Local Plan Review: Preferred Approach 2016-2035

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

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.

Natural England broadly supports policy S26 on the Natural Environment. However, we recommend that explicit reference is made to Chichester Harbour AONB in the second bullet point (though recognising that DM19 is the policy for the AONB). We would also like the Plan to acknowledge the importance of views from the SDNP (at Kingley Vale) to the AONB, and strive to protect this connection. We suggest the visual link between the two protected landscapes could be referred to in the supporting text.

We welcome the policy regarding best and most versatile land. Though we note that the Sustainability Appraisal concluded that the majority of greenfield allocations would impact BMV land.

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.

Natural England welcomes the fact that the Council has identified strategic wildlife corridors. Our view is that this is important in meeting the requirements of the NPPF paragraph 170(d) for ecological networks.

However we would like to work with the Council to improve the policy in the following ways:
- The corridors are rather narrow, particularly in the 'East of the City', limiting their value for people and wildlife.
- links should be made to the National Park's bat protocol - there is significant opportunity for enhancement of habitat for foraging bats.
- We suggest amending clause 3 to include development further from the corridor, eg link could be made with the concept of net gain for biodiversity, whereby development could compensate for biodiversity loss by contributing to enhancement work within the corridor.
- Link should also be made to the Green Infrastructure policy as there is opportunity to create habitat for people and wildlife.
- We suggest amending clause 1 to make it clear that development within and in close proximity to the corridors will be avoided in the first instance.

Whilst Natural England supports the intention of Policy S31 in minimising the impact of waste water on catchments, we concur with the Habitats Regulations Assessment (HRA) that protective policies are needed to avoid an adverse effect from water quality impacts on the integrity on Chichester Harbour both alone and in combination (and in combination for Langstone Harbour). In order to fulfil these requirements our view is that some redrafting is required.

At this time the evidence base for Pagham harbour water quality impacts is further behind that of Chichester and the overarching policy is sufficient to protect this harbour. However Natural England wish CDC to note that investigations into Pagham harbour water quality are planned with completion by 2022. We will therefore, update CDC on these investigations and any implications for their planning policies to feed into the next Plan review.

Further detail on water quality impacts in relation to Chichester (and Pagham) Harbour is set out in our response to the HRA.

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.

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.

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.

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.