Local Plan Review: Preferred Approach 2016-2035

Comment

Representation ID: 2724

Received: 07/02/2019

Respondent: Sussex Wildlife Trust

The PAP commits to delivering significant growth of the horticultural industry within this policy. In addition to this we highlight that CDC have made commitments to water savings in Policy S31. We seek clarity on how this significant growth by the horticultural industry will support commitments to water efficiency in an already water stressed area? We recommend that this issue is addressed in future versions of the plan.

Support

Representation ID: 2725

Received: 07/02/2019

Respondent: Sussex Wildlife Trust

We support this policy recognising green infrastructure within its provision in line with paragraph 171 of the NPPF. However, we do note inconsistencies within the PAP and seek clarity on whether the term 'green infrastructure' in this policy also captures blue assets. For example, the glossary for the PAP does not refer

to blue assets within the definition of Green Infrastructure. Yet the supporting text (5.61) for Policy S29: Green infrastructure does recognise the blue aspect of green infrastructure.

Support

Representation ID: 2726

Received: 07/02/2019

Respondent: Sussex Wildlife Trust

Acknowledge the positive steps this policy is taking to ensure provision of an enhanced network of green infrastructure and access to natural green spaces. We feel that this bullet point is vital if CDC is to uphold its environmental objectives against backdrop of significant development in and around Chichester City.

CDC acknowledges the possibility of a Supplementary Planning Document (SPD). Support an approach that will ensure opportunities to deliver natural capital and measureable net gains in biodiversity are planned for at an early stage. Will embed the requirements as a realistic and expected part of sustainable development in the area.

Support

Representation ID: 2727

Received: 07/02/2019

Respondent: Sussex Wildlife Trust

SWT is very supportive of any initiative to deliver an integrated transport strategy for Chichester City which conforms to the Government's transport hierarchy that sets the clear priorities of:
* Reducing the need to travel
* Switching to sustainable modes
* Managing existing networks more effectively
* Creating extra (car-related) capacity only when alternative methods have been fully explored

CDC must invest in innovative and modern strategies that focus on local journeys, air pollution and the production of sustainable transport options.

Support

Representation ID: 2728

Received: 07/02/2019

Respondent: Sussex Wildlife Trust

We are supportive of the 5th bullet point within this policy which highlights the importance of Green Infrastructure and landscape to enhance biodiversity and meet recreational needs, including public rights
of way. This is in line with paragraph 20d and 91c of the NPPF.

Comment

Representation ID: 2729

Received: 07/02/2019

Respondent: Sussex Wildlife Trust

SWT is supportive of CDC's commitment to an improved integrated transport network which we hope will conform to the Government's transport hierarchy.
Raise deep concerns about new Birdham Road to A27 Fishbourne Link road proposal as we are aware of the priority habitats of chalk stream and coastal grazing marsh being present, along with the close proximity to Lavant Marsh LWS and Chichester Harbour SPA/SAC/SSSI and Ramsar.

Remind CDC this area is within the Site of Special Scientific Interest Impact Risk Zone, which affects the SAC, SPA and Ramsar designations.

Question the survey data against biodiversity needs.

Support

Representation ID: 2730

Received: 07/02/2019

Respondent: Sussex Wildlife Trust

The Sussex Wildlife Trust supports the statement in section 5.37 that 'The plan area's countryside is an important and diminishing resource'. However, the policy wording fails to specifically reference the natural environment or biodiversity despite it being recognised in the support text and an intrinsic component.

Comment

Representation ID: 2731

Received: 07/02/2019

Respondent: Sussex Wildlife Trust

SWT is supportive of the inclusion in the PAP of a strategic policy for the Natural Environment. However we object to the weak policy commitment in section 5.51 to 'not cause significant harm' to the natural environment, and that 'landscape and biodiversity is not unduly compromised'. The wording is not nearly strong enough and does reflect the aims of Defra's 25 Year Plan for the Natural Environment. CDC have responsibilities both under the NPPF to deliver net gains in biodiversity and under section 40 of the Natural Environment and Rural Communities Act 2006 to have regard for biodiversity.

Comment

Representation ID: 2732

Received: 07/02/2019

Respondent: Sussex Wildlife Trust

SWT supports the statement made in section 5.61 which recognises the blue aspects of green infrastructure, however we feel that this is inconsistently represented throughout the rest of the PAP.
we are concerned that section
5.62 highlights that:

New green infrastructure is to be provided as part of the development at selected Strategic Development Locations....

We question why CDC have proposed only selected strategic development sites when there is a clear need to enhance the District's GI network.

Support

Representation ID: 2733

Received: 07/02/2019

Respondent: Sussex Wildlife Trust

We support CDC in its progressive move to include a strategic wildlife corridor policy within its strategic policies.
With regards to the policy word we seek clarity on what bullet point one means when it refers to 'sequentially preferable site'. We see that the Glossary for the plan does include a definition for sequential test but not sequentially preferable site.