Environmental Report March 2016

Strategic Environmental Assessment of the East Wittering and Bracklesham Neighbourhood Plan

Environmental Report

March 2016

Strategic Environmental Assessment of the East Wittering and Bracklesham Neighbourhood Plan

Environmental Report

LC-176 Document Control Box Client Chichester District Council Strategic Environmental Assessment of the East Wittering and Report Title Bracklesham Neighbourhood Plan: Environmental Report Status Final Filename LC-176_EWB_NDP_SEA_15_070316FG.docx Date 7th March 2016 Author AGP Checked SBS Approved NJD

Front credit: Beach Chalet by John Schulze

SEA of the East Wittering and Bracklesham NDP March 2016 LC-176_EWB_NDP_SEA_15_070316FG.docx

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Lepus Consulting Ltd (Lepus) has prepared this draft report areas, flood risk areas and watercourses, and the range of for the use of Chichester District Council. There are a uses taking place. The assessment was prepared between number of limitations, which should be borne in mind when September 2015 and March 2016 and is subject to and considering the results and conclusions of this report. No limited by the information available during this time. party should alter or change this report whatsoever without written permission from Lepus. This report has been produced to assess the sustainability © Lepus Consulting Ltd effects of the Neighbourhood Plan and meets the requirements of the SEA Directive. It is not intended to be a

SEA is a tool for predicting potential significant effects. The substitute for Environmental Impact Assessment (EIA) or actual effects may be different from those identified. Appropriate Assessment (AA). For further information on Prediction of effects is made using an evidence-based the differences between the products please see: approach and incorporates a judgement. http://www.rspb.org.uk/Images/environmentalassessment _tcm9- 257008.pdf

The assessments above are based on the best available information, including that provided to Lepus by the Council Client comments can be sent to Lepus using the following and information that is publicly available. No attempt to address. verify these secondary data sources has been made and 1 Bath Street, they have assumed to be accurate as published. Cheltenham

Every attempt has been made to predict effects as Gloucestershire accurately as possible using the available information. GL50 1YE Many effects will depend on the size and location of Telephone: 01242 525222 development, building design and construction, proximity E-mail: [email protected] to sensitive receptors such as wildlife sites, conservation www.lepusconsulting.com

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1 Introduction ...... 7 1.1 Introduction ...... 7 1.2 History of the NDP ...... 7 1.3 The SEA process ...... 8 1.4 Best Practice Guidance ...... 9 1.5 Structure of the NDP ...... 11 1.6 Meeting the SEA Directive requirements ...... 11 1.7 How the NDP SEA has evolved ...... 13 1.8 Relationship with the Local Plan ...... 14 2 Scoping ...... 15 2.1 Introduction ...... 15 2.2 Policy, plan and programme review ...... 15 2.3 Baseline data and information ...... 16 2.4 Key SEA issues ...... 16 2.5 The SEA Framework ...... 18 3 Reasonable Alternatives ...... 20 3.1 Introduction ...... 20 3.2 Identifying reasonable alternatives ...... 21 3.3 Distribution options ...... 21 3.4 Individual sites ...... 22 3.5 Best performing option ...... 24 4 Appraisal Methodology ...... 25 4.1 Assessment of the East Wittering and Bracklesham NDP ...... 25 4.2 Approach to the appraisal ...... 25 4.3 In-combination effects assessment ...... 26 4.4 Sources ...... 27 4.5 Assumptions and limitations ...... 29 5 Appraisal Findings ...... 33 5.1 Introduction ...... 33 5.2 Policy 1: A Spatial Plan for the Parish ...... 33 5.3 Policy 2: Housing Site Allocations ...... 34 5.4 Policy 3: Design ...... 35 5.5 Policy 4: East Wittering/Bracklesham Green Infrastructure ...... 36 5.6 Policy 5: Open Spaces and Seafront ...... 37 5.7 Policy 6: Natural Environment ...... 37 5.8 Policy 7: Schools ...... 37 5.9 Policy 8: Employment/Service Hub ...... 38 5.10 Policy 9: Local Employment ...... 38 5.11 Policy 10: Medical Service Centre ...... 39 5.12 Policy 11: East Wittering Village Centre ...... 39 5.13 Policy 12: Bracklesham Village Centre ...... 40

5.14 Policy 13: Local Tourism ...... 40 5.15 Assessment of in-combination effects ...... 41 6 Significant effects and mitigation ...... 44 6.1 Introduction ...... 44 6.2 Significant effects, mitigation and uncertainty ...... 44 6.3 SEA Objective 1: Biodiversity and Geodiversity ...... 45 6.4 SEA Objective 2: Natural Resources ...... 46 6.5 SEA Objective 6: Climate change adaptation ...... 46 6.6 SEA Objective 7: Transport ...... 46 6.7 SEA Objective 12: Health and wellbeing ...... 47 7 Reasonable Alternatives: Outline of the reasons for selection and rejection ...... 48 7.1 PPG advice on the selection of reasonable alternatives ...... 48 7.2 Distribution options ...... 48 7.3 Identifying reasonable alternatives for sites ...... 49 7.4 Reasons rejected site options were not taken forward ...... 49 7.5 Reasons for selecting the preferred approach ...... 50 8 Recommendations to enhance environmental performance ...... 52 8.1 Introduction ...... 52 8.2 Recommendations for enhancement ...... 52 9 Monitoring ...... 54 9.1 Monitoring proposals ...... 54 9.2 Links with the Annual Monitoring Report ...... 56 10 Next Steps ...... 57 10.2 Commenting on the Environmental Report ...... 58 11 References ...... 59

Appendix A: SEA Framework

Appendix B: Assessment Protocol

Appendix C: Reasonable Alternatives: assessment of distribution options Appendix D: Reasonable Alternatives: assessment of site options

Table N.1 Potential positive environmental effects of the NDP Table N.2 Potential negative environmental effects of the NDP

Table 1.1 List of NDP policies Table 1.2 Meeting the requirements of the SEA directive

Table 2.1 SEA Objectives

Table 3.1 Reasonable alternatives to distribution options

Table 3.2 Distribution option assessment results

Table 3.3 Reasonable alternatives to Policy 2 of the Pre-Submission NDP policies

Table 3.4 Site assessment results

Table 4.1 Key to the matrix assessment

Table 4.2 Key data sources

Table 5.1 Assessment of in-combination effects

Table 6.1 Results of policy appraisals

Table 7.1 Reasons for not taking forward alternatives to Policy 2

Table 7.2 Reasons for site selection

Table 8.1 Discussion of effects to be monitored

List of Figures

Figure 1.1 The key stages of SEA in Neighbourhood Plan Preparation (DCLG, 2015)

Acronyms

AA Appropriate Assessment CLP Chichester Local Plan CLPKP Chichester Local Plan Key Policy DCLG Department for Communities and Local Government DEFRA Department for Environment, Food and Rural Affairs DPD Development Plan Document EIA Environmental Impact Assessment EWB East Wittering and Bracklesham

EWBNDP East Wittering and Bracklesham Neighbourhood Plan EWBNDPG East Wittering and Bracklesham Neighbourhood Plan Group EWBNPSAR East Wittering and Bracklesham Neighbourhood Plan Site Assessment Report GI Green Infrastructure LNR Local Nature Reserves LP Local Plan NDP Neighbourhood Development Plan NPPF National Planning Policy Framework ODPM Office of the Deputy Prime Minister PAS Planning Advisory Service PPG Planning Practice Guidance PPP Policies, Plans and Programmes SA Sustainability Appraisal SEA Strategic Environmental Assessment SHLAA Strategic Housing Land Availability Assessment SSSI Site of Special Scientific Interest SuDS Sustainable Drainage Systems

What is Strategic Environmental Assessment?

Lepus Consulting is conducting a Strategic Environmental Assessment (SEA) for the East Wittering and Bracklesham Neighbourhood Plan (NDP; Neighbourhood Plan), on behalf of East Wittering and Bracklesham Neighbourhood Plan Steering Group and Chichester District Council. SEA is the process of informing and influencing the preparation of the NDP to help optimise the environmental performance of the plan.

This document is known as an Environmental Report (SEA Report). It includes the requirements of an Environmental Report in accordance with the SEA Directive.

Purpose and content of the Environmental Report

The purpose of this Environmental Report is to:

• Identify, describe and evaluate the likely significant effect of the plan on environmental factors;

• Suggest measures by which any adverse effects could be mitigated;

• Make recommendations to improve the environmental performance of the plan; and

• Provide an effective opportunity for statutory consultees, interested parties and the public to offer views on any aspect of the SEA process that has been carried out to date.

The Environmental Report contains:

• An outline of the contents and main objectives of the NDP and its relationship with other relevant plans, programmes and strategies;

• The SEA Framework of objectives and indicators against which the plan has been assessed;

• A summary of the reasonable alternatives stage of the NDP;

• The likely significant effects of the NDP in environmental terms;

• The measures envisaged to prevent, reduce and as fully as possible offset any significant adverse effects which may arise as a result of the plan;

• A description of the measures envisaged concerning monitoring; and

• The next steps for the SEA.

This report is one in a series of SEA Reports that have been prepared to facilitate an iterative and informative approach to SEA for the NDP. The stages of plan preparation and the associated SEA work are detailed below.

The screening stage

Chichester District Council undertook a screening assessment of the East Wittering and Bracklesham Neighbourhood Plan in December 20141, to determine whether the NDP should be screened into the SEA process. This assessment determined that the NDP had potential to lead to likely significant effects on the environment, thus it was screened in, in accordance with the SEA Directive.

The scoping stage

The first stage of the SEA was to prepare a Scoping Report2 to outline the background to environmental issues in East Wittering and Bracklesham and use this information to develop a framework against which to assess environmental impacts of the plan.

The Scoping Report identified relevant plans, policies, programmes and baseline information relating to environmental issues in the plan area. This identified the key environmental issues in East Wittering and Bracklesham and used this to set out a series of objectives for environmental protection and a SEA framework, against which the plan was to be assessed.

Assessment of reasonable alternatives

In the UK, reasonable alternatives are commonly referred to as ‘options’. The assessment of reasonable alternatives refers to the plan-making stage of exploring policy options. The NDP Steering Group started the plan-making process with an identification of potential development policies and sites, via the Strategic Housing Land Availability Assessment (SHLAA), a call for sites and through the Chichester District Council Local Plan Key Policies 2014-2029. The Steering Group came to the decision that the only policy for which reasonable alternatives could be considered was Policy 2, Housing Site Allocations.

All reasonable alternatives for Policy 2, as identified by the NDP Steering Group, were assessed by Lepus Consulting in September 2015. Assessment findings were sent to the NDP Steering Group in order to inform the selection of sites. The main findings and assessment results of these options stages are discussed in Chapter 3. Assessment results for reasonable alternatives are presented in Appendix D. The justification for selection and rejection of reasonable alternatives, as prepared by the East Wittering and Bracklesham Neighbourhood Development Plan Group (EWBNDPG), is presented in Chapter 7.

Pre-submission NDP

Following consideration of the reasonable alternatives, the NDP Steering Group prepared the Pre-Submission Plan. Lepus has assessed the Pre-Submission Plan and the findings are presented in this Environmental Report.

The established likely positive significant effects on each SEA Objective are presented in Table N1. Table N2 provides summary details of some potentially significant negative

1 Chichester District Council (2014) Strategic Environmental Assessment of the East Wittering and Bracklesham Neighbourhood Plan: Screening Document 2 Lepus Consulting (2015) Strategic Environmental Assessment of the East Wittering and Bracklesham Neighbourhood Plan: Final Scoping Report

© Lepus Consulting for Chichester District Council 2 SEA of the East Wittering and Bracklesham NDP March 2016 LC-176_EWB_NDP_SEA_15_070316FG.docx effects relating to each SEA Objective. Some effects have been associated with uncertain environmental performance, meaning they could be either positive, negative or possibly both depending on the range of receptors that may be affected. In the case of any potential negative or uncertain effects, recommendations are made in terms of mitigation and monitoring.

Table N1: Potential positive environmental effects of the NDP

Potential positive environmental effects of the NDP

Historic and cultural features

Most of the plan allocations are expected to be sympathetic to their surroundings. None of the allocations require direct demolition or degradation of a listed building or other recognised historic site.

Landscape and townscape

Many policies include the protection or enhancement of landscape and townscape, through protecting distinctive features and using landscaping to protect the visual amenity of existing development.

Biodiversity and geodiversity

The NDP contains policies that are likely to contribute to supporting local biodiversity and connectivity of green spaces across the plan area through Green Links.

Flooding and climate change

The plan includes policies that are expected to help East Wittering mitigate and adapt to the impacts of future climate change. Site allocations are located primarily within Flood Zone 1, which is land at low risk of flooding. The incorporation of green space and planting in and around development may also be beneficial in the light of future climate change.

