Local Plan Review: Preferred Approach 2016-2035

Natural England is concerned that this allocation scored poorly in the Sustainability Appraisal (SA), particularly in relation to waste water treatment, landscape and BMV land.

The SA states that Bosham WwTW does not have the capacity to take effluent from the site. Please see Natural England's comments under S31 and regarding the HRA. Clause 9 should be amended to include water quality as well as recreational impacts.

A LVIA should inform the site allocation as to whether views from the NP or AONB will be affected, and whether mitigation is possible without harming the open character of the site.

The Sustainability Appraisal identifies a problem with waste water treatment for this allocation. Please see Natural England's comments on S31, which apply to this site, in terms of avoiding an adverse effect on the integrity of Chichester Harbour SPA/SAC/Ramsar from water quality impacts.

Clause 8 should be amended as potential issues include recreational disturbance and water quality from foul sewerage.

Reference should be made in the supporting text to the Solent Wader and Brent Goose Strategy which maps important areas for SPA birds, and provides guidance on mitigation.

Natural England recommends amending clause 9 to add potential recreational disturbance and water quality impacts from sewerage. Please see Natural England's comments on S31 and the HRA regarding waste water quality impacts.

We recommend amending the supporting text to refer to the Solent Wader and Brent Goose Strategy (SWBGS), which identifies sites important for SPA birds, and provides guidance on mitigation. However, the allocation of sites in the parish should follow the 'avoid, mitigate, compensate' hierarchy and seek to avoid sites identified by the SWBGS.

Natural England notes that the HRA states that Hunston connects to Pagham WwTW. The Examination of the Arun Local Plan concluded that the headroom at Pagham WwTW would not support all of the housing allocations in Pagham, so connections to other treatment works in Arun were needed. Natural England would not support increasing the discharge consent at Pagham WwTW due to impacts on the SPA/Ramsar. Therefore, there is likely to be a significant effect from the Hunston allocation, in combination with planned development in Arun.

Clause 9 should read 'run-off into a designated site' and include waste water quality impacts.

If Park Farm is regularly used as foraging habitat by brent geese associated with Pagham Harbour SPA, then the first step should be to avoid that impact, and mitigate only if there are no other suitable development sites.

Clause 9 should include reference to recreational disturbance and water quality impacts.

Natural England's comments on S31 apply to potential allocations in Southbourne.

Reference should be made in the supporting text to the Solent Wader and Brent Goose Strategy, which maps important sites for SPA birds. These areas should be avoided when allocating sites in the Neighbourhood Plan.

In line with the HRA recommendations, this policy should make it clear that tourist accommodation must contribute to relevant strategic access management strategies to mitigate recreational disturbance to SPAs.

The second part of this policy needs amending, as the period of occupancy is not necessarily dependent on the degree of protection desirable to reduce disturbance to designated site. Instead, it should be made clear that caravan or camping accommodation needs to contribute to the relevant strategic access management strategy. In line with CDC policy, a pro rata contribution may be made if the site is not open for part of the season.

Natural England advocates a target of 100l/person/day. This is in line with Southern Water's policy. Whilst we note that Portsmouth Water supplies most of the District, Southern Water supplies the northern part.

Natural England supports the inclusion of a policy for achieving biodiversity net gain.

This is in line with the NPPF, and the Government's 25 year Environment Plan. Natural England would welcome the opportunity to work with CDC on the implementation of the net gain policy. We recommend including more detailed guidance for developers on achieving net gain, and suggest the following measures are incorporated into the Local Plan, either through policy wording, or a more detailed guidance:

* Biodiversity metric - developers should apply the Defra biodiversity metric, which is a clear and methodical calculation for net gain in biodiversity for individual planning proposals. The metric is currently being updated by Defra and Natural England to include a wider range of habitat types and incorporate wider benefits of Green Infrastructure (GI).

* Net gain plans - larger applications (and at least strategic allocations) should be required to submit a net gain plan which clearly sets out the ecological issues of the proposals, including clear accounting for residual biodiversity loss and how this is addressed, as well as additional 'net gain' provision which can be on and/or off-site.

You may wish to consider what threshold may be applied to development. We advise that where known ecological interests occur (e.g. ponds, bat roosts etc.), or proposals involving at least 0.1ha of greenfield land, a net gain plan should be required to address these issues.

A standard template for net gain plans may be useful to provide consistency and to facilitate policy reporting and auditing.