Southbourne Allocation Development Plan Document: Regulation 18 Consultation Assessment Framework
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New searchYes, but the constraint ‘Impact on views to the Chichester Harbour National Landscape to the south of the A259 and views to the north towards the South Downs National Park’ requires expanding to acknowledge that it is not just views to Chichester Harbour National Landscape (NL) that are relevant, but also views from the NL northwards towards the BLD, and the overall impact on the setting of the NL, as set out in paragraph 182 of the National Planning Policy Framework, given the very close proximity of scenarios 1 and 2 to the NL. Similarly, the constraint ‘Strategic Wildlife Corridors are proposed adjacent to the BLD area to protect local species networks such as waders, bats and water voles’ should be expanded as the wildlife corridors do so much more than this, they provide ecological connectivity between Chichester Harbour and the South Downs, ‘breathing space’ for residents, flood resilience, with the Ham Brook being one of only a few rare chalk streams in the world.
Additional constraints which should be included: • Additional pressure on the Waste Water Treatment Works. • Recreational disturbance to Chichester Harbour.
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Under 'Utilities', stating 'reinforcement needed' to wastewater treatment is an understatement, it will require additional capacity and upgrading. Under 'National Environment', for Chichester Harbour SPA, it should state the importance of providing a SANG within the development in addition to mitigation contributions and potential compensatory habitat.
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Under ‘Mitigate impact on the Chichester Harbour SPA from recreational disturbance by creating accessible natural greenspace’ all 3 scenarios are scored the same as ‘Strong’. We disagree. Scenarios 1 and 2 should be scored as ‘reasonable’ or ‘poor’ given their proximity to Chichester Harbour. Scenario 3 would have less impact in this regard and should stay as ‘strong’ to reflect and acknowledge the difference from being sited further from the Harbour and north of the railway line, and therefore likely to cause less recreational disturbance to the Harbour shoreline. Under ‘Preserve Wildlife Corridors’ all 3 scenarios are scored as ‘strong’. We disagree. Scenario 3 would be the furthest removed from the Strategic Wildlife Corridors and is therefore less likely to have a negative impact in this regard than scenarios 1 and 2, in particular scenario 2. Scenario 1 should be scored as ‘Reasonable’ and scenario 2 should be scored as ‘Poor’. Again, under ‘Protect and/or mitigate existing wildlife and biodiversity’ scenario 2 is shown as ‘reasonable’ with scenario 1 as ‘very poor’ and scenario 3 as ‘poor’. We disagree. Scenario 2, due to its proximity to the Strategic Wildlife Corridor (the Ham Brook) should score badly under this objective and should therefore be ‘very poor’ as well as scenario 1. Scenario 3 would have the least impact on this objective, with a much smaller area of Secondary Support Area for Brent Geese being affected than scenario 1, and overall being much further removed from the Strategic Wildlife Corridors and the Harbour, and therefore should have the highest rating, as ‘reasonable’. Under ‘Impacts to agricultural land’, all 3 of the scenarios would be located on Grade 1 and 2 Agricultural land, and score as ‘poor’ within the Assessment Framework as a result; although scenario 3 would appear to have the ‘least bad’ impact in this regard, as the proposed housing area includes less Grade 1 and more Grade 2 land than scenarios 1 and 2. Scenarios 1 and 2 should be scored as ‘very poor’ and scenario 3 as ‘poor’ to reflect and acknowledge this difference. Under ‘Impact on views to and from Chichester Harbour National Landscape (CHNL) and South Downs National Park (SDNP)’ all 3 scenarios are scored as ‘reasonable’. We disagree. Scenarios 1 and 2 should score as ‘very poor’ and ‘poor’ respectively, given the open nature of the land within the NL to the south and the views obtainable looking northwards towards the site for scenario 1 and given that scenario 2 directly adjoins the NL boundary at the last remaining field along this part of the A259 / NL boundary. Under ‘Retention of landscape gaps between villages/settlements’ scenario 1 is scored as ‘very poor’ and scenarios 2 and 3 are both scored as ‘poor’. Whilst we agree with the ratings for scenarios 1 and 2, we disagree with the rating for scenario 3, as this would clearly have by far the least impact in terms of coalescence and infilling landscape gaps, and should therefore score as ‘reasonable’, to reflect the difference between this scenario and scenarios 1 and 2.
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Under 'constraints', and 'potential coalescence and sprawl with neighbouring villages and maintaining a visual gap between settlements' this DPD should state that this will be guided by the landscape gaps as identified in the 'Landscape Gap Assessment' (2019), and this DPD should confirm the precise boundaries of these as they relate to Southbourne, as per the 2019 study, as required under emerging Local Plan Policy NE3, given that they are not shown or included within the Southbourne Neighbourhood Plan.
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