Natural resources and countryside

By encouraging development within and adjacent to current built up area boundaries, the plan restricts encroachment of development into the countryside. The plan prioritises development on brownfield land and aims to improve previously developed land.

Waste

Re-use of previously developed land and existing buildings may help minimise waste building materials.

Transport and rural barriers

Sustainable transport accessibility is generally good in and around East Wittering, particularly in terms of bus services.

Housing

The plan is expected to have strong positive impacts on housing as it is expected to meet the type and number of dwellings required in the area over the plan period.

Potential positive environmental effects of the NDP

Health

Accessibility to health and recreation services is generally good across the plan area, including for the allocated sites. Services are either within a reasonable walking distance or accessible by public transport.

Economy

The plan is expected to improve the local economy, both protecting business floorspace and making the plan area more attractive to visitors.

Table N2: Potential negative environmental effects of the NDP

Potential negative environmental effects of the NDP and areas for improvement

Historic and cultural features

Some site allocations are in areas of high archaeological potential or are on the site of known archaeological features. Development may lead to loss of archaeological features.

Biodiversity and geodiversity

Most site allocations are on greenfield land. The ecological quality of this land should be investigated before development and areas or features of particular value should be avoided or mitigated where necessary.

Flooding and climate change

Some development supported by the plan may be located in Flood Zones 2 or 3, which is land at high risk of flooding. The extent of development outside of Flood Zone 1 is unknown, as many policies do not specify development sites for new services and facilities. Development is likely to increase the area of non-permeable surfaces in the locality, which may exacerbate local flood risk by reducing surface water drainage both now and in the future.

Natural resources and countryside

Development may lead to loss of best and most versatile agricultural land.

Waste

Some policies have potential to generate waste from building demolition. Other policies have potential to lead to land use that would increase waste production in the operational phase. The increase in housing in the plan area may put more pressure on the sewerage works.

Potential negative environmental effects of the NDP and areas for improvement

Transport and rural barriers

Whilst East Wittering generally has good bus links and accessibility to services and facilities within the plan area, public transport and access to services outside of the plan area is poor. An increase in houses and poor connectivity to the rest of the Manhood Peninsula may result in an increased level of car use.

Housing

East Wittering Neighbourhood Plan Steering Group should ensure that housing developments (over 0.5ha) are screened for likely significant effects on the environment as made necessary in the EIA Regulations3. This will allow any potential adverse environmental impacts to be identified and mitigated.

Mitigation

In cases where potentially adverse effects have been identified, mitigation suggestions have been given in Chapter 8. Mitigation should be considered as part of a sequential hierarchy to deal with adverse effects: avoid, reduce, and then compensate. Mitigation prescriptions might include changes to policy wording, advocating design guides, offsetting biodiversity effects or provision of new supporting green infrastructure. In the case of this SEA Report, mitigation has been supplied to help address potential negative effects associated with classifications of uncertainty or adverse effects in the assessment process so that, if possible, positive or no residual affects remain.

Recommendations

Whilst the NDP brings a range of positive environmental effects, a number of recommendations have been proposed to help further improve its environmental performance when implemented. These are presented in Chapter 8.

Monitoring

Chapter 9 of the SEA Report explains why there should be a monitoring programme for measuring the NDP’s implementation in relation to the areas where the SEA has identified significant effects, and where opportunities for an improvement in environmental performance may arise. Monitoring for the SEA could be carried out in conjunction with other monitoring processes carried out by Chichester District Council.

Conclusions

Having appraised East Wittering and Bracklesham’s NDP, the process has identified several positive and a smaller number of negative effects. Through applying a suite of mitigation measures, it is possible to ensure that most of the residual significant adverse effects are overcome. If all mitigation measures were applied to the plan, the only residual

3 UK Legislation, (2011), Town and Country Planning (Environmental Impact Assessment) Regulations 2011: Schedule 2

© Lepus Consulting for Chichester District Council 5 SEA of the East Wittering and Bracklesham NDP March 2016 LC-176_EWB_NDP_SEA_15_070316FG.docx negative effect relates to the loss of best and most versatile agricultural land. Mitigation measures have been presented in Chapter 8.

Next Steps

The NDP will be published for consultation, together with other proposed submission documents including this SEA Report. This provides a formal opportunity for statutory consultees, the local community and other interested parties to consider the NDP. Chichester District Council will check whether the plan is suitable to submit to an independent examiner. If changes to the NDP result in the need for further SEA work, this will need to be undertaken prior to being submitted to the examiner. If the examiner deems the plan to meet the basic conditions set out in the Town and Country Planning Act (as amended), it will be subject to local referendum. If over 50% of votes are in favour of the NDP, the NDP will be adopted as part of the development plan.

1 Introduction

1.1 Introduction 1.1.1 Lepus Consulting is conducting the Strategic Environmental Assessment (SEA) of the Neighbourhood Development Plan (NDP; Neighbourhood Plan) for East Wittering and Bracklesham (EWB), on behalf of the EWB Neighbourhood Plan Steering Group (‘the Steering Group’) and Chichester District Council. SEA is the process of informing and influencing the progression of development plan documents (DPDs) to maximise the environmental credentials of the plan. This report should be considered through the on-going evolution of the NDP.

1.1.2 This document constitutes the Strategic Environmental Assessment for the NDP and represents an Environmental Report (SEA Report) under the requirements of the SEA Directive. This represents Stage C of SEA, according to the ODPM’s (2005) A Practical Guide to the SEA Directive4. This report also documents Stage B of SEA, developing and refining alternatives and assessing effects.

1.1.3 SEA is the process of informing local development plans to maximise the environmental value of the plan. SEA is a statutory requirement for local development plan documents. A SEA is also one of the ‘tests of soundness’ that planning inspectors use to evaluate the soundness of development plan documents, according to the Environmental Assessment of Plans and Programmes Regulations, 2004. The key objective of SEA is to promote a high level of environmental protection. The SEA is an objective assessment that helps to inform the identification of Preferred Options and the best way of implementing these with regards to environmental factors, but it does not necessarily dictate what these will be.

1.1.4 Each of the policies in the NDP has been subject to a full SEA, which is recorded in this document. A number of reasonable alternatives were identified for Policy 2. No reasonable alternatives were identified against any other policies in the NDP. Policies were assessed against a number of detailed criteria as set out in the SEA Framework (Appendix A).

1.1.5 Sustainability Appraisal (SA) is a UK-specific procedure used to appraise the sustainability impacts and effects of development plans in the UK. SA is not required for NDPs.

1.2 History of the NDP

1.2.1 The creation of neighbourhood plans started with the Government’s Localism Act which came into effect in April 2012. The Act sets out a series of measures to shift power away from central government and towards local people. One of the Localism Act’s key components is the Neighbourhood Plan; a new tier in planning policy which enables local people to shape the development of the community in which they live.

4 ODPM (2005) A Practical Guide to the Strategic Environmental Assessment Directive

1.2.2 The process started in the July 2013 when East Wittering and Bracklesham Parish Council wrote to Chichester District Council to request the plan area as designation of a Neighbourhood Area. Following designation, a Neighbourhood Plan Steering Group was formed which included representatives from the parish, including skilled volunteers.

1.2.3 The steering group had their first public meeting in August 2013 to collect public views on what residents would like to change about the area and used these to create a set of planning objectives which they believed reflected most of the major planning concerns in the community, this formed the consultation draft of the NDP.

1.2.4 The NDP will be published for consultation as a Pre-Submission Plan. This will provide an opportunity for the public and local organisations to comment on the plan.

1.2.5 After consultation, any responses will be taken into account and used to prepare a ‘Submission Version’ of the NDP. This version of the plan will be subject to inspection by an independent examiner. If the examiner approves the NDP it will be subject to a local referendum. If 50% or more of people voting in the referendum support the plan, the NDP will be adopted. Once adopted, planning decisions in the area will be made in accordance with the NDP and the Local Plan.

1.3 The SEA process

1.3.1 The European Union Directive 2001/42/EC or ‘SEA Directive’ applies to a wide range of public plans and programmes on land use, energy, waste, agriculture, transport etc. (see Article 3(2) of the Directive for other plan or programme types). The SEA procedure can be summarised as follows: an environmental report is prepared in which the likely significant effects on the environment and the reasonable alternatives of the proposed plan or programme are identified. The public and the relevant environmental authorities are informed and consulted on the draft plan or programme and the environmental report prepared. Further details on methodology are explained in Chapter 4.

1.3.2 The Directive has been transposed into English law by the Environmental Assessment of Plans and Programmes Regulations 2004 (the SEA Regulations, SI no. 1633). Detailed guidance of these regulations can be found in the Government publication ‘A Practical Guide to the Strategic Environmental Assessment Directive’ (ODPM, 2005).

1.3.3 Under the requirements of the SEA Directive and Environmental Assessment of Plans and Programmes Regulations (2004), specific types of plans that set the framework for the future development consent of projects, must be subject to an environmental assessment.

1.3.4 Where a Neighbourhood Development Plan could have significant environmental effects, it may fall within the scope of the Environmental Assessment of Plans and Programmes Regulations 2004 and so require a SEA. One of the basic conditions that will be tested by the independent examiner is whether the making of the Neighbourhood Plan is compatible with European obligations.

1.3.5 Whether a Neighbourhood Plan requires a strategic environmental assessment, and (if so) the level of detail needed, will depend on what is proposed in the draft Neighbourhood Plan. A SEA may be required, for example, where:

• The Neighbourhood Area contains sensitive natural or heritage assets that may be affected by the proposals in the plan; or

• The Neighbourhood Plan may have significant environmental effects that have not already been considered and dealt with through a sustainability appraisal of higher order plans.

1.3.6 The key stages of Neighbourhood Plan preparation and their relationship with the strategic environmental assessment process are shown in Figure 1.1, which is taken from National Planning Practice Guidance produced by DCLG.

1.4 Best Practice Guidance

1.4.1 A range of guidance documents has been utilised in preparing the SEA of the EWB Neighbourhood Plan. These are presented in Box 1.1.

Box 1.1: Best Practice Guidance for SEA

Lepus Consulting follows national guidance and best practice standards set out for SEA, including:

European Commission (2004) Implementation of Directive 2001/42 on the assessment of the effects of certain plans and programmes on the environment

Office of the Deputy Prime Minister (September 2005): A Practical Guide to the SEA Directive

Department for Communities and Local Government (2012) National Planning Policy Framework

Department for Communities and Local Government (2015) Planning Practice Guidance [online], available at: http://planningguidance.planningportal.gov.uk/blog/guidance/

Figure 1.1: The key stages of SEA in neighbourhood plan preparation (DCLG 2015)

1.5 Structure of the NDP

1.5.1 The pre-submission NDP is presented in 6 sections, as listed below:

• Section 1: Introduction and Purpose

• Section 2: State of the Plan Area

• Section 3: Planning Policy Context

• Section 4: Vision, Objectives and Land Use Policies

• Section 5: Implementation and Monitoring

• Section 6: Policies Maps

1.5.2 Section 4 contains the policies of the NDP that were subject to assessment through the SEA process. Table 1.1 lists all policies of the NDP.

Table 1.1: List of NDP policies in the Pre-Submission NDP

Policy number Policy

1 A Spatial Plan for the Parish

2 Housing Site Allocations

3 Design

4 East Wittering/Bracklesham Green Infrastructure

5 Open Spaces and Seafront

6 Natural environment

7 Schools

8 Employment/Service hub

9 Local Employment

10 Medical Service Centre

11 East Wittering Village Centre

12 Bracklesham Village Centre

13 Local Tourism

1.6 Meeting the SEA Directive requirements

1.6.1 Table 1.2 includes the requirements of the SEA Directive and shows where they are met within the SEA process.

Table 1.2: Meeting the requirements of the SEA Directive

Requirement for Environmental Report Location

Include an outline of the contents, main SEA Scoping Report: Chapters 1 and objectives of the plan or programme and Chapters 3 to 13 relationship with other relevant plans and Scoping Report: Appendix B programmes. SEA Report: Chapter 1

Include information on the relevant aspects of the current state of the environment and the SEA Scoping Report: Chapters 3 to likely evolution thereof without implementation 13 of the plan or programme.

SEA Scoping Report: Chapters 3 to Describe the environmental characteristics of 13 areas likely to be significantly affected

Specify any existing environmental problems which are relevant to the plan or programme SEA Scoping Report: Chapters 3 to including, in particular, those relating to any 13 (Key Issues boxes) areas of a particular environmental importance, such as areas designated pursuant to Directives SEA Report Chapter 5 79/409/EEC and 92/43/EEC. Consider the environmental protection objectives, established at international, SEA Scoping Report: Chapters 3 to Community or Member State level, which are 13 relevant to the plan or programme and the way Scoping Report: Appendix B those objectives and any environmental considerations have been taken into account SEA Report: Chapter 2 during its preparation. Assess the likely significant effects on the environment, including on issues such as biodiversity, population, human health, fauna, flora, soil, water, air, climatic factors, material SEA Report: Chapter 5 assets, and cultural heritage including architectural and archaeological heritage, landscape and the interrelationship between the above factors.

