Chichester Local Plan 2021 - 2039: Proposed Submission
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Chichester Local Plan 2021 - 2039: Proposed Submission
Policy NE2 Natural Landscape
Representation ID: 4112
Received: 15/03/2023
Respondent: Chichester Harbour Trust
We fully support the text and wording of the policy, which must translate into active support in the planning process. The contents should be proactively supported through the delivery of the Plan itself, particularly through policies A11 Land at Highgrove Farm, Bosham 245;
A13 Southbourne Broad Location for Development 1,050;A12 Nutbourne and Hambrook (Chidham and Hambrook Parish) 300
We fully support the text and wording of the policy, which must translate into active support in the planning process. The contents should be proactively supported through the delivery of the Plan itself, particularly through policies A11 Land at Highgrove Farm, Bosham 245;
A13 Southbourne Broad Location for Development 1,050;A12 Nutbourne and Hambrook (Chidham and Hambrook Parish) 300
Support and comment noted
Support
Chichester Local Plan 2021 - 2039: Proposed Submission
Policy NE3 Landscape Gaps between settlements
Representation ID: 4115
Received: 15/03/2023
Respondent: Chichester Harbour Trust
We welcome the inclusion of this policy in this iteration of the Plan. This is particularly important to protect the cohesion and identity of settlements along the A259 between Chichester and Emsworth.
We welcome the inclusion of this policy in this iteration of the Plan. This is particularly important to protect the cohesion and identity of settlements along the A259 between Chichester and Emsworth.
Support noted
Support
Chichester Local Plan 2021 - 2039: Proposed Submission
Policy NE4 Strategic Wildlife Corridors
Representation ID: 4118
Received: 15/03/2023
Respondent: Chichester Harbour Trust
We welcome the inclusion of the policy on strategic wildlife corridors, although would prefer that these were safeguarded to prevent any development in these designated areas. We feel that the policy, and indeed the corridors themselves, lack ambition and would benefit from being further strengthened to emphasise their importance in connecting the protected landscapes and habitats of Chichester Harbour and the South Downs. In addition it is not clear from the policy changes map whether or how the proposed corridors have changed since the last consultation in 2018/19.
We welcome the inclusion of the policy on strategic wildlife corridors, although would prefer that these were safeguarded to prevent any development in these designated areas. We feel that the policy, and indeed the corridors themselves, lack ambition and would benefit from being further strengthened to emphasise their importance in connecting the protected landscapes and habitats of Chichester Harbour and the South Downs. In addition it is not clear from the policy changes map whether or how the proposed corridors have changed since the last consultation in 2018/19.
Comment noted. The Council considers that the policy is ambitious as it is the first proposed of its kind across the country.
The Strategic Wildlife Corridors Background Paper has been updated to include detail relating to the evolution of the corridors.
Support
Chichester Local Plan 2021 - 2039: Proposed Submission
Policy NE5 Biodiversity and Biodiversity Net Gain
Representation ID: 4121
Received: 15/03/2023
Respondent: Chichester Harbour Trust
We support the inclusion of this policy within the Plan, however wish to make the observation that by default the sheer level of proposed development in close proximity to the Chichester Harbour SSSI/SPA/SAC site makes its delivery problematic.
We support the inclusion of this policy within the Plan, however wish to make the observation that by default the sheer level of proposed development in close proximity to the Chichester Harbour SSSI/SPA/SAC site makes its delivery problematic. It would need to ensure that any new developments did not contribute any additional waste water, surface drainage and nutrients into water bodies entering Chichester Harbour. It would need to ensure that there was no additional recreational pressure on the harbour, and any that arose would need to be effectively mitigated - which at present is not in place. Any proposed mitigation must be property resourced and monitored to ensure it is fit for purpose.
Support and comment noted.
Support
Chichester Local Plan 2021 - 2039: Proposed Submission
Policy NE6 Chichester's Internationally and Nationally Designated Habitats
Representation ID: 4124
Received: 15/03/2023
Respondent: Chichester Harbour Trust
Cross reference to our response to NE5.
We support the inclusion and comprehensiveness of this policy, but argue that it is in effect incompatible with the levels of development proposed in the Plan, particularly relating to the east-west corridor between Chichester and Emsworth, along the boundary of the Chichester Harbour SSSI/SPA/SAC designated site. Any proposed mitigation measures must be deliverable, funded and monitored effectively, otherwise they will not have an impact in preventing further ecological deterioration of the Harbour.
Cross reference to our response to NE5.
