat and need for impacts to be avoided as per section 179 of the NPPF 2021. Bullet point 7 references Chichester Gravel Pits and Leythorne Meadow as a Local Nature Reserve - should also state that site is a Local Wildlife Site.
Section 10.83: Chichester Gravel Pits and Leythorne Meadow is referenced as an SNCI. This needs to be amended to LWS (Local Wildlife Site).
Bullet point 7 in policy references Chichester Gravel Pits and Leythorne Meadow as a Local Nature Reserve - should also state that site is a Local Wildlife Site.
See attached representation.
Corrections will be made
Object
Chichester Local Plan 2021 - 2039: Proposed Submission
Policy A21 Land east of Rolls Royce
Representation ID: 5079
Received: 16/03/2023
Respondent: Sussex Wildlife Trust
Legally compliant? Not specified
Sound? Not specified
Duty to co-operate? Not specified
There is no ecological information supporting this allocation. However, we can see from aerial imagery that the allocation contains wooded habitat that appears to be functionally linked to the Strategic Wildlife Corridor. The policy currently contains no information to suggest that the existing biodiversity on the site will be safeguarded.
For consistency, we would suggest that the policy includes an additional bullet point:
• Ensure that development avoids harm to protected species and existing important habitat features; facilitates the achievement of a minimum of 10% biodiversity net gain; and facilitates the creation of high levels of habitat connectivity within the site and to the wider green infrastructure network and identified strategic wildlife corridors. This includes the provision of appropriate buffers as necessary in relation to important habitats which are being retained and/or created.
See attached representation.
This is a safeguarding policy rather than an allocation so does not have the same level of detail as full allocation policies. These requirements are covered by other policies (particularly NE4 Strategic Wildlife Corridors and NE5 Biodiversity and Biodiversity Net Gain) and do not need to be repeated.
Object
Chichester Local Plan 2021 - 2039: Proposed Submission
Policy NE15 Flood Risk and Water Management
Representation ID: 5273
Received: 16/03/2023
Respondent: Sussex Wildlife Trust
Legally compliant? Not specified
Sound? Not specified
Duty to co-operate? Not specified
Re; policy wording: Elsewhere, new development should be set back at least 8m from fluvial watercourses and 16 m from tidal watercourses to allow easy access for maintenance and repair.
SWT would support an increased set back from fluvial water course of 10 meters to support opportunities for biodiversity. Further increases to the setback for tidal water course of 25 meters, would be encouraged to bring it in line with the aspirations of Policy NE 12 Development around the coast.
SWT would support an increased set back from fluvial water course of 10 meters to support opportunities for biodiversity. Further increases to the setback for tidal water course of 25 meters, would be encouraged to bring it in line with the aspirations of Policy NE 12 Development around the coast.
See attached representation.
In terms of the request to provide an additional buffer for biodiversity, it is not considered that this is justified, particularly in relation to this policy, which is primarily targeted towards flood risk rather than biodiversity. The issue of the separation distances has been covered in other representations. The specified distance is driven by national legislation. The Council does not have a justification for extending that distance or what it should be extended to, so such a change is not considered to be a sound approach