Give details of the measures envisaged to prevent, reduce and as fully as possible offset any significant adverse effects on the SEA Report: Chapter 8 environment of implementing the plan or programme.

Give an outline of the reasons for selecting the alternatives dealt with, and a description of how the assessment was undertaken including any SEA Report: Chapters 3, 4, 6 and 7 difficulties (such as technical deficiencies or lack of know-how) encountered in compiling the required information.

Include a description of the measures envisaged SEA Report Chapter 9 concerning monitoring.

Include a non-technical summary of the SEA Report Non-Technical Summary information provided.

1.7 How the NDP SEA has evolved

1.7.1 This report is part of a series of reports that have been prepared to facilitate an iterative and informative approach to SEA. Chichester District Council undertook a screening assessment of the East Wittering and Bracklesham Neighbourhood Plan in December 2014, to determine whether the NDP should be screened into the SEA process. This assessment determined that the NDP had potential to lead to likely significant effects on the environment, thus it was screened in, in accordance with the SEA Directive.

Scoping

1.7.2 Once screened into the process, the first stage of the SEA was to prepare a Scoping Report5 to outline the background to environmental issues in East Wittering and Bracklesham and use this information to develop a framework against which to assess environmental impacts of the plan. The Scoping Report represents Stage A of the SEA process (see Figure 1.1).

1.7.3 The Scoping Report identified relevant plans, policies and programmes and baseline information relating to environmental issues in East Wittering and Bracklesham. This also set out a series of objectives for environmental protection and a SEA framework, against which the plan is to be assessed. This is discussed in more detail in Chapter 2.

Reasonable alternatives

1.7.4 The Steering Group put forward a number of the sites which were assessed for significant environment effects. These sites were assessed and the results sent to the Steering Group for consideration. Details of these assessments are given in Chapter 3 and Appendix D.

Pre-submission NDP

1.7.5 This report presents an SEA of the pre-submission version of the NDP. This represents Stage C of the SEA process, as described in Figure 1.1 and also documents Stage B, as described in Chapter 3. The Pre-Submission version of the NDP will be consulted on and any comments will be taken into account going forward. If the comments result in changes to the NDP, the SEA work may need to be re-visited to assess the effects of any changes to the plan.

5 Lepus Consulting (2014) Strategic Environmental Assessment of the East Wittering and Bracklesham Neighbourhood Plan: Final Scoping Report

1.7.6 Once the NDP has been formally adopted, an SEA Post-Adoption Statement will be prepared, in order to demonstrate how environmental considerations highlighted in the SEA process were taken into consideration during the preparation of the plan. The Post-Adoption Statement will fulfil Stage E of the SEA process (see Figure 1.1).

1.8 Relationship with the Local Plan

1.8.1 The Chichester Local Plan: Key Policies 2014-2029 (CLPKP) was adopted on 15th July 2015. Now it has been adopted, this forms the key planning document for Chichester District as a whole. The Chichester Local Plan (CLP) is a high-level document, which will form the basis of other development plans in the area.

1.8.2 When adopted as a development plan document (DPD), the EWB NDP will sit alongside the Chichester Local Plan as part of the statutory Development Plan. The Development Plan will form the blueprint for future planning decisions in Chichester.

1.8.3 The NDP must be complimentary to the Local Plan and provide more detailed policies, rather than alternative policies that would negate the Local Plan. The Local Plan was subject to an integrated Strategic Environmental Assessment (SEA) and Sustainability Appraisal (SA), which assessed the plan for significant effects on sustainability and fulfilled the requirements of the SEA Directive. SA assesses the likely implications of a plan on social and economic factors, as well as environmental effects. Mitigation measures were suggested where negative or uncertain impacts were identified.

2 Scoping

2.1 Introduction

2.1.1 The first phase of preparation for the SEA was the scoping stage. This represented Stage A of SEA, according to the DCLG (2015) Guidance on SEA for Neighbourhood Plans (Figure 1.1). Scoping is the process of deciding the scope and level of detail of a SEA, including the environmental effects and alternatives to be considered, the assessment methods to be used, and the structure and contents of the SEA Report.

2.1.2 The purpose of the Scoping Report is to set the criteria for assessment (including the SEA Objectives), and establish the baseline data and other information, including a review of relevant policies, programmes and plans. The scoping process involves an overview of key issues, highlighting areas of potential conflict.

2.1.3 The Scoping Report covers the early stages of the SEA Process and includes information about:

• Identifying other relevant policies, plans and programmes, and environmental objectives;

• Collecting baseline information;

• Identifying environmental issues and problems; and

• Developing the SEA Framework.

2.1.4 The Scoping Report that accompanies this report was carried out by Lepus Consulting in 20156. The Scoping Report was sent to Environmental Agency, Natural England and Historic England for five week consultation (3rd July to 7th August 2015). Comments were received from Natural England and Historic England.

2.1.5 Comments from Natural England mostly raised awareness of vulnerabilities associated with the network of Natura 2000 sites along the south coast.

2.1.6 Historic England’s consultation responses discussed past land use presence of statutory designations in the local area. Comments also included adding an indicator to the SEA Framework which looks at the number of buildings with historic interest demolished as a result of planning applications.

2.2 Policy, plan and programme review

2.2.1 A plan or programme may be influenced in various ways by other plans or programmes, or by external environmental protection objectives such as those laid down in policies or legislation. The SEA process takes advantage of potential synergies and addresses any inconsistencies and constraints.

6 Lepus Consulting (2014) Strategic Environmental Assessment of the East Wittering and Bracklesham Neighbourhood Plan: Scoping Report

2.2.2 The Scoping Report presented an analysis of the objectives of the key policies, plans and programmes (including legislation) that are relevant to the NDP and the SEA assessment process. These were presented by their geographic relevance, from international to local level.

2.3 Baseline data and information

2.3.1 A key part of the scoping process is the collection of baseline data. The purpose of this exercise is to help identify key issues and opportunities facing the area which might be addressed by the NDP, and to provide an evidence base for the assessment.

2.3.2 The baseline chapters in the Scoping Report (Chapters 3 to 13) provided a review of existing environmental conditions within the plan area and their likely evolution in absence of the NDP. One of the purposes of consultation on the Scoping Report was to seek views on whether the data selected was appropriate. Helpful comments were received from a range of stakeholders in response to the Scoping Report and in some cases new baseline information was provided.

2.4 Key SEA issues

2.4.1 The key issues for each SEA Objective, identified in the Scoping Report have been summarised below:

SEA Objective 1: Biodiversity and geodiversity

There is one SSSI in the NDP area

The condition of Bracklesham Bay SSSI is favourable

SEA Objective 2: Natural resources

Need to encourage development on brownfield land

Areas of best and most versatile agricultural land exist in the plan area

Infrastructure to accompany growth may result in soil erosion and loss

SEA Objective 3: Waste

Continue to improve recycling rates and working towards zero waste to landfill

SEA Objective 4: Pollution

There are no known air quality issues in the plan area

Increased traffic and congestion may add to air pollution issues

SEA Objective 5: Climate change minimisation

Carbon emissions have come from transport, industry, commercial and domestic sources

Identify and support opportunities for renewable energy provision locally

Increases in flood risk linked to climate change

SEA Objective 6: Climate change adaptation

Risks posed by climate change include increase in incidents of heat- related illnesses and deaths, risk of injury and death due to storms, increased flooding, changes in biodiversity and increased drought and flood related problems (e.g. soil shrinkage, subsidence)

Changes in landscape due to invasive species

Changes in farming practice and soil erosion

SEA Objective 7: Transport

Congestion in the busier areas of the plan area

Barriers to pedestrians and cyclists

Lack of a train station

SEA Objective 8: Landscape and townscape

The former Church of the Assumption of the St Mary the Virgin is a Grade II* Listed Building on the Heritage at Risk Register

East Wittering and Bracklesham is rated as medium tranquillity

SEA Objective 9: Cultural heritage

Increased traffic could affect integrity of the historic environment and its setting

Potential direct damage to cultural and historic features

Potential damage to archaeological remains

SEA Objective 10: Housing

Increased pressure on housing provision from growing population

Ageing population will increase demand for certain types of housing

Shortfall of affordable housing

Need for affordable rented accommodation

SEA Objective 11: Rural barriers

Nearest urban centre is Chichester, which is accessible by bus

There is no train station in the plan area

SEA Objective 12: Health

Health inequalities exist in the NDP area

Ageing population and increased dependency ratio

East Wittering has low levels of crime

SEA Objective 13: Economy

New business start-ups should be encouraged

The majority of residents have clerical professions with lower than average incomes

2.5 The SEA Framework

2.5.1 The purpose of the SEA Framework is to provide a way of ensuring that the NDP considers the environmental needs of East Wittering in terms of its environmental effects. It also enables the environmental effects of the NDP policies to be described, analysed and compared.

2.5.2 The SEA Framework consists of environmental objectives, which, where possible, the achievement of which is measurable using indicators. There is no statutory basis for setting objectives but they are a recognised way of considering the environmental effects of a plan and comparing alternatives. The SEA Objectives provide the basis from which effects of the NDP were assessed.

2.5.3 The SEA Objectives were developed through the PPP review, the baseline data collection and the key issues identified for the plan area. The SEA topics identified in Annex I (f) of the SEA Directive7 were one of the key determinants when considering the SEA Objectives to be used for appraisal purposes. The SEA Objectives seek to reflect each of these influences to ensure the assessment process is robust and thorough. The full SEA framework is presented in Appendix A.

7 Biodiversity flora and fauna; Population; Human health; Soil; Water; Air; Climatic factors; Material assets; Cultural heritage (including architectural and archaeological heritage); and Landscape.

Table 2.1: SEA Objectives

SEA Objective

1. Biodiv. Protect, enhance and manage biodiversity and geodiversity.

2 Resrce. Protect and conserve natural resources.

Reduce waste generation and disposal, and promote the waste hierarchy 3 Waste of reduce, reuse, recycle/compost, energy recovery and disposal.

4 Polln. Reduce air, soil and water pollution.

Climate 5 Minimise the district’s contribution to climate change. contrib. Climate 6 Plan for the anticipated levels of climate change. plan. Improve the efficiency of transport networks by increasing the 7 Transp. proportion of travel by sustainable modes and by promoting policies, which reduce the need to travel. Protect, enhance and manage the character and appearance of the 8 Landsc. landscape and townscape, maintaining and strengthening distinctiveness and its special qualities. Protect, enhance and manage sites, features and areas of archaeological, 9 Cult. Her. historical and cultural heritage importance Provide affordable, environmentally sound and good quality housing for 10 House. all.

11 Rural. Reduce barriers for those living in rural areas

12 Health Safeguard and improve community health, safety and wellbeing.

Develop a dynamic, diverse and knowledge-based economy that excels 13 Econ. in innovation with higher value, lower impact activities.

3 Reasonable Alternatives

3.1 Introduction

3.1.1 The Strategic Environmental Assessment Directive requires that the SEA process considers:

‘Reasonable alternatives taking into account the objectives and the geographical scope of the plan or programme’ and gives ‘an outline of the reasons for selecting the alternatives dealt with’ (Article 5.1 and Annex I (h)).

3.1.2 In the UK, reasonable alternatives are commonly referred to as ‘options’. The assessment of reasonable alternatives refers to the plan making process stage of exploring policy options. This represented Stage B of SEA, according to the PPG (DCLG, 2015).

3.1.3 The role of the SEA is to inform the plan making group in their selection and assessment of options. The findings of the SEA can help with refining and further developing these options in an iterative and on-going way. The SEA findings do not form the sole basis for decision-making; other studies, the feasibility of the option and consultation feedback will also contribute to the decision made by East Wittering and Bracklesham Neighbourhood Plan Steering Group and Chichester District Council.

3.1.4 Options assessment is proportionate; in more high-level strategic planning, such as the Chichester Local Plan, the assessment may have a criteria-based approach and focus on the key differences between possibilities for scale, distribution and quality of development. The options do not have to be mutually exclusive and elements of each may be further developed into a preferred option. Consequently the process is fluid with options changing and developing as further studies are undertaken, additional findings are established and the responses from previous consultation stages are considered.

3.1.5 The results of an SEA may reveal that there is no single, best performing option. Where there is no obvious discernable difference at a strategic scale, the SEA process will record this as an outcome for that particular stage of the assessment process.

3.1.6 In the case of a development plan document not fully complying with the NPPF and SEA Regulations, the planning examiner is likely to recommend the plan for withdrawal or suspension. For example, a legal challenge was lodged against Forest Heath District Council in 2011, regarding their proposed Core Strategy. The High Court ruled that the Core Strategy did not give clear reasoning as to why alternative policies that were rejected were deemed unreasonable. This ruling should guide current best practice and ensure that the reasons for selecting or rejecting alternatives are explained, and that the public should have an effective opportunity to comment on appraisal of alternatives. The SEA report accompanying the plan must refer to, summarise or repeat the reasons that had been given in earlier iterations of the plan and SEA, and these must still be valid.

