Southbourne Allocation Development Plan Document: Regulation 18 Consultation Main Document

No

Natural England is broadly satisfied with the vision and objectives set out in the submitted document; however, we would support a stronger reference to protected landscapes in the vision given the developments location and the enhanced duty to 'seek to further the purpose' of National Landscapes (Section 245, Levelling-up and Regeneration Act 2023). Similarly, we would welcome clearer consideration of the need to ensure that any future development ensures that designated sites, protected species and priority habitats are safeguarded as far as practicable and are considered in line with paragraph 186 of the NPPF. Notwithstanding the above, Natural England supports the holistic approach to environmental matters within Section 4, and the inclusion of specific objectives relating to 'transport and sustainable travel', climate change moving towards net zero carbon living and the multifunctional benefits associated with the proposed continuous Green Ring.

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Yes

Following a review of Scenario 1, we agree that the delivery of this option has the potential to provide opportunities for better connections with nature for both the existing and new residents of Southbourne, through the delivery of the western section of the Green Ring as well as quality green open space provision and the retention of existing PROW. Natural England supports the delivery of options that have the potential to facilitate connections between people and nature within the wider community. We also agree that the current ownership of the land would help to facilitate a more 'joined up approach' to development, and Natural England would strongly encourage benefits to people and nature being considered in a manner that ensures cohesion and delivery of multiple benefits at scale. Your authority has identified that a large proportion of the site is designated as a 'Secondary Support Area' by the Solent Wader and Brent Geese Strategy and that any loss will require mitigating, and Natural England agrees that this is a challenge that will need addressing and considering in line with the mitigation hierarchy (paragraph 186 of the NPPF).

Given the location of the site, any new overnight accommodation will have a likely significant effect upon the Chichester and Langstone Harbour SPA and Ramsar site, as well as the Solent Maritime SAC, due to increased levels of recreational disturbance and treated effluent being discharged into the site. Nutrient neutrality has the potential to be addressed via on-site land use change, such as woodland planting. Natural England would encourage the consideration of mitigation options that can provide multiple benefits. For example, woodland planting (or other appropriate land use change) can have the additional benefit of providing on-site greenspace to attract some recreational activity away from the Solent designated sites (as part of a mitigation package for recreational disturbance impacs) while addressing increased levels of nutrients. However, we advise that given the scale of the development and its proximity to coastal designated sites, standard financial contributions and on-site greenspace provision are unlikely to wholly mitigate the impact of increased recreational disturbance alone, and may require additional bespoke mitigation measures in line with the Solent Recreation Mitigation Strategy (December 2017). In addition, as the proposed development site for Scenario 1 is smaller than the other scenarios being considered - but still delivers the same number of dwellings - we would suggest that the potential challenges with delivering onsite mitigation should be considered, including whether offsite solutions may be required instead. It is important to note that, although built development will not cover the entirety of the 'Secondary Support Area', changes in land use that do not constitute built development may still constitute a loss of suitable foraging habitat for birds identified within the Solent Wader and Brent Goose Strategy. It is not currently clear what the plans are for the remainder of the Broad Location of Development (BLD), but even the provision of open greenspace is likely to adversely impact upon the suitability of the site (as a secondary support area) as there is likely to be a reduction in the availability of appropriate foraging resource as a result of increased recreational activities in this area. Having used our Agricultural Land Classification predictive tool, we would advise at this stage that this scenario would result in the loss of primarily Grade 1 agricultural land rather than Grade 1 and 2. In line with Policy 48 in your authority's currently adopted Local Plan, development of poorer quality land should be fully considered in preference to best and most versatile land and this should be evidenced within application documents. Given that the Southbourne Broad Location of Development (BLD) is located within the setting of both the South Downs National Park to the north, and the Chichester Harbour National Landscape (formerly 'Area of Outstanding Natural Beauty') to the south, all development scenarios will need to consider potential landscape impacts. In line with Paragraph 182 of the National Planning Policy Framework (NPPF), development within the setting of protected landscapes should be sensitively located and designed to avoid or minimise adverse impacts on the designated areas. We would therefore expect any potential impacts to be assessed in line with Paragraph 183 of the NPPF and Section 245 of the Levelling-up and Regeneration Act 2023.

This question is outside of Natural England's remit, and we therefore will not be providing comment.

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Yes

Following a review of Scenario 2, Natural England advise that we agree with the potential benefits as laid out in the DPD. Namely, this option may provide opportunities for better connections with nature for both the existing and new residents of Southbourne, through the delivery of the eastern section of the Green Ring with the incorporation of locally protected hedgerows, historic orchards and local green spaces. The provision of foot and cycle paths along with attractive green spaces has the potential to benefit both people and wildlife, both within and beyond the development site. We support the consideration of how this scenario may integrate existing water courses to allow for a blue and green infrastructure strategy. We note that the challenges currently outlined within the DPD are largely outside of our remit to comment on, however, we concur that the development of this site would result primarily in the loss of Grade 1 Best and Most Versatile Agricultural Land. In line with Policy 48 in your authority's currently adopted Local Plan, development of poorer quality land should be fully considered in preference to best and most versatile land and this should be evidenced within application documents. In addition, there are further environmental challenges that should be considered, as described in the section below.

