Local Plan Review: Preferred Approach 2016-2035

Object

Representation ID: 2773

Received: 07/02/2019

Respondent: Sussex Wildlife Trust

SWT is concerned that the impacts on Pagham Harbour SPA and in particular the importance of functionally linked supporting habitat for Dark-bellied Brent Geese, have not been sufficiently considered by CDC. As mentioned previously we do not think it is sufficient to simply use policy wording to require mitigation. For the allocation to be deliverable there must be sufficient confidence that avoidance of adverse impacts can be achieved. In the case of policy AL8, there needs to be recognition that both recreational disturbance and the loss of functionally linked supporting habitat needs to be avoided.

Comment

Representation ID: 2778

Received: 07/02/2019

Respondent: Sussex Wildlife Trust

SWT notes that policy AL9 includes a specific requirement for development to demonstrate that it would not have an adverse impact on the nature conservation interests of identified sites and habitats. We support the inclusion of this requirement, although as per the revised NPPF, it should also require net gains to biodiversity. However we question why this requirement is not included in any of the previous site allocations when they clearly will also impact on 'nature conservation interests'. Despite this requirement, the policy still needs to be strengthened

Object

Representation ID: 2781

Received: 07/02/2019

Respondent: Sussex Wildlife Trust

SWT is concerned about the number of dwelling allocated for this parish, given its current size and proximity to designated sites. We note that unlike for many other strategic allocation policies, there is no recognition in the supporting text of the presence of a Local Wildlife Site within the parish, this should be amended. We also question why recreation disturbance is not noted as an adverse impact on the nearby SPA to be avoided. An allocation of this size will likely result in an increase in visitors to the Harbour.

Comment

Representation ID: 2784

Received: 07/02/2019

Respondent: Sussex Wildlife Trust

Whilst SWT supports the recognition of Hunston Copse LWS in section 6.72, it is not clear why Chichester Canal LWS which also passes through the Parish is not mentioned. there is a particular requirement in section 6.77 for development to protect and enhance non-designated sites and their setting. We question why it is not included in the supporting text of other allocations which may impact on LWS or in the policy wording for AL11. We ask CDC to be more consistent in their recognition of LWS as per paragraph 174 of the NPPF and recommend amendments in this case:

Object

Representation ID: 2787

Received: 07/02/2019

Respondent: Sussex Wildlife Trust

SWT objects to this allocation as we have no confidence that the value of this site as functional linked supporting habitat has been sufficiently assessed. As stated in our comments in relation to the HRA the lack of robust evidence in terms of the usage to farmland in Chichester District by Dark-bellied Brent Geese is concerning. It is irresponsible of CDC to allocate a site for development without sufficient knowledge of whether it is deliverable in terms of the requirements of the Habitat Regulations.

Whilst we maintain our objection, if CDC choose to progress the allocation then we request amendments.

Object

Representation ID: 2791

Received: 07/02/2019

Respondent: Sussex Wildlife Trust

As stated for previous allocations and in our general comments, SWT is unclear why concerned as to whether the level of development proposed in AL13 can be absorbed within this parish. We also note, that again both the GI and biodiversity requirements of the plan are unambitious and should be amended

Comment

Representation ID: 2793

Received: 07/02/2019

Respondent: Sussex Wildlife Trust

Similarly to allocation AL13, we question the size of the allocation for Tangmere. In addition to our standard concerns over the GI and biodiversity requirements, we also note that there is no reference made in the supporting text to the chalk stream priority habitat within the site. This should be rectified.

Object

Representation ID: 2799

Received: 07/02/2019

Respondent: Sussex Wildlife Trust

Slightly concerned about policy as support text highlights some potential facilities in 7.44 but acknowledges list is not exhaustive. As we progress to the policy wording, the first sentence references land currently or last used for community facilities, public services, leisure and cultural uses. Potential uncertainty as to what is covered as 'a facility', we recommend that the policy includes wording which acknowledges the site/land may form part of Green Infrastructure Network and therefore the integrity of network should be considered. This would be consistent with DM34 approach: Open space, sport and recreation including indoor sports facilities and playing pitches.

Support

Representation ID: 2802

Received: 07/02/2019

Respondent: Sussex Wildlife Trust

We are pleased to see this policy acknowledge biodiversity and encourage CDC to ensure the wording reflects the ethos of measurable net gains to biodiversity in paragraph 174b of the NPPF. SWT therefore make the suggested amendments to bullet point 9:

9.The natural environment and biodiversity will be protected and/or where appropriate provision will be made for improvements to deliver measureable net gains to biodiversity areas and green infrastructure;

Support

Representation ID: 2808

Received: 07/02/2019

Respondent: Sussex Wildlife Trust

Whilst SWT strongly supports the inclusion of this policy, we are concerned that the reference to protecting biodiversity it only in relation to the designated sites. The coast may include areas of biodiversity value, such as priority and irreplaceable habitats (for example vegetated shingle and saltmarsh), which sit outside the designated sites. We therefore recommend amendment to bullet point 1