3.1.7 Similarly, the planning examiner raised concerns regarding the Bath and North East Somerset Core Strategy in 2012. These concerns were centred on the fact that there was weak justification for selecting the preferred policies, particularly as some of the preferred options did not appear to meet the needs identified in the sustainability appraisal (SA)/SEA. These cases demonstrate the need for transparency in the plan-making process, including taking the SEA findings into account and drawing on the SEA to justify the preferred options selected.

3.2 Identifying reasonable alternatives

3.2.1 The Planning Practice Guidance (PPG)8 states that the environmental report accompanying a neighbourhood plan should ‘outline the reasons the alternatives were selected, the reasons the rejected options were not taken forward and the reasons for selecting the preferred approach in light of the alternatives’.

3.2.2 Reasonable alternatives for the East Wittering and Bracklesham NDP considered various deliverable sites included in the Strategic Housing Land Availability Assessment (SHLAA) and a call for sites undertaken by the East Wittering Neighbourhood Plan Group.

3.3 Distribution options

3.3.1 Following a housing option note produced by rCOH9, three distribution options for development were explored; Distribution Option 1) A combination of Settlement Focus and Dispersal Strategy; Distribution Option 2) Focused development to the north of the settlement; and Distribution Option 3) Focused development to the east of the settlement.

3.3.2 Table 3.1 shows the three distribution options, which have been subject to SEA assessments.

Table 3.1: Reasonable alternatives to distribution options (DO refers to Distribution Option)

Number Reasonable alternative

DO1 A combination of Settlement Focus and Dispersal Strategy

DO2 Focused development to the north of the settlement

DO3 Focused development to the east of the settlement

3.3.3 The three distribution options have been assessed and used to inform the selection of sites to be incorporated into the plan. Distribution options assessment results are shown in Table 3.2. The full assessment of distribution options is presented in Appendix C.

8 DCLG (2015) Planning Practice Guidance 9 rCOH (2015) Housing Options Note (3rd November 2015)

Table 3.2: Distribution options assessment results

SA Objective Option 1 2 3 4 5 6 7 8 9 10 11 12 13 DO1 +/- ++ 0 0 +/- -- +/- ++ +/- + 0 +/- +/- DO2 +/- -- 0 0 + -- ++ + 0 + ++ - +/- DO3 +/- -- 0 0 + -- ++ ++ 0 + ++ - 0 *DO refers to Distribution Option

3.3.4 Strong negative effects were identified for all distribution options with regards to SEA Objective 6. This is due to the presence of Flood Zone 3 within the site boundary. Strong negative effects were identified with SEA Objective 2 for distribution options 2 and 3 due to the presence of best and most versatile agricultural land.

3.3.5 Strong positive effects were identified against SEA Objectives 2 and 8 for distribution option 1 as the sites involve development on previously developed land and would preserve best and most versatile agricultural land and preserve or enhance landscape character. Strong positive effects were also identified against SEA Objectives 7 and 11 for distribution options 2 and 3 as they are located near to amenities and public transport links. Strong positive effects were also identified against SEA Objective 8 for distribution option 3 due to the minimal effects on landscape being anticipated.

3.4 Individual sites

3.4.1 The Pre-Submission NDP presents preferred policy options, each of which addresses a single development theme.

3.4.2 Reasonable alternatives were identified against Policy 2. EWBNDPG did not consider that any other policies had reasonable alternatives.

3.4.3 Table 3.3 shows the reasonable alternatives considered for Policy 2, Housing Site Allocations. These alternatives (‘site options’) were subject to SEA, the full results of which are presented in Appendix D; a summary of SEA results for Policy 2 is presented in Table 3.4.

Table 3.3: Reasonable alternatives to Policy 2 of the Pre-Submission NDP policies. Number Reasonable alternative

1 Windmill, Church Road

2 Co-op, Stocks Lane

3 School Playing Field

4 Land north of Briar Avenue

5 Land north of Stocks Lane

6 Land off Wessex Avenue

7 Land opposite Richardsons

8 Land at Church Farm Lane

9 Martlets, Peerly Road

10 Cobham, Stocks Lane

11 Gees Camping

12 Land west of Bracklesham Lane

13 Land west of Bracklesham Lane 1

14 Sunlands

15 Land north of Lively Lady

16 Land south of Grasmere

17 Land north of Grasmere

18 Land south of Clappers Lane

Table 3.4: Site assessment results at the reasonable alternatives stage (see also Appendix D)

SEA Objective Site 1 2 3 4 5 6 7 8 9 10 11 12 13 Windmill, Church +/- ++ 0 0 + + ++ ++ +/- + 0 + 0 Road Co-op, Stocks Lane +/- ++ 0 0 + + ++ ++ 0 + 0 + --

School Playing Field +/- + 0 0 + + ++ + 0 + ++ - 0 Land north of Briar Avenue +/- -- 0 0 - -- -- +/- + + - + 0 Land north of Stocks +/- -- 0 0 +/- -- - + + + - + 0 Lane Land off Wessex +/- -- 0 0 + -- + + 0 + ++ + 0 Avenue Land opposite +/- -- 0 0 + + ++ + 0 + ++ - 0 Richardsons Land at Church Farm Lane +/- -- 0 0 - + -- + +/- + -- + 0 Martlets, Peerly Road +/- ++ 0 0 + -- ++ ++ 0 + 0 + 0

Cobham, Stocks Lane 0 ++ 0 0 + + ++ ++ 0 + 0 - --

Gees Camping +/- +/- 0 0 + + ++ + 0 + ++ - --

Land west of +/- -- 0 0 + -- ++ + 0 + ++ - 0 Bracklesham Lane Land west of Bracklesham Lane 1 +/- -- 0 0 + -- ++ + 0 + ++ + 0 Sunlands +/- +/- 0 0 + + ++ ++ 0 + ++ - 0 Land north of Lively +/- ++ 0 0 + + ++ + 0 + 0 - 0 Lady Land south of +/- -- 0 0 + + ++ - + + ++ - 0 Grasmere Land north of 0 -- 0 0 + + ++ - + + ++ - 0 Grasmere Land south of Clappers Lane +/- -- 0 0 + -- ++ ++ 0 + ++ - 0

3.4.4 Strong negative effects were identified for the preferred option (site 12) with regards to SEA Objectives 2, 6 and 12. This is due to the presence of best and most versatile agricultural land (SEA Objective 2), presence of Flood Zone 3 within the site boundary (SEA Objective 6) and distance from nearest health centre (SEA Objective 12). Uncertain effects were identified with regards to SEA Objectives 1: Biodiversity. The site contains hedgerows and trees, removal of which may impact on both biodiversity.

3.4.5 In terms of alternatives not taken forward, negative effects were identified against SEA Objectives 5, 7, 8, 11 and 12 (see Table 3.4). Negative effects against SEA Objectives 5, 7, 11 and 12 were generally due to the location of the sites, which resulted in difficulty accessing amenities and public transport stops. Negative effects against SEA Objective 8 were due to the potential impact of development on the landscape of the area.

3.4.6 Strong negative effects were identified against SEA Objective 2 due to loss of best and most versatile agricultural land. Strong negative effects were also identified against SEA Objective 6 as areas of the sites are located in either Flood Zone 2 or 3. Strong negative effects were identified against SEA Objective 7 and Objective 11 due to the distance from key amenities and public transport. Sites 2, 10 and 11 have strong negative effects associated with them as development would result in a loss of employment land or tourism.

3.4.7 Strong positive effects were identified against SEA Objectives 2 as the sites involve development on previously developed land and would preserve best and most versatile agricultural land. Strong positive effects were also identified against SEA Objectives 7 and 11 as these sites are located near to amenities and public transport links. Strong positive effects were also identified against SEA Objective 8 due to the minimal effects on landscape being anticipated.

3.4.8 It is stressed that selection and rejection of sites is a decision made by the NDP Steering Group (see Chapter 7) and not by Lepus Consulting. The role of Lepus Consulting is to provide an objective assessment of options, which can then be used by plan makers to make decisions regarding the selection of preferred options.

3.5 Best performing option

3.5.1 With regards to those sites that were assessed during the SEA of distribution options and site options, some sites performed better than others and might be considered to have similar sustainability performance overall, however, it is difficult to confirm a standalone best performing option without further work on those SEA objectives identified to have uncertainty associated with their assessment evaluation. Details of how each reasonable alternative performs in relation to the SEA objectives are presented in section 3.3 and section 3.4.

4 Appraisal Methodology

4.1 Assessment of the East Wittering and Bracklesham NDP

4.1.1 A full list of NDP policies can be found in Table 1.1. Each of the policies has been assessed against the 13 SEA Objectives established through the Scoping Report’s SEA Framework (which is reproduced in full in Appendix A). Lepus Consulting has also put together an assessment protocol (Appendix B), which gives further examples of how to apply the matrix in Table 4.1 to the assessment.

4.2 Approach to the appraisal

4.2.1 The assessment of the NDP was undertaken using a combination of empirical evidence, and to a lesser extent professional judgement. Each policy was assessed against each of the SEA Objectives.

4.2.2 The findings are presented in matrix format and are accompanied by a commentary on identified effects. The matrix is not a conclusive tool. Its main function is to show visually whether or not the proposed options are likely to bring positive, adverse or uncertain effects in relation to the SEA Objectives. A commentary has been prepared to interpret the matrix findings. Table 4.1 shows the key to identifying whether the effects of an option are positive, adverse or uncertain.

Table 4.1: Key to the matrix assessment

Key:

Likely strong positive effect ++

Likely positive effect +

Neutral/no effect 0

Likely adverse effect -

Likely strong adverse effect --

Uncertain effects +/-

4.2.3 Where the assessment findings identify potential negative or uncertain effects, these will be examined further in Chapter 6.

4.2.4 All assessments are prepared using the criteria contained within Annex II of the SEA Directive10. These criteria are presented in Box 4.1.

4.2.5 Where uncertainty is associated with the assessment process, the precautionary principle is used. The European Commission describes the precautionary principle as follows:

10 This SEA is being carried out in accordance with the requirements of the Directive 2001/42/EC, the SEA Directive.

4.2.6 “If a preliminary scientific evaluation shows that there are reasonable grounds for concern that a particular activity might lead to damaging effects on the environment, or on human, animal or plant health, which would be inconsistent with protection normally afforded to these within the European Community, the Precautionary Principle is triggered.”

4.2.7 Decision-makers then have to determine what action(s) to take. They should take account of the potential consequences of no action, the uncertainties inherent in scientific evaluation, and should consult interested parties on the possible ways of managing the risk. Measures should be proportionate to the level of risk, and to the desired level of protection. They should be provisional in nature pending the availability of more reliable scientific data.

4.2.8 Action is then undertaken to obtain further information, enabling a more objective assessment of the risk. The measures taken to manage the risk should be maintained so long as scientific information remains inconclusive and the risk is unacceptable.

4.2.9 The hierarchy of intervention is important: where significant effects are likely to be adverse or uncertain, plan makers must firstly seek to avoid the effect through for example, a change of policy. If this is not possible, mitigation measures should be explored to remove or reduce the significant effect. If neither avoidance, nor subsequently, mitigation is possible, alternatives to the plan should be considered.

Box 4.1: Criteria for the assessment of significant effects (reproduced from Annex II of the SEA Directive)

Characteristics of the effects and of the area likely to be affected, having regard, in particular, to

The probability, duration, frequency and reversibility of the effects;

The cumulative nature of the effects;

The transboundary nature of the effects;

The risks to human health or the environment (e.g. due to accidents);

The magnitude and spatial extent of the effects (geographical area and size of the population likely to be affected);

The value and vulnerability of the area likely to be affected due to:

Special natural characteristics or cultural heritage;

Exceeded environmental quality standards or limit values;

Intensive land-use;

The effects on areas or landscapes that have a recognised national, Community or international protection status.

4.3 In-combination effects assessment

4.3.1 As required by the SEA Regulations, cumulative, synergistic and indirect effects have been identified and evaluated during the assessment. An explanation of these is as follows:

4.3.2 Indirect effects are effects that are not a direct result of the plan, but occur away from the original effect or as a result of a complex pathway;

4.3.3 Cumulative effects arise where several developments each have insignificant effects but together have a significant effect, or where several individual effects of the plan have a combined effect;

4.3.4 Synergistic effects interact to produce a total effect greater than the sum of the individual effects.

4.3.5 To enable an assessment of the complete range of environmental effects resulting from the NDP, the full range of cumulative effects, incorporating secondary, indirect and synergistic effects were evaluated. Whilst a number of these types of effects are recorded by the appraisal findings for the assessment of the policies, a number of these effects can only be established through examining all of the policies and proposals presented by the NDP together. These interactions are examined in Table 5.1 of this report.

