Chichester Local Plan 2021 - 2039: Proposed Submission
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Chichester Local Plan 2021 - 2039: Proposed Submission
Appendix F: Monitoring framework
Representation ID: 5274
Received: 16/03/2023
Respondent: Sussex Wildlife Trust
Legally compliant? Not specified
Sound? Not specified
Duty to co-operate? Not specified
SWT suggests that the monitoring framework as presented doesn’t clearly indicate the monitoring requirement for each policy. As a result, SWT feels it fails to capture some important information to inform the effectiveness of the policies. For example, policy NE5 Biodiversity and Biodiversity Net Gain does not appear to have a monitoring requirement that will capture the percentage of net gain delivered by applications. Given that the Environment Act will bring in mandatory net gain of a minimum of 10% by November 2023, we feel it would be remiss of CDC to miss capturing the effectiveness of their policy against national mandatory requirements. It might also help to build a picture of the feasibility of exceeding that minimum requirement.
We also highlight that Sussex Wildlife Trust is listed as a responsible agency/partner. Can we ask CDC to clarify our role in that? It may be that an amendment is required to more specifically reference the role of the Sussex Biodiversity Record Centre rather than SWT.
Propose an additional monitoring indicator of;
• Number of planning applications delivering a BNG in excess of 10%
See attached representation.
The framework layout reflects that many of the targets in the monitoring framework are applicable to several policies within each Chapter. However, an introduction has been inserted to the Monitoring Framework for clarity. The target for Policy NE5 Biodiversity and Biodiversity Net Gain policy is for all development proposals to provide a minimum of 10% net gain in biodiversity in order to be granted planning permission. The identification of the actual percentage of net gain achieved is not a target linked to the policy. The reference to Sussex Wildlife Trust will be changed to Sussex Biodiversity Record Centre.
Support
Chichester Local Plan 2021 - 2039: Proposed Submission
Policy NE5 Biodiversity and Biodiversity Net Gain
Representation ID: 6179
Received: 16/03/2023
Respondent: Sussex Wildlife Trust
SWT is supportive of the inclusion of a Biodiversity and Biodiversity Net Gain (BNG) policy, this is consistent with 174 & 175 of the NPPF 2021.
See attached representation.
Support in principle noted.
Support
Chichester Local Plan 2021 - 2039: Proposed Submission
Policy NE8 Trees, Hedgerows and Woodlands
Representation ID: 6248
Received: 16/03/2023
Respondent: Sussex Wildlife Trust
SWT supports the inclusion of this policy to recognise the value of these habitats.
See attached representation.
Support noted
Support
Chichester Local Plan 2021 - 2039: Proposed Submission
Policy NE12 Development around the Coast
Representation ID: 6249
Received: 16/03/2023
Respondent: Sussex Wildlife Trust
We support the inclusion of a policy that recognises the issues relating to the coastline in the face of changing climate, its resilience and future development.
See attached representation.
Support noted
Support
Chichester Local Plan 2021 - 2039: Proposed Submission
Policy NE17 Water Neutrality
Representation ID: 6250
Received: 16/03/2023
Respondent: Sussex Wildlife Trust
SWT is supportive of policy measures coming forward to address impacts on designated sites from abstraction. This is the first time SWT has seen a policy of this kind come forward in a Local Plan, so we have not had an opportunity to comment through the Regulation 18 process. As such, our comments related to this policy may not be considered strictly within the realms of soundness.
See attached representation.
Comments noted.
Support
Chichester Local Plan 2021 - 2039: Proposed Submission
Policy NE19 Nutrient Neutrality
Representation ID: 6251
Received: 16/03/2023
Respondent: Sussex Wildlife Trust
SWT supports CDC with the inclusion of this policy. SWT has not had an opportunity to comment through the Regulation 18 process. As such our comments on this policy related to its use and therefore may not be considered strictly within the realms of soundness.
See attached representation.
Support noted
Support
Chichester Local Plan 2021 - 2039: Proposed Submission
Policy A5 Southern Gateway – Police Field, Kingsham Road
Representation ID: 6252
Received: 16/03/2023
Respondent: Sussex Wildlife Trust
We are supportive of the bullet points 5 – 9 within the policy that seek to avoid impacts to biodiversity and maximise gains for biodiversity as per section 174 NPPF 2021.
See attached representation.
Support noted