Given the location of the site, any new overnight accommodation will have a likely significant effect upon the Chichester and Langstone Harbour SPA and Ramsar site, as well as the Solent Maritime SAC, due to increased levels of recreational disturbance and treated effluent being discharged into the site. Nutrient neutrality has the potential to be addressed via on-site land use change, such as woodland planting. Natural England would encourage the consideration of mitigation options that can provide multiple benefits. For example, woodland planting (or other appropriate land use changes) can have the additional benefit of providing on-site greenspace to attract some recreational activity away from the Solent designated sites (as part of a mitigation package for recreational disturbance impacs) while addressing increased levels of nutrients. However, we advise that given the scale of the development and its proximity to coastal designated sites, standard financial contributions and on-site greenspace provision are unlikely to wholly mitigate the impact of increased recreational disturbance alone, and may require additional bespoke mitigation measures in line with the Solent Recreation Mitigation Strategy (December 2017). In addition, although the proposed development site for Scenario 2 is larger than Scenario 1 it is still relatively small in comparison with Scenario 3 and is still delivering the same number of houses. We would suggest that the potential challenges with delivering onsite mitigation should be considered if this scenario is to be taken forward, including whether offsite solutions may be required instead. Natural England advise that whilst this scenario does not appear to directly impact any areas identified within the Solent Wader and Brent Goose Strategy, this does not necessarily mean that the land is not functionally linked to Chichester & Langstone Harbour SPA and Ramsar site. We would consider the entire Broad Location of Development (BLD) to be suitable for use by designated bird features and therefore further survey work would be required to determine the scale of impact. Given that the Southbourne Broad Location of Development (BLD) is located within the setting of both the South Downs National Park to the north, and the Chichester Harbour National Landscape (formerly 'Area of Outstanding Natural Beauty') to the south, all development scenarios will need to consider potential landscape impacts. In line with Paragraph 182 of the National Planning Policy Framework, development within the setting of protected landscapes should be sensitively located and designed to avoid or minimise adverse impacts on the designated areas. We would therefore expect any potential impacts to be assessed in line with Paragraph 183 of the NPPF and Section 245 of the Levelling-up and Regeneration Act 2023.

This question is outside of Natural England's remit, and we therefore will not be providing comment.

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Nothing chosen

Following a review of Scenario 3, we agree that the delivery of this scenario has the potential to provide greater benefit to both nature and people with the delivery of the entire Green Ring around Southbourne Parish. In addition, we agree that this scenario is likely to have a lesser impact upon the setting of both Chichester Harbour National Landscape and South Downs National Park given that 800 homes are to be provided over a greater hectarage and the pattern of development is aligned with the existing shape of Southbourne. We are also concerned that the existence of multiple landowners and planning applications across this site could result in a reduced benefit for nature and people, with a likely piecemeal approach to mitigating impacts to designated sites and green infrastructure provision and agree that development should come forward in a coordinated manner to ensure that these elements are dealt with as strategically as possible. Wherever possible, Natural England would strongly encourage benefits to people and nature being considered in a manner that ensures cohesion and the delivery of multiple benefits at scale.

As with the scenarios discussed above, Scenario 3 will also have a likely significant effect upon the Chichester & Langstone Harbour SPA and Ramsar site, as well as the Solent Maritime SAC, due to the increased levels of recreational disturbance and treated effluent being discharged into the site. Given the larger site area (198.2ha) there is a greater likelihood that mitigation such as greenspace provision or woodland planting will be able to be delivered on site, when compared with Scenarios 1 & 2. In addition, there is greater opportunity for large scale green and blue infrastructure provision which has multiple benefits, for example nature-based solutions to flooding. It is important to note that, although built development will not cover the entirety of the 'Secondary Support Area', changes in land use that do not constitute built development may still constitute a loss of suitable foraging habitat for birds identified within the Solent Wader and Brent Goose Strategy. It is not currently clear what the plans are for the remainder of the Broad Location of Development (BLD), but even the provision of open greenspace is likely to adversely impact upon the suitability of the site (as a secondary support area) as there is likely to be a reduction in the availability of appropriate foraging resource as a result of increased recreational activities in this area. Having used our Agricultural Land Classification predictive tool, we would advise at this stage that this scenario would result in the loss of primarily Grade 1 agricultural land rather than Grade 1 and 2. In line with Policy 48 in your authority's currently adopted Local Plan, development of poorer quality land should be fully considered in preference to best and most versatile land and this should be evidenced within application documents.

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Scenario 3: Mixed Scenario, Scenario 2: Land to the East, Scenario 1: Land to the West

This ranking has been given primarily on the basis that Scenario 3 (Mixed Scenario) provides greater opportunities to deliver on-site benefits for both nature and people, which would be harder to achieve in the other two scenarios given their size. In addition, Scenario 3 has the benefit of following the existing layout of Southbourne which should help to minimise impacts upon protected landscapes. It is however important to note that all three scenarios will have similar impacts in terms of nutrient neutrality and recreational disturbance, as well as the potential for land to be functionally linked to Chichester Harbour SPA and Ramsar site. As mentioned, Scenario 3 may find it easier to avoid or mitigate these impacts due to the larger amount of land available and there is likely to be greater opportunities for wildlife connectivity across the site. We would also like to highlight that it is currently unclear what would happen to the land in Scenario 1 if Scenario 2 was to be taken forward, or vice-versa, particularly as planning applications have already been approved within both Broad Locations of Development. It should be noted that if, eventually, both scenarios are to be taken forward leading to 1600 new dwellings in this area then the impact upon both South Downs National Park and Chichester Harbour National Landscape would be significantly greater.

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