4.4 Sources

4.4.1 The assessments presented in Chapter 5 draw on a variety of data sources, including the information contained in the July 2015 Scoping Report11. Appropriate datasets were analysed for each assessment; these are presented in Table 4.2 below. Other data sources have been referenced in the text, or in footnotes.

11 Lepus Consulting (2015) Strategic Environmental Assessment of the East Wittering and Bracklesham Neighbourhood Plan: Final Scoping Report

Table 4.2: Key data sources used in this SEA assessment

Information Data source Agricultural Land Classification (note: this Natural England (2010) Agricultural Land data source does not split the Grade 3 Classification map South East region category into 3a and 3b) Agricultural Land Classification (note: this Natural England (2015) MAGIC, available at: shows Grade 3a and Grade 3b land http://www.magic.gov.uk separately, but it is an incomplete dataset) Location of footpaths Listed Buildings Statutory designations LNRs Habitats present Registered Parks and Gardens Scheduled Monuments SSSIs Green belt Bus routes and timetables Compass Travel (2015) Compass website, available at: http://www.compass- travel.co.uk/download/west-sussex-surrey- bus-services/150.pdf Stagecoach Group Plc (2015) Stagecoach bus website, available at: https://www.stagecoachbus.com/default.asp x Flexibus (2014) Flexibus website, available at: www.lexi-bus.co.uk National Express (2015) National Express website, available at: www.nationalexpress.com West Sussex County Council (2015) West Sussex Direct: Buses, travel and transport, available at: https://www.westsussex.gov.uk/roads-and- travel/travel-and-public-transport/bus-and- coach-travel/bus-timetables/ Flood Zones Environment Agency (2015) What’s in Your Backyard: Flood Map for Planning (Rivers and Sea), available at: http://maps.environment- agency.gov.uk/wiyby/wiybyController?x=357 683&y=355134&scale=1&layerGroups=default &ep=map&textonly=off&lang=_e&topic=flood map#x=357683&y=355795&lg=1,2,&scale=1 Habitats present Google (2015) Google Maps, available at: Current land use https://www.google.co.uk/maps

Locations of services and amenities Location of bus stops and train stations Water quality GOV UK, Catchment Area Management Strategy, available at: https://www.gov.uk/government/collections /water-abstraction-licensing-strategies- cams-process Landscape capacity HDA, (2011), Landscape Capacity Study Extension, available at: http://www.chichester.gov.uk/CHttpHandler. ashx?id=15651 Population data ONS, (2015) Neighbourhood Statistics: East Car ownership Wittering Ward Economic information Qualification information Air Quality Management Areas Defra UK Air Map (2015) available at: http://uk-air.defra.gov.uk/aqma/maps Climate projections for the South East UK Climate Projections (2009) http://ukclimateprojections.defra.gov.uk/

4.5 Assumptions and limitations

4.5.1 There are a number of assumptions and limitations, which should be borne in mind when considering the results and conclusions of this assessment.

4.5.2 SEA is a tool for predicting potential significant effects. The actual effects of the policies may be different from those identified. Prediction of effects is made using an evidence-based approach and incorporates a judgement. The assessment matrices should not be regarded as conclusive as additional information may come to light.

4.5.3 The strategic nature of the assessment identifies issues that could be improved. However due to the broad nature of the policies, the assessment does not go into great depth.

4.5.4 The assessments are based on the best available information, including that provided to us by Chichester District Council and information that is publicly available. Every attempt has been made to predict effects as accurately as possible using the available information.

4.5.5 All distance measurements have been taken from the centre of each site, as the crow flies. The only exception to this is when a service, facility or feature abuts the boundary of a proposed site, in which case this has been stated.

4.5.6 Any major changes to the policies would need to be subject to an SEA before it could be submitted for examination.

4.5.7 Many effects will depend on the size and location of development, building design and construction, proximity to sensitive receptors such as wildlife sites, conservation areas, flood risk areas and watercourses, and the range of uses taking place.

4.5.8 This report has been produced to assess the environmental effects of the NDP and meets the requirements of the SEA Directive. It is not intended to be a substitute for Environmental Impact Assessment (EIA) or Appropriate Assessment (AA). For further information on the differences between these assessments please see:

https://ec.europa.eu/inea/sites/inea/files/download/events/2014/may_E NER_info_day/cef_2352014__hab_dir_art__6_aa__env_extra.pdf

SEA Objective 1: Biodiversity and Geodiversity

4.5.9 Where biological records are available, these should be checked for the presence of European Protected Species to help determine the need for surveys at the sites.

SEA Objective 2: Natural resources

4.5.10 In the first instance, MAGIC12 is used to determine soil quality at the sites allocated for Policy 2. Where MAGIC data is unavailable, Natural England Agricultural Land Classification (ALC) GIS data is used to inform the assessment. Natural England notes that ‘these maps are not sufficiently accurate for use in assessment of individual fields or development sites, and should not be used other than as general guidance’. They are used in this way to inform Strategic Environmental Assessment13, rather than for example a more detailed assessment that might be associated with an Environmental Impact Assessment14. The Natural England ALC maps are used to inform the assessment as more detailed soil maps are not available.

SEA Objective 3: Waste

4.5.11 West Sussex County Council has a Minerals and Waste Development Scheme in place which operates from 2015 to 2018. This scheme sets out the progress for both the Minerals and Waste Local Plans in the county. It is assumed that the same waste management provisions will be made available to new residents as those that are currently in place, such as recycling facilities. The Minerals and Waste Development Scheme is expected to be sufficient in encouraging waste minimisation. As such, all policies have been assessed as neutral against SEA Objective 3.

12 MAGIC, (2015), http://magic.defra.gov.uk 13 Strategic environmental assessment considers only the environmental effects of a plan, whereas sustainability appraisal considers the plan’s wider economic and social effects in addition to its potential environmental impacts. Sustainability appraisal should meet all of the requirements of the Environmental Assessment of Plans and Programmes Regulations 2004, so a separate strategic environmental assessment should not be required. 14 The EIA Directive (85/337/EEC) is in force since 1985 and applies to a wide range of defined public and private projects.

SEA Objective 4: Pollution

4.5.12 No sites are currently classed as contaminated land and no Air Quality Management Areas (AQMAs) are present within the plan area. The West Sussex Transport Plan15 (2013) does not list any area of East Wittering as a concern for congestion, and as such, no anticipated significant effects are expected to arise from development at any of the sites.

4.5.13 It has been noted that there is a capacity issue with the sewer works at East Wittering. Although foul drainage from new development will be directed to Sidlesham Wastewater Treatment Works (WWTW), the issue lies in the pipe diameter. The current capacity of the WWTW can support is inadequate for the number of homes proposed in the plan16. As the plan will be allocating sites to deliver up to 180 homes, there will be an overall negative impact as this is greater than the known capacity of the sewage works. As the number of the houses to be allocated at each site is unknown, it has not been considered in the assessment of individual sites.

SEA Objective 5: Climate change minimisation

4.5.14 There is an assumption that the majority of residents moving into new residential developments will own a car, or other private vehicle. An increase in housing in the plan area is expected to lead to a proportional increase in cars on the road and an increase in greenhouse gas emissions associated with transport. This has potential negative implications for SEA Objective 5, minimise climate change. The assessment considers whether the plan is likely to increase or decrease carbon emissions per head of the population, rather than overall, in order to give a more meaningful assessment of policies. This is assessed using the assumption that car use is likely to be lower if local services and amenities are close enough to be accessible by foot (using the distances stated in Barton et al, 201017) or if there are good links to sustainable modes of transport, particularly buses and cycleways.

SEA Objective 6: Climate change adaptation

4.5.15 All data regarding Flood Zones has been sourced from the Environment Agency’s ‘What’s In My Backyard18’ (2015) flood map for planning (rivers and sea).

SEA Objective 7: Transport

4.5.16 The Chichester Local Transport Plan (CLTP) does not list any area of East Wittering as a concern for congestion, and as such, no anticipated affect is expected to arise from development at any of the sites. All assessment in relation to SEA Objective 7 draws on current accessibility to sustainable modes of travel within the plan area.

15 Jacobs, (2013), Transport Study of Strategic Development Options and Sustainable Transport Measures 16 Southern Water, (2014), https://publicaccess.chichester.gov.uk/online- applications/files/F7F340D0450AF44514B61C89E9DE99E2/pdf/14_01806_OUT- SOUTHERN_WATER_1.7.14-1883376.pdf 17 Barton, H., Grant, M. and Guide, R. (2010) Shaping Neighbourhoods for local health and global sustainability 18 Environment Agency, (2015), What’s In My Backyard, http://maps.environment- agency.gov.uk/wiyby/wiybyController?x=357683&y=355134&scale=1&layerGroups=default&ep=map&tex tonly=off&lang=_e&topic=floodmap

4.5.17 In the wider area, the A27/A286 is known to be an area of congestion and this is identified in the CLTP. Congestion and traffic problems outside the plan area have not influenced the assessments as the results for the assessment of sites would be the same, making it difficult to distinguish between sites. The Chichester Local Plan Transport Study (2013) takes these issues into account and provides mitigation and financial forecasts to deal with the issue of development in East Wittering and other areas of the Manhood Peninsula. In order to assess the effects of the plan transport on a site by site basis, the provision and accessibility of sustainable modes of travel has been used to inform the assessment against this objective.

SEA Objective 8: Landscape

4.5.18 The Chichester Landscape Capacity Study Extension (2011)19 has been used to assess landscape impacts, where possible. Sites in the urban area were not scored in the Chichester Landscape Capacity Study. These sites have been assessed as having positive effects against SEA Objective 8. Policy 40 of the Chichester Local Plan Key Policies (CLPKP) 2014-2029 states that the ‘historic and built environment, open space and landscape character will be protected and enhanced.’ This Local Plan policy will ensure development within East Wittering will maintain the local distinctiveness of the area.

SEA Objective 9: Cultural heritage

4.5.19 As yet to be discovered archaeological sites have the potential to exist across the plan area. This assessment can only reference historic features that have been recorded and existing assessments of archaeological potential.

SEA Objective 12: Health

4.5.20 There is little information available regarding the capacity of local services, including doctors’ surgeries. The NHS choices website20 shows that all health services within five miles of East Wittering are currently accepting new patients, thus capacity of healthcare facilities is not considered to be a barrier to health in the area.

SEA Objective 13: Economy

4.5.21 Policies that are not anticipated to result in a loss of local employment (i.e. pubs, industrial buildings etc.) have been assessed as neutral in this report. It should be noted that an increase in residential buildings in an area may contribute to the economy by boosting the economy of the local construction industry in the short term. Any site which results in a loss of employment or tourism opportunities has been assessed as negative as it contradicts Policy 26 in CLPKP, which seeks to retain employment land across the district.

19 Hankinson Duckett Associates (2011), Chichester Landscape Capacity Study Extension 20 http://www.nhs.uk/Service-Search/GP/

5 Appraisal Findings

5.1 Introduction

5.1.1 The policies have been individually assessed against each of the 13 SEA Objectives. This chapter contains the results of this appraisal. The results for each policy can be found in a single line matrix, which displays whether the policy has been assessed positively or negatively against each SEA Objective. The matrices are followed by an explanation of the results. Assessment findings are presented below. A description of the key used in assessments can be seen in Table 4.1.

5.2 Policy 1: A Spatial Plan for the Parish

1 2 3 4 5 6 7 8 9 10 11 12 13

Nat Clim Clim Cult Rural Biodiv. Waste Poll Transp Landsc House Health Econ Res mini adapt Her Barrier 0 +/- 0 0 + +/- + + 0 0 + 0 0

5.2.1 There is potential for the policy to lead to development on previously developed land, as this is more likely to occur in the existing urban area. This would reduce the likelihood of developing on best and most versatile agricultural land, which would lead to a loss of this resource. Where previously developed land is not available, this policy could lead to development on best and most versatile agricultural land, but this remains uncertain (SEA Objective 2).

5.2.2 This policy is likely to ensure development is close to existing services and facilities, as well as to bus services serving these, thus reducing the need to travel and reducing the carbon footprint of East Wittering and Bracklesham (SEA Objectives 5 and 7).

5.2.3 The built up areas within the plan contain areas of Flood Zones 2 and 3. By restricting development to the settlement boundary, development may occur within a Flood Zone. Policy 42 of the Chichester Local Plan only permits development in areas of flood risk identified by the Environment Agency if a list of criteria are met. All development will at a minimum, ensure no net increase in surface water run-off from new development, if criteria set out in Policy 42 are met. The effects of this are uncertain as they are location and design dependent (SEA Objective 6).

5.2.4 By ensuring all development is within a distinct settlement boundary and does not encroach into the more rural parts of the plan area in the north, access to amenities and key services will be easier and may reduce the need to travel. Bus services within the plan area are frequent and allow easier access to sustainable travel for those needing to travel outside of the plan area (SEA Objectives 7 and 11).

