Chichester Local Plan 2021 - 2039: Proposed Submission

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Support

Chichester Local Plan 2021 - 2039: Proposed Submission

Policy NE2 Natural Landscape

Representation ID: 4112

Received: 15/03/2023

Respondent: Chichester Harbour Trust

Representation Summary:

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

Full text:

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

Attachments:


Our response:

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

Representation Summary:

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.

Full text:

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.

Attachments:


Our response:

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

Representation Summary:

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.

Full text:

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.

Attachments:


Our response:

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

Representation Summary:

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.

Full text:

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.

Attachments:


Our response:

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

Representation Summary:

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.

Full text:

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.

Attachments:


Our response:

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

Representation Summary:

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.

Full text:

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.

Attachments:


Our response:

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

Representation Summary:

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.

Full text:

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.

Attachments:


Our response:

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

Representation Summary:

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.

Full text:

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.

Attachments:


Our response:

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

Representation Summary:

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.

Full text:

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.

Attachments:


Our response:

Support noted

Support

Chichester Local Plan 2021 - 2039: Proposed Submission

4.91

Representation ID: 4281

Received: 15/03/2023

Respondent: Chichester Harbour Trust

Representation Summary:

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.

Full text:

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.

Attachments:


Our response:

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

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