Local Plan Review: Preferred Approach 2016-2035

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Local Plan Review: Preferred Approach 2016-2035

Spatial Vision and Strategic Objectives

Representation ID: 1442

Received: 07/02/2019

Respondent: Natural England

Representation Summary:

Natural England supports the vision as it recognises the importance of biodiversity and unspoilt landscape, and access for people to those resources.

Comment

Local Plan Review: Preferred Approach 2016-2035

Local Plan Strategic Objectives

Representation ID: 1444

Received: 07/02/2019

Respondent: Natural England

Representation Summary:

Natural England broadly supports the strategic objectives. However, we would urge the Council to be more ambitious in the greenhouse gas emissions objective, and amend 'minimise the net increase' to 'reduce greenhouse emissions'. Chichester District is at particular risk from the effects of climate change, in terms of sea level rise and cost of flood management infrastructure, but also loss of intertidal habitats (and the species that rely on them) that residents and visitors value.

Comment

Local Plan Review: Preferred Approach 2016-2035

Policy S26: Natural Environment

Representation ID: 1468

Received: 07/02/2019

Respondent: Natural England

Representation Summary:

Natural England recommends explicit reference to Chichester Harbour AONB in the policy.
We recommend reference to the importance of the views from Kingley Vale to the AONB in the supporting text.
We welcome the BMV land policy, though note the conclusions on the Sustainability Appraisal on this point.

Comment

Local Plan Review: Preferred Approach 2016-2035

Policy S27: Flood Risk Management

Representation ID: 1471

Received: 07/02/2019

Respondent: Natural England

Representation Summary:

SuDS are important in addressing water quality impacts of surface water run-off, as well as managing flood risk. Natural England advocates the use of the risk index method in the CIRIA SuDS Manual, to identify the risk of pollutants and the SuDS measures that would mitigate the risk.

Therefore, we recommend amending the text to read:
There should be no increase in either the volume or rate of surface water runoff leaving the site, and the SuDS should be designed to minimise water quality impacts.

Comment

Local Plan Review: Preferred Approach 2016-2035

Policy S30: Strategic Wildlife Corridors

Representation ID: 1497

Received: 07/02/2019

Respondent: Natural England

Representation Summary:

Strategic Wildlife Corridors are important in complying with the NPPF. However, we would like the policy strengthened by widening the corridors (particularly in the east); linking to the SDNP bat protocol; linking to the net gain concept of off site compensation of biodiversity loss; linking to the GI policy; and making it clear that development within or close to the corridor will be avoided.

Object

Local Plan Review: Preferred Approach 2016-2035

Policy S31: Wastewater Management and Water Quality

Representation ID: 1507

Received: 07/02/2019

Respondent: Natural England

Representation Summary:

Natural England's view is that the policy needs redrafting in order to ensure an adverse effect on Chichester Harbour SPA/SAC/Ramsar is avoided.

Our view is that the current evidence base indicates that the overarching policy is sufficient to address potential impacts on Pagham Harbour.

Comment

Local Plan Review: Preferred Approach 2016-2035

Policy S32: Design Strategies for Strategic and Major Development Sites

Representation ID: 1520

Received: 07/02/2019

Respondent: Natural England

Representation Summary:

Given the potential impacts of the strategic allocations on the setting of the National Park and AONB, Natural England recommends including a requirement for the Masterplan to be informed by a Landscape and Visual Impact Assessment.

Comment

Local Plan Review: Preferred Approach 2016-2035

Policy AL1: Land West of Chichester

Representation ID: 1521

Received: 07/02/2019

Respondent: Natural England

Representation Summary:

Natural England supports the biodiversity and landscape clauses in Policy AL1.

However, we recommend amending clause 14 to read:
Be planned with special regard to the need to mitigate potential impacts of recreational disturbance on the Chichester Harbour SAC/SPA/Ramsar including contributing to strategic access management, and providing on-site recreational space; and avoiding/mitigating water quality impacts.

Comment

Local Plan Review: Preferred Approach 2016-2035

Policy AL3: Land East of Chichester

Representation ID: 1523

Received: 07/02/2019

Respondent: Natural England

Representation Summary:

Natural England notes that the Sustainability Appraisal identifies the importance of the pit in the SE of the site for wildlife, and the risk that this allocation will cause harm to the wildlife, and through water quality impacts.

Therefore, Natural England recommends adding a clause to the policy to ensure that the existing biodiversity interest of the site is protected and enhanced, and that a buffer should be left around the pit to minimise disturbance. A Sustainable Urban Drainage Scheme should also be produced to minimise the potential for surface water quality impacts from run-off.

Comment

Local Plan Review: Preferred Approach 2016-2035

Policy AL6: Land South-West of Chichester (Apuldram and Donnington Parishes)

Representation ID: 1526

Received: 07/02/2019

Respondent: Natural England

Representation Summary:

Natural England notes that this is a large allocation site adjacent to the AONB and close the SPA/SAC/Ramsar/SSSI. We welcome clause 6, which requires mitigation for potential impacts on nature conservation sites - our view is that the key issues will be recreational disturbance and water quality (both surface water and sewerage). Given the status of Apuldram WwTW, Natural England's recommendations for policy S31 are particularly important for this site allocation.

Clause 3 is also vital - a Landscape and Visual Impact Assessment will be necessary to identify whether development is possible without harming the setting of the AONB.

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