5.2.5 Development within the settlement boundary is likely to help protect the local distinctiveness of the plan area and reduce visual impacts, by building in a current urban area (SEA Objective 8).

5.2.6 This policy will not lead to housing provision in itself, rather it will influence the location of any housing proposed by other policies, thus having neutral effects against SEA Objective 10.

5.3 Policy 2: Housing Site Allocations

5.3.1 The following assessment for Policy 2 has identified neutral impacts on waste (SEA Objective 3) and pollution (SEA Objective 4).

5.3.2 Overall waste production is likely to increase by the virtue of additional residents and households producing waste on top of the current level of waste production. Waste production per capita is not expected to increase with development at the sites allocated in the plan, nor is recycling expected to decrease, as new residents will have access to the same waste facilities as current residents. West Sussex County Council have a Minerals and Waste Development Scheme which is in place from 2015 to 2018. The scheme sets out the progress for both Minerals and Waste Plans. For this reason, SEA Objective 4 has been assessed as neutral for Policy 2 as any implications of new development on waste will be dealt with through the Minerals and Waste Development Scheme.

5.3.3 No part of the site is currently classed as contaminated land and no Air Quality Management Areas (AQMAs) are present within the parish. The West Sussex Transport Plan (2013) does not list any area of East Wittering as a concern for congestion, and as such, no anticipated effect is expected to arise from development at the proposed site.

5.3.4 Development of the site is expected to have similar impacts on the economy. Economic impacts are expected to be minimal. There may be short-term benefits to the construction industry if local firms are instructed to undertake building works. Additional residents may also support the local economy through both employment and spending. If residents of East Wittering and Bracklesham work in the district, it is more likely that they will spend more of their earnings in the district, rather than taking this money elsewhere. The allocation has been assessed as neutral where no loss of employment or tourism is anticipated. Policy 24 of the CLPKP protects land used for employment and tourism opportunities. Sites which provide employment or tourism opportunities in the plan area have been assessed as negative.

5.3.5 There is little information regarding capacity of primary health care facilities. The Chichester Infrastructure Delivery Plan21 identifies that the Witterings Practice has recently had a large new extension and can accommodate incoming patients from new developments. For the purpose of the assessment in Policy 2, the existing surgeries that have capacity for new patients is assumed to be sufficient for the additional dwellings proposed by the plan.

21 Chichester District Council (2014) Draft Infrastructure Delivery Plan

Land west of Bracklesham Lane

1 2 3 4 5 6 7 8 9 10 11 12 13 Nat Clim Clim Cult Rural Biodiv. Waste Poll Transp Landsc House Health Econ Res mini adapt Her Barrier +/- -- 0 0 + -- ++ + 0 + ++ - 0

5.3.6 This site is a series of open arable fields with hedgerows to the north of East Wittering. Features of arable landscapes such as hedgerows and streams can support a variety of species. Ecological surveys should be undertaken in order to determine the ecological value of the site (SEA Objective 1).

5.3.7 The site is categorised as Grade 2 agricultural land, therefore development will result in a loss of best and most versatile agricultural land (SEA Objective 2).

5.3.8 The site is within 400 metres of a high frequency bus stop, providing residents with links to key amenities in the local area. This could help to reduce the carbon footprint of the area and promote sustainable modes of travel (SEA Objective 5, 7 and 11).

5.3.9 A stream borders the western edge of the site and areas of Flood Zone 3 are present along the stream, which is at high risk of flooding. Development in Flood Zone 3 is at highest flood risk. The risk may be exacerbated as a result of climate change (SEA Objective 6).

5.3.10 The Chichester Landscape Capacity Study (2011) assessed this site as having medium to high capacity for development (SEA Objective 8).

5.3.11 Housing development at the site will help meet the local housing demand (SEA Objective 10).

5.3.12 The site is further than one kilometre of a medical centre, making access to health facilities more difficult for those who need it (SEA Objective 12).

5.4 Policy 3: Design

1 2 3 4 5 6 7 8 9 10 11 12 13 Nat Clim Clim Cult Rural Biodiv. Waste Poll Transp Landsc House Health Econ Res mini adapt Her Barrier 0 0 0 0 0 + 0 + + 0 0 0 0

5.4.1 This policy states that development proposals must be able to demonstrate that they will not increase flood risk on or adjoining the proposals, thus having positive implications for adapting to the impacts of climate change (SEA Objective 6).

5.4.2 This policy aims to ensure that all development reflects and enhances the character of the plan area. By ensuring development is designed to be in keeping with the local area, this policy performs positively against SEA Objective 8.

5.4.3 Ensuring development is inkeeping with the local area will help to maintain the setting of the area and retain cultural heritage and local distinctiveness (SEA Objective 9).

5.5 Policy 4: East Wittering/Bracklesham Green Infrastructure

1 2 3 4 5 6 7 8 9 10 11 12 13 Nat Clim Clim Cult Rural Biodiv. Waste Poll Transp Landsc House Health Econ Res mini adapt Her Barrier + 0 0 0 + + + + 0 0 + + 0

5.5.1 This policy proposes the creation of Green Links on the Manhood Peninsula, which may benefit biodiversity through the creation of habitat corridors. Habitat connectivity is important and can help to support a metapopulation of species. A metapopulation refers to the population of a species across a wider area, which has interactions within it (SEA Objective 1).

5.5.2 The creation of Green Links, including a new footpath and cycle route, may result in a decrease in the carbon footprint per person as less people may rely on car use (SEA Objective 5).

5.5.3 The delivery of green infrastructure is important for facilitating a reduction in the scale of predicted impacts associated with climate change. Providing green infrastructure has positive implications in reducing and adapting to the impacts of climate change, including local cooling effects and the absorption of carbon dioxide22 (SEA Objective 6).

5.5.4 The policy proposes to create a new footpath and cycle path which will create linkages for those choosing to walk or cycle around the plan area, thus reducing the need for car use and promoting the use of sustainable travel around the plan area (SEA Objectives 7 and 11).

5.5.5 The provision of green infrastructure in the plan area may contribute towards improving the visual amenity of the area (SEA Objective 8).

5.5.6 By creating new routes for sustainable travel, residents may engage in more recreational activity, which can in turn improve health and quality of life (SEA Objective 12).

22 Forest Research (2010) Benefits of Green Infrastructure. Available at: http://www.forestry.gov.uk/pdf/urgp_benefits_of_green_infrastructure.pdf/$file/urgp_benefits_of_green_infrastruct ure.pdf

5.6 Policy 5: Open Spaces and Seafront

1 2 3 4 5 6 7 8 9 10 11 12 13 Nat Clim Clim Cult Rural Biodiv. Waste Poll Transp Landsc House Health Econ Res mini adapt Her Barrier 0 0 0 0 0 0 0 + 0 0 0 + 0

5.6.1 This policy will protect seven areas of Local Green Space and the Seafront area. Development on any of the Local Green Spaces or on the Seafront will be resisted. By protecting Local Green Space across the plan area, the visual amenity and local distinctiveness are likely to be retained. Protecting the Seafront from development will maintain the character of the area (SEA Objective 8).

5.6.2 If areas of amenity grassland are made easily accessible to residents, they are likely to use it for recreational activities, thus promoting a healthy lifestyle and good quality of life (SEA Objective 12).

5.7 Policy 6: Natural Environment

1 2 3 4 5 6 7 8 9 10 11 12 13 Nat Clim Clim Cult Rural Biodiv. Waste Poll Transp Landsc House Health Econ Res mini adapt Her Barrier + 0 0 0 0 0 0 + 0 0 0 0 0

5.7.1 This policy seeks to protect designated environmental and landscape sites inside or in close proximity to the plan area. By protecting sites important for biodiversity, it allows for species which reside there to be protected. By resisting development in sites designated for landscape value, it will protect the visual amenity and character of the area (SEA Objectives 1 and 8).

5.8 Policy 7: Schools

1 2 3 4 5 6 7 8 9 10 11 12 13 Nat Clim Clim Cult Rural Biodiv. Waste Poll Transp Landsc House Health Econ Res mini adapt Her Barrier 0 0 0 0 0 0 + 0 0 0 + 0 +

5.8.1 This policy encourages the provision of a new primary school to serve the village and a secondary school to serve the Manhood Peninsula. There is currently one primary school (East Wittering Community Primary School) and no secondary school in the plan area. The Chichester District Council Infrastructure Delivery Plan explains that the intake of schools on the Manhood Peninsula was projected to be high in September 2013. Demand outweighed supply, meaning that temporary measures were necessary but no permanent solutions were required as numbers decreased in the following three years. The nearest secondary schools are currently located in Chichester.

5.8.2 The policy states that the schemes to deliver a new primary and secondary school in the neighbourhood plan will be supported, providing that they are conveniently located to encourage walking and cycling. If delivered, this may reduce personal car use and traffic levels in the plan area. An easily accessible secondary school will also reduce the barriers of living in a rural area, thus scoring positively against SEA Objectives 7 and 11.

5.8.3 The provision of any new education facilities in the local area will increase job opportunities for those living in the plan area and may contribute to broadening the skills base of the future workforce (SEA Objective 13).

5.9 Policy 8: Employment/Service Hub

1 2 3 4 5 6 7 8 9 10 11 12 13 Nat Clim Clim Cult Rural Biodiv. Waste Poll Transp Landsc House Health Econ Res mini adapt Her Barrier 0 0 0 0 + 0 + 0 0 0 + 0 0

5.9.1 The extension of a village library and construction of new offices may reduce the need for residents to travel out of the plan area to access similar resources, thus allowing residents to access this service on foot and minimise the need for car use (SEA Objectives 5, 7 and 11).

5.10 Policy 9: Local Employment

1 2 3 4 5 6 7 8 9 10 11 12 13 Nat Clim Clim Cult Rural Biodiv. Waste Poll Transp Landsc House Health Econ Res mini adapt Her Barrier 0 0 0 0 + + + + 0 0 0 0 +

5.10.1 This policy protects current employment land and supports applications for the creation of new areas of employment land, providing they do not result in detrimental effects on flood risk, local amenity, traffic and landscape or that any impacts can be mitigated (SEA Objectives 5, 6, 7 and 8). The protection of current employment opportunities and promotion of new opportunities will help lead to an increase in economy in the local area (SEA Objective 13).

5.11 Policy 10: Medical Service Centre

1 2 3 4 5 6 7 8 9 10 11 12 13 Nat Clim Clim Cult Rural Biodiv. Waste Poll Transp Landsc House Health Econ Res mini adapt Her Barrier 0 0 0 0 0 0 0 0 0 0 + + +

5.11.1 The construction of a new medical centre in Bracklesham is likely to have a positive effect against SEA Objective 11. Residents from Bracklesham who are currently using The Witterings Medical Centre will have a shorter distance to travel and may be able to access the medical centre on foot, thus promoting sustainable transport and allowing easy access to services for those without a car.

5.11.2 Providing Bracklesham with a medical centre is expected to have a positive effect on SEA Objective 12. The provision of a new medical facility would mean that residents have access to suitable health facilities should they need them. Additionally, the extra capacity for patients may serve future developments in the area.

5.11.3 The construction of a new medical facility in Bracklesham will deliver more local employment opportunities to the area, thus helping the economy and providing employment opportunities for local people (SEA Objective 13).

5.12 Policy 11: East Wittering Village Centre

1 2 3 4 5 6 7 8 9 10 11 12 13 Nat Clim Clim Cult Rural Biodiv. Waste Poll Transp Landsc House Health Econ Res mini adapt Her Barrier 0 0 0 0 0 0 +/- + 0 0 + 0 +

5.12.1 Part of the proposal to designate an East Wittering Village Centre includes provision of more car parking. Promoting this may result in more residents travelling by car and not using sustainable modes of travel (SEA Objective 7).

5.12.2 The provision of, or a financial contribution towards, improving the village and seafront is likely to improve the visual amenity of the plan area and retain the character and local distinctiveness. The policy also states that the proposals will not result in the loss of any retail or commercial frontage for development to non-retail use, helping to retain the character of the area (SEA Objective 8).

5.12.3 By protecting the retail units currently in East Wittering, the retention of key services in the plan area will result in easy access to amenites for those without a personal car, thus reducing the barriers to living in a rural area (SEA Objective 11).

5.12.4 Promoting the retention of retail units and improving the appearance of the village is likely to bring more tourism to the area as well as reducing the need to travel to larger centres to access amenities, thus having an positive impact on the local economy of the area (SEA Objective 13).

5.13 Policy 12: Bracklesham Village Centre

1 2 3 4 5 6 7 8 9 10 11 12 13 Nat Clim Clim Cult Rural Biodiv. Waste Poll Transp Landsc House Health Econ Res mini adapt Her Barrier 0 0 0 0 0 0 +/- + 0 0 + 0 +

5.13.1 The policy states that the development of a new retail complex will be supported, providing it makes provision for additional car parking. The impacts of this are uncertain as more people may drive to the centre rather than use sustainable methods of transport, particularly if this attracts visitors from outside the plan are (SEA Objective 7).