We support the inclusion and comprehensiveness of this policy, but argue that it is in effect incompatible with the levels of development proposed in the Plan, particularly relating to the east-west corridor between Chichester and Emsworth, along the boundary of the Chichester Harbour SSSI/SPA/SAC designated site. Any proposed mitigation measures must be deliverable, funded and monitored effectively, otherwise they will not have an impact in preventing further ecological deterioration of the Harbour.
Support and comment noted
Support
Chichester Local Plan 2021 - 2039: Proposed Submission
Policy NE10 Development in the Countryside
Representation ID: 4272
Received: 15/03/2023
Respondent: Chichester Harbour Trust
Whilst we welcome this policy for development management, it should be noted that the delivery of the Plan is overly reliant on development in the countryside through the spatial strategy. Of the 3,225 homes proposed between Chichester and Southbourne, overwhelmingly they will be built on greenfield sites. We would hope to see much greater focus on delivery of brownfield sites and urban locations.
Whilst we welcome this policy for development management, it should be noted that the delivery of the Plan is overly reliant on development in the countryside through the spatial strategy. Of the 3,225 homes proposed between Chichester and Southbourne, overwhelmingly they will be built on greenfield sites. We would hope to see much greater focus on delivery of brownfield sites and urban locations.
Support noted
Support
Chichester Local Plan 2021 - 2039: Proposed Submission
Policy NE11 The Coast
Representation ID: 4274
Received: 15/03/2023
Respondent: Chichester Harbour Trust
We are encouraged to see the inclusion of this policy with recognition of Chichester Harbour's regional importance, an reference to the work of the CHaPRoN partnership.
We are encouraged to see the inclusion of this policy with recognition of Chichester Harbour's regional importance, an reference to the work of the CHaPRoN partnership.
Support noted
Support
Chichester Local Plan 2021 - 2039: Proposed Submission
Policy NE12 Development around the Coast
Representation ID: 4277
Received: 15/03/2023
Respondent: Chichester Harbour Trust
It would be helpful in this section to see greater reference to the challenging issues around sea defences - both repairs to existing and new structures, and to the need for Marine Management Organisation and Natural England consent for any works adjacent to the SSSI.
It would be helpful in this section to see greater reference to the challenging issues around sea defences - both repairs to existing and new structures, and to the need for Marine Management Organisation and Natural England consent for any works adjacent to the SSSI.
Paragraph 4.72 before NE11 sets out where the Marine Plan produced by the Marine Management Organisation must be used. Flood defences are covered in NE11 .
Support
Chichester Local Plan 2021 - 2039: Proposed Submission
Policy NE13 Chichester Harbour Area of Outstanding Natural Beauty
Representation ID: 4279
Received: 15/03/2023
Respondent: Chichester Harbour Trust
It is encouraging to see such strong recognition and emphasis on the conservation of Chichester Harbour AONB. It does however cause reflection on the apparent conflict with the strategic allocation policies within the Plan, particularly A11 at Highgrove Farm, and potentially both A13 Southbourne Broad Location for Development and A12 Nutbourne and Hambrook (Chidham and Hambrook Parish). We would hope that the Local Planning Authority would recognise this discrepancy in relation particularly to NE13.3.
It is encouraging to see such strong recognition and emphasis on the conservation of Chichester Harbour AONB. It does however cause reflection on the apparent conflict with the strategic allocation policies within the Plan, particularly A11 at Highgrove Farm, and potentially both A13 Southbourne Broad Location for Development and A12 Nutbourne and Hambrook (Chidham and Hambrook Parish). We would hope that the Local Planning Authority would recognise this discrepancy in relation particularly to NE13.3.
Support noted
Support
Chichester Local Plan 2021 - 2039: Proposed Submission
4.91
Representation ID: 4281
Received: 15/03/2023
Respondent: Chichester Harbour Trust
It does seem that given the strength of the constraints identified in this section, it seems clear that such high levels of development on the coastal plain are by default unsustainable. The levels of management, control and monitoring to enable such development seems unachievable, given that the systems in place currently are not fit for purpose.
It does seem that given the strength of the constraints identified in this section, it seems clear that such high levels of development on the coastal plain are by default unsustainable. The levels of management, control and monitoring to enable such development seems unachievable, given that the systems in place currently are not fit for purpose.
The flooding constraints facing the plan area are significant, particularly with respect to the Manhood Peninsula. However, they do not necessarily mean it is appropriate to restrict the housing requirement on that basis alone, particularly if there are sufficient sites available which will pass the sequential test. Moreover, this issue also needs to be considered in relation to other constraints, and balanced against the level of need