Local Plan Review: Preferred Approach 2016-2035

Comment

Representation ID: 2734

Received: 07/02/2019

Respondent: Sussex Wildlife Trust

Having viewed this policy we note that it captures standards for water consumption in new development. This seems to be focused on households and suggests standard of a maximum of 110 litres per person per day. Whilst we support this requirement, given the plan's commitment to delivering significant growth in the horticultural sector, we ask how water consumptions standards in this policy would apply to these developments, as we do not feel it is clear from the policy or supporting text.

Comment

Representation ID: 2735

Received: 07/02/2019

Respondent: Sussex Wildlife Trust

We do not think that the evidence base for the PAP is sufficient in terms of assessing the ability of the District's natural capital to absorb the level and location of development proposed.
in general, the level of greenfield development proposed is concerning. Little consideration of brownfield alternatives contrary to paragraph 117 of the NPPF.
Little explanation of how the housing numbers were divided up between settlements of the same type (policy S2). No consideration of recreation disturbance for Chichester and Pagham Harbours. Green infrastructure requirements to be delivered before any new dwellings are occupied within a site.

Comment

Representation ID: 2736

Received: 07/02/2019

Respondent: Sussex Wildlife Trust

SWT supports the inclusion of this policy, particularly given the large number of dwellings planned within strategic allocations. However, whilst it includes a requirement for proposals to consider green infrastructure, there is a lack of detail regarding biodiversity. In particular, we think section 1d currently confounds several planning issues, which means neither are given appropriate weight in the policy. As stated previously, CDC need to be more proactive and ambitious when it comes to delivering green infrastructure enhancements for the District.

Comment

Representation ID: 2737

Received: 07/02/2019

Respondent: Sussex Wildlife Trust

SWT is concerned there is no recognition of net gains to biodiversity within the policy, in particular the presence of a chalk stream, which is priority habitat, within the allocation site and parkland priority habitat adjacent to site. Should be noted section 6.14 with Brandy Hole Copse LNR and ancient woodland.

The term 'mitigation' used in relation to protecting nearby SPA from adverse impacts. Habitat Regulations clear that adverse impacts must be avoided. This is the purpose of strategic mitigation strategy. If this strategy is not resulting in avoidance of impacts then it is not effective and not legally compliant.

Object

Representation ID: 2739

Received: 07/02/2019

Respondent: Sussex Wildlife Trust

SWT does not believe this policy is ambitious enough in terms of the enhancements to biodiversity and green infrastructure that need to be delivered in order to ensure that the development is truly sustainable. All the other requirements in the policy, for example in relation to views and road access are written as 'absolute musts' whereas criteria for green infrastructure reads as a much softer 'nice to have'. This is not acceptable in terms of the NPPF, in particular the requirement to safeguard components of ecological networks (174) and conserve and enhance the natural environment, including green infrastructure (20).

Object

Representation ID: 2747

Received: 07/02/2019

Respondent: Sussex Wildlife Trust

-Concerned about the very broad housing number associated with this allocation. States a minimum of 600 dwellings, the supporting text refers to the possibility of 1000.
-Unclear how such a difference can be planned for in terms of impacts on natural and deliver the required green infrastructure and natural environment enhancements.
-Must be a robust assessment of the true capacity of this allocation taking into consideration impacts on natural capital assets, e.g. gravel pits have high
biodiversity value in terms of breeding birds.
-Reference to Chichester Harbour and SPA unclear.
-Requirement for green infrastructure is unambitious.

Comment

Representation ID: 2750

Received: 07/02/2019

Respondent: Sussex Wildlife Trust

SWT are concerned about the suggestion of a 'new linear greenspace with public access' along the River Lavant floodplain. Any progression of this would need to consider the potential impacts of recreational disturbance on riverine habitats. We also recommend that there is assessment of the potential for any greenspace to contribute to natural flood management of the river.

As stated for the previous allocations, SWT recommend that the policy is amended in terms of its ambitions for green infrastructure provision and biodiversity net gains:

Comment

Representation ID: 2754

Received: 07/02/2019

Respondent: Sussex Wildlife Trust

As the only brownfield site allocated as a strategic allocation, CDC should aim to be more progressive in realising opportunities site could deliver in terms of green infrastructure and biodiversity net gains. NPPF states green infrastructure used in new development to avoid increased vulnerability to impacts arising from climate change. Southern Gateway is a fantastic opportunity to incorporate innovative design, particularly increased green infrastructure e.g. green walls.

SWT objects to the term 'mitigation' in relation to protecting nearby SPA from adverse impacts. If this strategy is not resulting in avoidance of impacts then is not effective and not legally compliant.

Object

Representation ID: 2770

Received: 07/02/2019

Respondent: Sussex Wildlife Trust

SWT objects to this allocation as no evidence is provided to demonstrate the development, in particular the new road, can be achieved without significant harm to the environment e.g. Lavant Marsh LWS and chalk stream that runs through the site. site falls within Impact Risk Zone for the Chichester Harbour SSSI.
In the absence of adequate survey data to assess the impact of this proposal on biodiversity and demonstrate that measurable net gains to biodiversity are achievable the site should not be allocated. Ucceptable for the provision of this crucial environmental information to be left until planning application stage.

Object

Representation ID: 2772

Received: 07/02/2019

Respondent: Sussex Wildlife Trust

As in other comments, the requirement for green infrastructure in policy AL7 is unambitious and does not align with the requirements of paragraphs 20 and 174 of the NPPF. Additionally there needs to be some recognition of the presence of a chalk stream which is a priority habitat.