Local Plan Review: Preferred Approach 2016-2035

Comment

Representation ID: 2830

Received: 07/02/2019

Respondent: Sussex Wildlife Trust

SWT recommends inclusions/amendments to the glossary:
* Inclusion of the definition of Ancient or veteran tree
* Inclusion of the definition of Brownfield Site Green infrastructure definition to included blue assets
* Inclusion of term Protected Species
* Rename the term Sites of Nature Conservation importance as Local Wildlife Site
* Inclusion of the definition for Sequential Preferable Site

Comment

Representation ID: 2838

Received: 07/02/2019

Respondent: Sussex Wildlife Trust

Section 2.24 of the PAP references Sites of Nature Conservation Importance, we recommend that this is updated to reflect that sites are now referred to as Local Wildlife Sites (LWS). This is a national move to ensure that all locally designated sites are consistently referenced, especially within the planning system.

In section 2.29 SWT recommends that the penultimate bullet point is revised both to include geodiversity and locally designated sites. Paragraphs 171 and 174 of the NPPF are clear that locally designated sites must be safeguarded in plans in order to protect and enhance biodiversity.

Comment

Representation ID: 2842

Received: 07/02/2019

Respondent: Sussex Wildlife Trust

Section 3.1 does not show a strong enough commitment to the natural environment as required by the revised NPPF, which is much more progressive in its approach. The term supporting should be strengthened to reflect the need to protect, conserve and enhance the natural environment.

Section 3.2 includes the vision and we are pleased to see biodiversity and the wider natural environment recognised within this. Further opportunity to include net gains to Natural Capital and recognise the need for climate change resilience.

Comment

Representation ID: 2853

Received: 07/02/2019

Respondent: Sussex Wildlife Trust

Section 3.3 of the PAP refers to good access to a range of employment opportunities and affordable housing, we seek clarity on what good access means? Does this vision reflect the requirement for development to be sustainable and in particular planning which limits the need to travel and offers a genuine choice of transport modes (NPPF paragraph 103)?
A large amount of development is focused on the East-West corridor. No acknowledgement of the need for protection and likely need for growth of area's natural capital in order to deliver the ecosystem services required to support development.

Comment

Representation ID: 2854

Received: 07/02/2019

Respondent: Sussex Wildlife Trust

Manhood Peninsula
SWT welcomes the amendments that have been made to this section of the plan following our 2017 comments. As a result the 'rural hinterland' is now included alongside the coast and surrounding countryside for protection.

We still suggest that there is an opportunity to reflect the area's value in terms of ecosystem services delivery, in particular in relation to flood resilience.

Comment

Representation ID: 2855

Received: 07/02/2019

Respondent: Sussex Wildlife Trust

SWT supports the spirit of the objectives and are pleased to see a group of 'environmental objectives'. However we would like to see a stronger commitment to net gains to biodiversity and acknowledgement of the need for a growth in the natural capital of the district in order to support development, in line with paragraphs 171 and 174 of the NPPF. We recommend the inclusion of an additional bullet point

Comment

Representation ID: 2860

Received: 07/02/2019

Respondent: Sussex Wildlife Trust

Section 4.4 - expected to see a reference to ecological networks and green infrastructure influencing decisions. Little evidence relating to the need to 'identify, map and safeguard components of local wildlife-rich habitats and wider ecological networks'. Expect CDC to incorporate more thorough evidence base. Very little information on state of District's environment. Concern about potential location of new settlement of up to 3,000 dwellings as no information provided to demonstrate this is a feasible option. No confidence the evidence base will be used to inform potential locations for a new settlement. Section 4.33 does'n include natural capital impacts and investment