Chichester Local Plan 2021-2039 - Main Modifications consultation

Use the term "National Landscape" rather than "AONB"

We note that the footnote explains that the Local Plan will refer to Area of Outstanding Natural Beauty (AONB) throughout despite this having been renamed 'National Landscape' in 2023. We would ask that the Council reconsiders this as we would like to see this the other way around, with National Landscape as the correct term used throughout, with the footnote explaining that this was formerly known as an AONB. This would be consistent with the NPPF and the Chichester Harbour Management Plan and would, we feel, avoid confusion for those using the Plan going forwards.

We support the addition of the wording at the end of the first paragraph of objective 2.

We support the additional text to criteria 1 of Policy NE1.

We object to the wording at criterion 5 of Policy NE2 ‘minimise adverse impacts on’ the AONB and SDNP….. and that development proposals should ‘have regard to’ the Chichester Harbour AONB Management Plan…. The Levelling and Regeneration Act 2023 strengthened the duty on all relevant authorities who now must ‘seek to further the purpose’ of the AONB/National Landscape (to conserve and enhance natural beauty). The wording should reflect this. This strengthened duty should also be reflected in the AONB Policy (NE13) or at the very least in the supporting text to it.
We support the additional text referencing the need for LVIAs for small-scale development within the setting of the AONB/National Park.

We are disappointed that the Council is not committing to confirming the landscape gaps identified in their 2019 study but is putting their formal identification off until a future site allocation DPD or neighbourhood plan – this produces uncertainty and makes these areas, which are under huge pressure for development, more vulnerable in the absence of firm policy and precise boundaries. We hope that the 2019 gaps study will still carry significant weight in decisions until such a future document identifies their precise boundaries.

The boundary of the Strategic Wildlife corridors should accord with those set out in the adopted Southbourne Neighbourhood Plan.

Following the discussions at the Local Plan Examination and the evidence put forward by Southbourne Parish Council regarding the evidence base behind the Hambrook Chalk Stream Strategic Wildlife Corridor set out in the neighbourhood plan which is larger than that shown in the Local Plan Map, we are disappointed that the Council proposes to clarify any confusion by confirming that the smaller Local Plan boundary of the corridor will take precedence. We do not understand why the corridor cannot be widened to accord with the Neighbourhood Plan which is based on a detailed evidence base.

We support the addition of criterion c) on coastal squeeze which is such a critical issue contributing to the depletion of nature and therefore must be seriously considered wherever relevant.

Delete this policy altogether.

Whilst we note the Council adding clarification that Policy A12 would only apply in the event that the committed supply of dwellings already permitted does not come forward; we feel that this is unhelpful and unclear and that the Policy should be deleted altogether, to provide greater certainty to developers, the community and other groups. The idea that the neighbourhood plan steering group would have to be responsible for keeping track of which permissions are built out at any one time and therefore what the latest shortfall would be in order to work out whether Policy A12 applies or not is unreasonable and unrealistic, it is not the job of the Parish to do this.

Include a map of all site allocations

Overall we feel that the Local Plan consultation is not user-friendly. The consultation should provide a clear map showing all allocations within the District, as has been done for the Havant Local Plan consultation. Otherwise it is off-putting for the average person to try to wade through everything to try to understand what is being planned, and less people will engage with the process.

Add reference to the strengthened duty to seek to further the purpose of the AONB/National Landscape

We appreciate that this consultation is on the main modifications only, however, Policy NE13 should refer to the new strengthened duty on all relevant authorities to 'seek to further the purpose' of the AONB / National Landscape. This is a key point from the legislation for any decision-taker. Attached is the the ‘Applying the CRoW Act section 85 duty to ‘seek to further the purpose’ in National Landscapes (AONBs) briefing paper November 2024.