5.13.2 By retaining current retail units in the centre of Bracklesham and resisting the conversion of these into non-retail units, the local distinctiveness and character of the village centre will be retained (SEA Objective 8).

5.13.3 Protecting the retail units currently in Bracklesham and resisting the conversion of them into non-retail developments will help to retain key amenities for those without personal transport methods, thus reducing the barriers to living in a rural area (SEA Objective 11).

5.13.4 Promoting the retention of retail units and improving the appearance of the village may bring more tourism to the area as well as reducing the need to travel to larger areas to access amenities, thus having a positive impact on the local economy of the area. In particular, the development of a new retail complex will create more local employment opportunities (SEA Objective 13).

5.14 Policy 13: Local Tourism

1 2 3 4 5 6 7 8 9 10 11 12 13 Nat Clim Clim Cult Rural Biodiv. Waste Poll Transp Landsc House Health Econ Res mini adapt Her Barrier 0 0 0 0 0 0 +/- 0 0 0 0 0 +

5.14.1 An increase in tourism in the area is likely to result in an increased number of cars on the roads in East Wittering and Bracklesham. This may result in congestion in the more built up areas and an increase in greenhouse gases, resulting from a higher level of vehicle emissions. This will depend on the location, accessibility and type of tourism introduced in the area (SEA Objective 7).

5.14.2 An increase in tourism in the area is expected to bring more money to the local economy, through increased spending in shops, restaurants and tourist accommodation. It is possible that it may also lead to the creation of local job opportunities, which could benefit local residents (SEA Objective 13).

5.15 Assessment of in-combination effects

5.15.1 As required by the SEA Regulations, cumulative, synergistic and indirect effects have been identified and evaluated during the assessment of the policies included in the East Wittering and Bracklesham Neighbourhood Plan (see Table 5.1). An explanation of indirect, cumulative and synergistic is as follows:

• Indirect effects are effects that are not a direct result of the plan, but occur away from the original effect or as a result of a complex pathway;

• Cumulative effects arise where several developments each have insignificant effects but together have a significant effect, or where several individual effects of the plan have a combined effect;

• Synergistic effects interact to produce a total effect greater than the sum of the individual effects.

5.15.2 In preparing an assessment of in-combination effects, consideration has been given to the adopted Chichester Local Plan Key Policies 2014-2029 document. The East Wittering and Bracklesham Neighbourhood Development Plan will become part of the Development Plan and therefore should be considered in-combination with the Chichester Local Plan.

5.15.3 The neighbouring parish of Birdham has prepared a neighbourhood plan and the Examiner’s report has now been published. The Birdham Neighbourhood Plan is not expected to have any in-combination effects with the East Wittering and Bracklesham Neighbourhood Plan as Birdham has not allocated any sites for housing. The localised nature of other policies included in both the Birdham and East Wittering and Bracklesham Plans are not anticipated to result in any in-combination effects.

Table 5.1: Assessment of in-combination effects

SEA Objectives Proposals which bring in-combination effects Significance 1. Biodiversity and Policy 49 of the Chichester Local Plan Key Policies geodiversity: 2014-2029 document is expected to work Protect, enhance and alongside NDP Policy 6 to provide a strong basis + manage biodiversity and for protecting and enhancing biodiversity and geodiversity geodiversity. Policies 46 and 48 of CLPKP both relate to protecting and conserving natural resources. 2. Natural resources: These policies are likely to have positive Protect and conserve natural cumulative effects with NDP Policy 6 to encourage + resources development on previously developed land and thus protecting the best and most versatile agricultural land. 3. Waste Reduce waste generation No in-combination effects were identified against and disposal, and achieve this objective. the sustainable management of waste Policy 26 of the Chichester Local Plan Key Policies 2014-2029 document states that it will not allow planning permission for employment sites if it generates air, soil or water pollution. This will provide a positive in-combination effect with NDP Policies 9, 11 and 12. Policy 39 of the CLPKP + document will not allow planning permission if the 4. Pollution development will generate air pollution or any other damage to the environment, thus working in- Reduce air, soil and water combination with NDP Policies 2 and 6 to ensure pollution and development does not produce high levels of pollution. Policies 2, 11, 12 and 13 are likely to increase traffic movements in the plan area and may increase congestion in the area. It is uncertain as to +/- whether this will significantly increase air pollution in East Wittering and Bracklesham. The CLPKP contains policies that may work in- 5. Climate change combination with the NDP policies to minimise the contribution area’s contribution to climate change through Minimise the plan area’s reducing the need to travel, the delivery of green + contribution to climate infrastructure, renewable energy provision and change promoting sustainable travel. These policies include 8, 13, 39 and 41 of the CLPKP. Policies in the CLPKP help to adapt for the effects of climate change. This includes resisting 6. Climate change development in Flood Zones 2 and 3 and adaptation delivering green infrastructure. Such policies + Plan for the anticipated include 42 and 52. Policy 40 includes a clause levels of climate change stating that any new proposals will include measures to adapt to climate change, such as the provision of GI and SuDS. The following policies in the CLPKP all relate to 7. Transport transport within the district, in terms of both Improve the efficiency of promoting sustainable transport and tackling + transport networks by congestion: Policies 8, 13, 39 and 41. These Policies increasing the proportion of are expected to act cumulatively with those in the travel by sustainable modes NDP to improve transport in the plan area. and by promoting policies which reduce the need to NDP Policies 2, 11, 12 and 13 are likely to increase travel traffic movements in the plan area and may - increase congestion as a result. 8. Landscape Protect, enhance and manage the character and Policies in the CLPKP likely to work in-combination appearance of the landscape with the NDP to protect and enhance the + and townscape, maintaining landscape and townscape include Policy 7 and 44. and strengthening distinctiveness and its

special qualities 9. Cultural heritage Protect, enhance and Policy 3 of the NDP is likely to work in-combination manage sites, features and with Policy 47 of the CLPKP, which will ensure + areas of archaeological, good design and protect the local distinctiveness historical and cultural of the plan area. heritage importance

10. Housing The provision of housing via Policy 2 of the NDP and Policies 4, 5, 34 and 35 of the CLPKP will work Provide affordable, in-combination to deliver an adequate mix of ++ environmentally sound and housing tenure and types in the plan area, good quality housing for all including affordable housing.

11. Rural barriers The NDP Policies 7, 10, 11 and 12 will work in combination to ensure that key services are easily + Reduce barriers for those accessible, thus reducing the barriers to living in a living in rural areas rural area.

12. Health Policies 4, 5 and 10 in the NDP are expected to work in-combination to protect and promote Safeguard and improve healthy living. This may have positive implications + community health, safety on the mental health of residents and encourage and well being them to partake in outdoor recreation.

13. Economy NDP Policies 8, 9, 10,11, 12 and 13 will work in- combination to bring new jobs and visitors to the Develop a dynamic, diverse area, thus helping the local economy. The NDP and knowledge-based policies will also work in-combination with Policy + economy that excels in 24 of the CLPKP document which discusses the innovation with higher value, possibility of providing employment land to the lower impact activities plan area.

6 Significant effects and mitigation

6.1 Introduction

6.1.1 The following chapter further explores uncertain and negative effects identified for policies in Chapter 5.

6.1.2 These are presented under the relevant SEA Objective. The following objectives are not discussed as no uncertain or negative effects were identified against them:

• SEA Objective 3 (Waste);

• SEA Objective 4 (Pollution);

• SEA Objective 5 (Climate Change Minimisation);

• SEA Objective 8 (Landscape);

• SEA Objective 9 (Cultural Heritage);

• SEA Objective 10 (Housing);

• SEA Objective 11 (Rural Barriers);

• SEA Objective 12 (Health and Wellbeing); and

• SEA Objective 13 (Economy).

6.2 Significant effects, mitigation and uncertainty

6.2.1 This chapter considers significant potential adverse effects that have been identified through the assessment process and recorded as uncertain using the assessment classification in Table 4.1. Where possible, mitigation has been prescribed. The effects are described as potential adverse since any policy categorised as uncertain may also have positive effects and the nature of the effects might be only partially known.

6.2.2 The mitigation hierarchy is a sequential process that operates in the following way: firstly, if possible, adverse effects should be avoided. Failing this, the nature of the effect should be reduced, if possible, so that it is no longer significant. If neither avoidance nor reduction is feasible, mitigation measures should be considered. Mitigation prescriptions might include changes to policy wording, advocating design guides, offsetting biodiversity effects or provision of new supporting green infrastructure. In the case of this SEA Report, mitigation has been supplied to help address negative effects so that, if possible, no residual affects remain.

6.2.3 A summary of the results of the appraisal of policies, as presented in Chapter 5, is shown in Table 6.1.

Table 6.1: Summary of all assessment findings presented in Chapter 5

Name SEA Objective 1 2 3 4 5 6 7 8 9 10 11 12 13 A spatial plan for the 1 0 +/- 0 0 + +/- + + 0 0 + 0 0 parish

2 Housing Site Allocations +/- -- 0 0 + -- ++ + 0 + ++ - 0

3 Design 0 0 0 0 0 + 0 + + 0 0 0 0

East 4 Wittering/Bracklesham + 0 0 0 + + + + 0 0 + + 0 Green Infrastructure Open Spaces and 5 Seafront 0 0 0 0 0 0 0 + 0 0 0 + 0

6 Natural Environment + 0 0 0 0 0 0 + 0 0 0 0 0

7 Schools 0 0 0 0 0 0 + 0 0 0 + 0 +

8 Employment/Service Hub 0 0 0 0 + 0 + 0 0 0 + 0 0

9 Local Employment 0 0 0 0 + + + + 0 0 0 0 +

10 Medical Service Centre 0 0 0 0 0 0 0 0 0 0 + + +

East Wittering Village 11 0 0 0 0 0 0 +/- + 0 0 + 0 + Centre

Bracklesham Village 12 0 0 0 0 0 0 +/- + 0 0 + 0 + Centre

13 Local Tourism 0 0 0 0 0 0 +/- 0 0 0 0 0 +

6.3 SEA Objective 1: Biodiversity and Geodiversity

6.3.1 Policy 2 was identified as having uncertain effects with regards to SEA Objective 1, Biodiversity. This arises through the potential loss of biodiversity where semi-natural habitats would be replaced with housing or employment developments.

6.3.2 It is recommended that an ecological survey is carried out at the site allocated for development in Policy 2. This would allow the ecological value of the site to be determined and protected and/or enhanced if seen to be important. Specific mitigation strategies can be tailored by the ecologist and implemented to maximise environmental sustainability.

6.4 SEA Objective 2: Natural Resources

6.4.1 Policy 1 was identified as having uncertain effects with regards to SEA Objective 2, Natural Resources. This is due to the potential loss of best and most versatile agricultural land, which may be permanently lost if the land is used for development. The land in question has been categorised as Grade 3. It is recommended that a soil survey is carried out at the sites categorised as Grade 3 land in order to determine whether it is Grade 3a or 3b.

6.4.2 Negative effects were identified against the site proposed in Policy 2. This is because the land allocated for development is categorised as Agricultural Land Classification Grade 2, which is recognised as forming the best and most versatile agricultural land in the NPPF.

6.4.3 Loss of best and most versatile land is an irreversible effect that cannot be compensated for. Further information on local quantity and distribution of best and most versatile agricultural land would give more detail on the magnitude of this loss.

6.5 SEA Objective 6: Climate change adaptation

6.5.1 Negative effects were identified against SEA Objective 6 for Policy 2, which proposes one development site. The site was assessed negatively against this SEA Objective since it is situated partially in Flood Zone 3, making it at high risk of flooding.

6.5.2 Uncertain effects were identified against SEA Objective 6 for Policy 1. The policy proposes all future development is kept within a distinct settlement boundary. However, some undeveloped areas within the settlement boundary lie within Flood Zone 3 and it is possible that development in a Flood Zone may occur.

6.5.3 Flood risk should be addressed by avoiding development on land most at risk of flooding and providing suitable Sustainable Urban Drainage Systems (SUDS) infrastructure. Where possible, green infrastructure, such as areas of green space and plantations of trees and shrubs should incorporated into, be adjacent to, or link to the site.

6.6 SEA Objective 7: Transport

6.6.1 Policies 11, 12 and 13 were identified as having uncertain effects against SEA Objective 7. All three of the policies may result in an increase in visitors to, and associated cars in, East Wittering and Bracklesham, thus increasing the likelihood of congestion in the area. With Policies 11 and 12 proposing additional car parking, an increase in cars in the village centres is likely.

6.6.2 Policies 11, 12 and 13 were assessed as negative in-combination against SEA Objective 7 as all three will bring an increased level of traffic on the roads in the plan area and may result in congestion.

