Local Plan Review: Preferred Approach 2016-2035

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Comment

Local Plan Review: Preferred Approach 2016-2035

Policy DM29: Biodiversity

Representation ID: 2932

Received: 06/02/2019

Respondent: CPRE Sussex

Agent: CPRE Sussex

Representation Summary:

Issues with net gain. We are disappointed that Chichester DC does not appear to want to take a lead on this topic and set a standard for other authorities. Given the time scale of the plan (to 2035) it is very likely that the statutory requirement for net gain will be in place, and we would wish to see the principle more firmly established in this plan. This would also be consistent with the statements made in Section 5 on Design Standards and Policy DM18 on Sustainable Design and Construction.

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Comment

Local Plan Review: Preferred Approach 2016-2035

Policy DM30: Development and Disturbance of Birds in Chichester, Langstone and Pagham Harbours Special Protection Areas

Representation ID: 2933

Received: 06/02/2019

Respondent: CPRE Sussex

Agent: CPRE Sussex

Representation Summary:

We are pleased to see the inclusion of this important issue in such an important bird area. However, we are puzzled by the suggestion that mitigation strategies are realistic in this context. There is no indication of what the package of measures (b) might be. Some examples might be helpful. Any such proposal will be very carefully monitored by many organisations and local people. Transparency in these processes is essential.

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Comment

Local Plan Review: Preferred Approach 2016-2035

Policy DM31: Trees, Hedgerows and Woodlands

Representation ID: 2934

Received: 06/02/2019

Respondent: CPRE Sussex

Agent: CPRE Sussex

Representation Summary:

We welcome the inclusion of this issue and trust that the 'exceptional circumstances' will be extremely rare. Item 2 is unacceptable. The myth that you can replace protected trees, non-protected trees, woodlands and hedgerows is truly unsustainable, and therefore in conflict with your policy statements. The timescale to replace these features properly is much longer than the timescale of your plan.

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Comment

Local Plan Review: Preferred Approach 2016-2035

Policy DM32: Green Infrastructure

Representation ID: 2935

Received: 06/02/2019

Respondent: CPRE Sussex

Agent: CPRE Sussex

Representation Summary:

It might be helpful if this Policy had a slightly different name to avoid confusion with S29 which seems to refer to the Strategic Sites. We welcome the protection and improvement of green infrastructure in the plan, as well as the requirement not to dissect the linear network of cycle ways, rights of way and ecological corridors, subject to our comments on S14.

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Comment

Local Plan Review: Preferred Approach 2016-2035

Policy S3: Development Strategy

Representation ID: 2936

Received: 06/02/2019

Respondent: CPRE Sussex

Agent: CPRE Sussex

Representation Summary:

Use of Green Spaces: We believe that the destruction of green spaces for housing and other development should be a policy of last resort. The document hardly mentions the use of brownfield sites, or the possibility of creative ideas to make brownfield sites available for housing development. No obvious policies within the document which show how that sequential test has been used in relation to brownfield sites, other than a general approach of guiding development towards larger towns. No reference is given to the Council's Brownfield register and unclear how this fits into the overall strategy for development.

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Comment

Local Plan Review: Preferred Approach 2016-2035

Policy S4: Meeting Housing Needs

Representation ID: 2937

Received: 06/02/2019

Respondent: CPRE Sussex

Agent: CPRE Sussex

Representation Summary:

Please can you confirm as to whether further stages of plan development will use the new national formula for calculating housing need?

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Comment

Local Plan Review: Preferred Approach 2016-2035

Policy S11: Addressing Horticultural Needs

Representation ID: 2938

Received: 06/02/2019

Respondent: CPRE Sussex

Agent: CPRE Sussex

Representation Summary:

This policy supports a large amount of new glasshouse development (in excess of 200,000 square metres) over the plan period. This activity is particularly exposed to the impacts of Brexit (both +ve and -ve) and the overall amount of new development required will need to be kept under review.
We are concerned about the impact of light pollution on the AoNB arising from such developments. This topic has been the subject of research by CPRE, See CPRE 'nightblight maps' (www.nightblight.cpre.org.uk page 153).

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Comment

Local Plan Review: Preferred Approach 2016-2035

Policy S12: Infrastructure Provision

Representation ID: 2939

Received: 06/02/2019

Respondent: CPRE Sussex

Agent: CPRE Sussex

Representation Summary:

We are concerned that there is a real risk that development and supporting infrastructure will continue to be out of step in some places.

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Support

Local Plan Review: Preferred Approach 2016-2035

Policy S13: Chichester City Development Principles

Representation ID: 2940

Received: 06/02/2019

Respondent: CPRE Sussex

Agent: CPRE Sussex

Representation Summary:

We support the requirement to protect views of the Cathedral (but please see response to AL6).

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Comment

Local Plan Review: Preferred Approach 2016-2035

Policy S14: Chichester City Transport Strategy

Representation ID: 2941

Received: 06/02/2019

Respondent: CPRE Sussex

Agent: CPRE Sussex

Representation Summary:

Welcome plans to improve public transport, walking and cycling, and to protect existing footpaths and cycleways, do not feel these proposals are strong or clear enough to contribute to much needed reduction in private car use in Chichester area. Assurances needed that well established routes will be protected and improved, e.g. Centurion Way adjacent to Western development. Clear cycleway routes need to be identified and safe for general use. These routes must enable people to cycle and/or walk from developments on the fringe of the city into the City Centre as well as giving easy access to the countryside

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