Sustainability Appraisal and Habitats Regulation Assessment

Comment

Representation ID: 6009

Received: 03/05/2023

Respondent: Natural England

[RECEIVED LATE]
Atmospheric Pollution - Do not agree with many of the arguments currently used to conclude No Adverse Effect on Integrity (AEOI) for the following sites: Ebernoe Common Special Area of Conservation (SAC); The Mens SAC; Butser Hill SAC; Kingley Vale SAC; Duncton to Bignor Escarpment SAC. Not saying conclusion of No AEOI is incorrect but other evidence needs to be provided to support this.

Water Quality (including Nutrient Neutrality) - Solent sites: in relation to proposed site allocation at Highgrove Farm and nutrient mitigation land at Chilgrove Farm, local Nutrient Neutrality (NN) lead is satisfied with approach proposed. Happy to have discussion with CDC to understand and hopefully allay any remaining concerns about the Plan’s approach to NN; - Pagham Harbour: evidence still developing in relation to water quality situation at PH, may not be as simple as HRA currently makes it (stating there is no current issue with water quality and no requirement for specific mitigation). However, given Plan allocates limited (if any) development discharging to Pagham Harbour, general protection afforded by policies NE6 and NE16 may be sufficient to conclude No AEOI at this point in time.

Loss or Degradation of Functionally Linked Habitat
- Solent sites: functionally-linked land around Solent is well documented through Solent Wader and Brent Goose Strategy. Draft Local Plan proposes new development in four areas which potentially overlap with Solent functionally-linked land although there are no detailed site allocations at this point. Support general policy protection provided through policies NE5, NE6 and NE7 but advise wording in ‘Broad Location for Development’ policies for Chidham and Hambrook (A12) and Southbourne (A13) be strengthened to better reflect the mitigation hierarchy.

Further discussion with Natural England and work around the issue of air quality remains on-going to resolve this issue.

In relation to ‘Loss or Degradation of Functionally Linked Habitat
- Solent sites’ - amendments CM327 to Policy A12 Chidham and Hambrook and CM337 to Policy A13 Southbourne BLD are proposed as set out in the Council’s Suggested Modifications Schedule (May 2024) to better reflect the mitigation hierarchy.