Sustainability Appraisal and Habitats Regulation Assessment
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Sustainability Appraisal and Habitats Regulation Assessment
Sustainability Appraisal - January 2023
Representation ID: 5362
Received: 17/03/2023
Respondent: Landlink Estates Ltd
Agent: Jackson Planning Ltd
Does not test spatial land use implications for coastal retreat, deal with relocation of dwellings from vulnerable parts of Manhood Peninsula or consider allocation of climate change management area; 9.6 should plan for production of renewable energy as 3.3.1 states objective was to achieve net zero; no examination of impacts of gap designations in preventing development of critical climate adaptation development or impacts of removing BMV land within proposed wildlife corridors; re; NE14, dismissed linked pathways and impacts of relocating current settlement; not tested growth scenario at Selsey; Selsey site not considered as reasonable alternatives for dealing with coastal change management on MP, no cogent argument supporting its removal; haven't tested significant effects of not improving B2145.
The SA has not examined reasonable alternatives so that the plan reflects the sustainability objectives. It does not recognise the significant role of renewable energy in mitigation of fossil fuels and GHG increasing climate change, and this is not addressed at all under the climate change mitigation section of the SA.
See attachments.
As set out in the Planning Practice Guidance, the primary source of evidence for defining coastal change management areas is the shoreline management plan. However, the relevant SMPs for the Plan Area do not currently require the identification of such areas.
Local Plan viability testing showed that requiring new development to meet higher standards ahead of Building Regulation changes would not be viable even if other contributions such as affordable housing were reduced.
Consideration has been given to the making of a strategic allocation at Selsey. However, as the Local Plan has progressed this approach has been revised to take account of the large amount of development that has, since the Preferred Approach consultation, received planning permission and updated evidence in respect of flood risk.
