Southbourne Allocation Development Plan Document: Regulation 18 Consultation Assessment Framework

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We agree with the list of opportunities and constraints provided on pages 19, 20 and 21 of the Assessment Framework, however we would advise that some of the identified constraints (e.g. the Strategic Wildlife Corridors) should not be viewed as barriers to development. Instead, the proposed Scenarios have the potential to deliver valuable opportunities to create and reinforce links between natural habitats, thereby increasing ecosystem resilience and connectivity.

As highlighted in our comments to the three scenarios above, we would consider the requirement to deliver mitigation for both nutrient neutrality and recreational disturbance impacts a potential constraint on the site. However, as with our comments in response to Question 11, we would also strongly recommend that mitigation options (for both nutrient impacts and recreational disturbance), should consider how they can be delivered in a way that provides multiple benefits to people and nature i.e., the provision of high quality and biodiverse open greenspace. In addition, we would like to flag that areas within the Broad Location of Development (BLD) area, but not identified within the Solent Wader and Brent Goose Strategy, still have the potential to provide functional linkage to the Chichester and Langstone Harbour SPA and Ramsar site (as well as being an identified secondary support area for Brent Geese). Further survey work would be required to determine whether the site is functionally linked and whether mitigation would be required for its loss.

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We note that your authority has highlighted the need for natural greenspace to be provided, which we presume is to mitigate the impact of increased recreational disturbance on Chichester & Langstone Harbour SPA and Ramsar site. While Suitable Alternative Natural Greenspace (SANG) is a potentially suitable mitigation method, its effectiveness in relation to coastal designated sites is assessed on a case-by-case basis given that on-site greenspace typically only attracts around one third of would-be coastal visitors. In some other coastal locations, Natural England has advised that a SAMMS+ approach to be implemented. We recommend that you consult the Solent Recreation Mitigation Strategy (December 2017) for further information. With regard to Biodiversity Net Gain (BNG) requirements we recommend that the Biodiversity Gain Hierarchy is followed to ensure that BNG is achieved in a structured manner and that as much of the BNG requirement is delivered on site as possible. In the event that Scenario 2 or 3 is taken forward, a strategic approach to BNG could be beneficial to maximise benefits for nature across multiple application sites. It should also be noted that BNG can be delivered in combination with mitigation for nutrient impacts and SANG provision, so long as non-BNG outcomes only contribute up to a point of 'no net loss'. We are concerned that the infrastructure requirements mention the provision of compensatory habitat in relation to recreational disturbance impacts on Chichester and Langstone Harbour SPA. It is Natural England's opinion that the potential impacts of recreational disturbance arising from this development, subject to the provision of appropriate mitigation, can be mitigated and we would therefore not expect there to be a need to deliver "compensatory habitat'. Furthermore, in line with paragraph 186(a) of the NPPF, impacts should be avoided in the first instance, then adequately mitigated for and finally compensation measures provided as a last resort.

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Natural England does not have any comments to make on the assessment methodology.

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Natural England does not have any comments to make on the site assessment scoring.

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