Chichester Local Plan 2021 - 2039: Proposed Submission

Support

Representation ID: 4855

Received: 17/03/2023

Respondent: Environment Agency

We support the specific criteria in this policy to ensure that sites avoid locations where there are significant constraints including flood risk (criteria 2).

Comment noted

Object

Representation ID: 4856

Received: 17/03/2023

Respondent: Environment Agency

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

We note that green infrastructure provision is mentioned in this policy and within the glossary there is reference to this term including blue infrastructure. However, it would be better to change all references to ‘green infrastructure’ to say ‘green/blue infrastructure’ to ensure that opportunities in the water environment alongside the terrestrial environment are not marginalised or ignored.

As per our response to representation 4860, Local Plan references to Green Infrastructure as an overarching term is consistent with terminology within the NPPF, Planning Practice Guidance and the Natural England Green Infrastructure Framework. The Local Plan Appendix J Glossary does, however, define Green and Blue Infrastructure as a multifunctional network of green and blue spaces

Object

Representation ID: 4858

Received: 17/03/2023

Respondent: Environment Agency

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

We support this policy as drafted, save for amending the reference to green infrastructure as per our comments for Policy P1. The expectation for development to integrate climate change adaption measures in point 4 is positive.

Objection and proposed change noted. In line with our response to your representation 4860, we consider Local Plan references to Green Infrastructure as an overarching term to be consistent with terminology within the NPPF, Planning Practice Guidance and the Natural England Green Infrastructure Framework. The Local Plan Appendix J Glossary does, however, define Green and Blue Infrastructure as a multifunctional network of green and blue spaces. To ensure the inclusion of blue infrastructure is emphasised within Policy P5 we will consider a minor modification to the policy to specifically reference blue infrastructure assets.

Object

Representation ID: 4860

Received: 17/03/2023

Respondent: Environment Agency

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

As per out comment for Policy P1, references to green infrastructure should be amended to green/blue infrastructure.

Objection and proposed change noted. Local Plan references to Green Infrastructure as an overarching term is consistent with terminology within the NPPF, Planning Practice Guidance and the Natural England Green Infrastructure Framework. The Local Plan Appendix J Glossary does, however, define Green and Blue Infrastructure as a multifunctional network of green and blue spaces. To ensure the inclusion of blue infrastructure is emphasised within Policy P14 itself we will consider minor modifications to the policy to reference blue infrastructure. Furthermore, additional modifications will be made other policies, in response to separate EA representations, to refer to blue infrastructure assets and networks.

Support

Representation ID: 4861

Received: 17/03/2023

Respondent: Environment Agency

We are pleased to see specific reference to the need to demonstrate adequate water resources are available and/or water efficiency measures (criteria 6).

Support noted

Support

Representation ID: 4863

Received: 17/03/2023

Respondent: Environment Agency

We are pleased to see that our comments form the Regulation 18 consultation have been incorporated into this policy with the addition of the wording “They are located so as to avoid areas at greatest risk of flooding.”

Support noted

Support

Representation ID: 4864

Received: 17/03/2023

Respondent: Environment Agency

We are pleased to see that our comments from the Regulation 18 consultation have been incorporated into this policy with reference included to flood defences and SuDS infrastructure.

Support Noted

Support

Representation ID: 4866

Received: 17/03/2023

Respondent: Environment Agency

We are supportive of the policy intention to “maximise opportunities for integration of natural features to achieve biodiversity net gain and sustainable water management.”

Support noted

Support

Representation ID: 4867

Received: 17/03/2023

Respondent: Environment Agency

We are supportive of the policy requirements for allocations to accord with the sequential approach to flood risk, with development being located in areas at the lowest risk of flooding (requirement 9), and the need for phasing to ensure that wastewater disposal capacity is available (requirement 10).

Support noted

Support

Representation ID: 4868

Received: 17/03/2023

Respondent: Environment Agency

Paragraph 10:14 of the accompanying text explains that parts of the site in Flood Zones 2 & 3, so development design needs to account for this and mitigate this. We recommend that developers incorporate such considerations into their masterplanning for any sites.

Support noted – the site-specific policies require the flood risk to be addressed