6.6.3 The effects could be minimised through promoting travel by sustainable modes of transport. This could include introducing incentives such as discounts for visitors travelling by sustainable transport and ensuring tourist attractions are accessible by public transport, including provision of bike storing facilities. Improvements to sustainable modes of transport, such as extended and more regular bus services, may encourage travel by these modes.

6.7 SEA Objective 12: Health and wellbeing

6.7.1 Policy 2 was identified as having negative effects against SEA Objective 12 due to the relative inaccessibility of health services in parts of the plan area.

6.7.2 Issues regarding inaccessibility of health services could be mitigated by provision of new, accessible services or by improving sustainable transport links to existing services that have capacity for new patients.

6.7.3 Green space and recreational space should be retained if possible and its role enhanced for both people and nature. If loss of recreational space is inevitable, alternative recreational space and facilities could be provided nearby, of at least an equal size and quality. Loss of recreational space could be permitted if it can be demonstrated that the new development would improve health and wellbeing of residents in other ways or if sufficient recreational opportunities are available nearby.

7 Reasonable Alternatives: Outline of the reasons for selection and rejection

7.1 PPG advice on the selection of reasonable alternatives

7.1.1 The Planning Practice Guidance (PPG)23 states that the environmental report accompanying a neighbourhood plan should ‘outline the reasons the alternatives were selected, the reasons the rejected options were not taken forward and the reasons for selecting the preferred approach in light of the alternatives’.

7.1.2 It is stressed that selection and rejection of sites is a decision made by the East Wittering and Bracklesham NDP Steering Group and not by Lepus Consulting. The role of Lepus Consulting is to provide an objective assessment of options, which can then be used by plan makers to make decisions regarding the selection of preferred options.

7.2 Distribution options

7.2.1 The three distribution options were explored in the rCOH Housing Option note24. The note recommends that options 2 and 3 are taken forward for assessment. Distribution options 1 and 3 have been rejected and option 2 has been selected as the distribution option for the plan. The reasons for rejection of options 1 and 3 have been extracted from the rCOH report and are outlined in Table 7.1.

Table 7.1: Reasons for rejection of distribution options 1 and 3 by rCOH

Option Reasons for rejection A review of the site marking exercise indicates that a large proportion of sites falling within this option are either unavailable, likely to be treated as windfall, already have planning applications, or have little or no potential as assessed in the SHLAA 2013/2014 as they are stand alone sites isolated from the main settlement. Taken as a whole the sites are unlikely to yield the housing number set out in Policy 24. 1 Strategy as a whole would fail to deliver the policy intent of CDC Policy 24 or the residual housing requirement of 130 dwellings. It contains considerable risk of placing further pressure on existing infrastructure and services and may require other uses such as employment to be displaced which could result in a loss of jobs or access or employment in the area. This option is subject to a planning application of 110 dwellings, should this be upheld then a residual allocation of 3 20 dwellings would be needed to achieve the overall yield of 130 dwellings. Given the nature of the site it is considered to

23 DCLG (2015) Planning Practice Guidance 24 rCOH (2015) Housing Options Note (3rd November 2015)

be more challenging to integrate it with the surrounding settlement although ways to achieve this are included in the scheme proposals.

7.3 Identifying reasonable alternatives for sites

7.3.1 The Chichester Local Plan Key Policies 2014-2029 document allocates approximately 180 houses to East Wittering and Bracklesham.

7.3.2 The starting point for identifying site allocation alternatives (Policy 2) was the Chichester Strategic Housing Land Availability Assessment (SHLAA)25. The Steering Group contacted all SHLAA site landowners and dismissed those sites at which landowners expressed no interest in development within the plan period.

7.3.3 The East Wittering and Bracklesham Neighbourhood Plan Group held a call for sites.

7.3.4 Three distribution options were assessed (see Appendix C), and this informed the selection of sites to be taken forward.

7.3.5 No alternatives for other policies were put forward.

7.4 Reasons rejected site options were not taken forward

7.4.1 Table 7.1 reproduces information sourced from the East Wittering and Bracklesham Neighbourhood Plan Site Assessment Report26 (EWBNPSAR, 2015). It presents the reasons behind the rejection of the options considered as part of preparing the Pre-Submission Plan.

Table 7.1: Reasons for not taking forward alternatives to Policy 2

Site Reason for not taking forward Windmill, Church Road Not available for development. This is an employment site and the Local Plan seeks Co-op, Stocks Lane to retain it for this use only. School Playing Field Not available for development. Results of SEA – Flood Zone 3 and loss of best and Land north of Briar Avenue most versatile land. Land north of Stocks Lane Site not in keeping with vision of the plan. Land off Wessex Avenue Results of SEA – loss of best and most versatile land. Can only be developed in conjunction with land to Land opposite Richardsons the south. Half the land is currently occupied with existing Land at Church Farm Lane houses.

Martlets, Peerly Road Too small to be allocated in the plan. This is an employment site and the Local Plan seeks Cobham, Stocks Lane to retain it for this use only.

25 Chichester District Council (2014) Strategic Housing Land Availability Assessment – May 2014 26 rCOH (2015) East Wittering and Bracklesham Neighbourhood Plan Site Assessment Report, 23rd November 2015. Received by email.

The Local Plan seeks to retain existing tourism sites Gees Camping and infrastructure. Land west of Bracklesham Lane Results of SEA – loss of best and most versatile land. 1 Sunlands Not available for development. Land north of Lively Lady Site too small for allocation in NP. Land south of Grasmere Site too small for allocation in NP. Land north of Grasmere Site too small for allocation in NP. Results of SEA – Flood Zone 3 and loss of best and Land south of Clappers Lane most versatile land.

7.5 Reasons for selecting the preferred approach

7.5.1 The NDP states that the selected site (Land West of Bracklesham Lane) presented in Policy 2 is considered to:

• Respect the setting, form and character of the settlement;

• Avoid actual and perceived coalescence of settlements; and

• Ensure good accessibility to local services and facilities.

7.5.2 The full reasons for selecting this site are presented in the EWBNPSAR, 2015. Extracts outlining the reasons for selection are presented in Table 7.2.

Table 7.2: Reasons for site selection

Reasons for selecting Land west of Bracklesham Lane The proposal will extend the northern boundary of the settlement, by filling in a gap between Bracklesham Lane and Downview recreation ground. This meets the NP vision to have a clearly defined settlement boundary. The site adjoins Downview, with a car park proposed on the western side of the site, which will provide a much needed facility for Downview, as well as allowing easier pedestrian access for new residents to East Wittering village. This use of land will address the fact that the area by the stream on the western side is in Flood Zone 3 and will help protect houses from any flood risk as outlined in Policy 3.7. A bridleway/cycle path is envisioned within the site providing horses with a route from Bracklesham Lane to Stubcroft Lane and then Stocks Lane avoiding the busy roads. New cycle paths and footpaths through the site will provide easier pedestrian access to the village of East Wittering. This will promote the NP objective to aid connectivity between the villages and the open space. The green infrastructure at Downview will be enhanced by linking to the site via pedestrian footbridges only and the site itself will provide a lake, creating more green infrastructure for residents’ enjoyment. The proposal will position bungalows adjacent to the existing mature houses on Stocks Lane, so that the view of the development will be softened. This fits with the NP objective of finding a location which will not harm the character of the village. The views from the north mentioned in the SEA will be housing, but it is already housing. It is planned that the gardens of the new development will back on to the farmland and that some degree of screening will soften the visual impact from the north. The proposals take into account those aspects set out in Policy 2: smaller dwellings for commuters to the east nearer the exit onto Bracklesham Lane, bungalows and housing

for elderly in the west nearer the pedestrian access to the village; no buildings higher than two storeys; roads of a standard adoptable by Highways; at least two off street car parking spaces per dwelling; a lake and connecting footpaths and cycle ways; the lake to act as a large balancing pond and the ditches surrounding the site to cope with surface water run-off. The design of the houses are to be varied and to reflect local architecture in line with Policy 3. Adjoining properties will largely meet the development garden-to-garden to minimise flood risk. An area for employment is included in the proposal which will be on Bracklesham Lane and slowly developed as businesses are found to occupy the plots. Thoughtful planning is required to ensure that the visual impact is minimised, but the employment opportunities and support for the growth of local small businesses should outweigh any negative impact. This meets the NP objective to provide support for local employment as outlined in Policy 9. There is a possibility that a medical service centre for Bracklesham could be located in the eastern area of the site which is preserved for business use. However, the current trend in the NHS is to centralise services rather than providing satellite surgeries, but Policy 10 supports such a measure if Government Policy changes in the future.

8 Recommendations to enhance environmental performance

8.1 Introduction

8.1.1 This chapter provides recommendations for maximising the environmental opportunities presented in the NDP.

8.2 Recommendations for enhancement

8.2.1 The SEA has suggested measures to prevent, reduce or offset significant adverse effects of implementing East Wittering and Bracklesham NDP throughout Chapter 6. These measures are collectively referred to as ‘mitigation measures’.

8.2.2 Whilst the NDP as it stands brings a range of positive environmental effects, Chapter 6 has addressed where the effects are adverse or uncertain. A number of strategic proposals have been suggested to help the NDP further improve its environmental performance throughout its implementation. These recommendations for enhancement are summarised below:

• The policies should aim to improve access by a range of sustainable transportation modes, including bus travel. This includes improved provision, capacity and connectivity of sustainable transport.

• Areas of green space should be improved for a diversity of uses and to enhance biodiversity.

• Opportunities for biodiversity gain should be identified and created where possible, including creation of wildlife corridors.

• Sustainable Urban Drainage Systems could be incorporated into development to reduce the risk of flooding and resilience to the increased threat of flood risk as a result of climate change.

• Renewable energy should be included in developments where possible.

• Sustainable waste management should be encouraged with incentives or local programmes to reduce the amount of waste sent to landfill.

• Development will need to ensure that services, facilities and suitable employment opportunities are accessible for new residents and have capacity to meet the needs of all residents, including the elderly.

• The effect of development on historic features can be mitigated up to a point through careful design and siting, with development being located in such a way as to avoid impacts on the most sensitive features.

• Proposals in proximity to listed buildings and other historic features should consider how to avoid and mitigate effects on the settings of these features.

• The best and most sensitive areas of development sites, in terms of landscape, should be maintained with strong landscape infrastructure. All important landscape and townscape features should be retained and be enhanced where possible. Considerate design and landscaping should be carried out to integrate the development into the area.

• Any development that takes place should take into account the size, scale, shape and character of the area. All development should be designed sympathetically and not harm the character of the area or detract from its surroundings, particularly in conservation areas.

• Larger developments should aim to conform to BREEAM ‘good’ standards to help protect natural resources and ensure sustainable development. Housing development should aim to meet additional Buildings Regulations standards and contribute towards achieving Zero Carbon Homes.

• Those effects identified as uncertain should be monitored in order to establish early on in the lifetime of the plan to determine whether they will become negative, as well as provide time to compensate for and mitigate any potential negative effects. Identifying potential negative effects early and developing mitigation or compensation can help address any potential adverse effects and simultaneously serve to maximise environmental performance of the plan. Details on monitoring are discussed further in Chapter 9.

9 Monitoring

9.1 Monitoring proposals

9.1.1 The SEA Directive states that ‘member states shall monitor the significant environmental effects of the implementation of plans and programmes… in order, inter alia, to identify at an early stage unforeseen adverse effects, and to be able to undertake appropriate remedial action’ (Article 10.1). In addition, the Environmental Report should provide information on a ‘description of the measures envisaged concerning monitoring’ (Annex I (i)). This represents Stage E of SA, according to the DCLG (2015) Guidance on SEA for Neighbourhood Plans.

9.1.2 The monitoring requirements typically associated with the SEA process are recognised as placing heavy demands on authorities with SEA responsibilities. For this reason, the proposed monitoring framework should focus on those aspects of the environment that are likely to be negatively impacted upon, where the impact is uncertain or where particular opportunities for improvement might arise.

9.1.3 The SEA process has identified some areas that would benefit from being monitored due to their uncertain effects. The areas specified for monitoring include:

• Ecological value of greenfield sites and trends in net biodiversity;

• Rate of visitor increase at Bracklesham Bay SSSI;

• Carbon footprint of East Wittering and Bracklesham;

• Percentage of residents choosing to travel by sustainable modes of transport;

• Capacity of local amenities, services and facilities;

• Accessibility of services and facilities;

• Rate of loss of and demand for best and most versatile agricultural land;

• Number of developments in Flood Zones 2 or 3; and

• Average journey time from East Wittering to Chichester.

9.1.4 Monitoring is particularly useful in answering the following questions:

• Were the assessment’s predictions of environmental effects accurate?

• Does the NDP contribute to the achievement of desired SEA objectives?

• Are mitigation measures performing as well as expected?

• Are there any unforeseen adverse effects? Are these within acceptable limits, or is remedial action required?

9.1.5 The purpose of monitoring is to measure the environmental effects of a plan, as well as to measure success against the plan’s objectives. It is therefore beneficial if the monitoring strategy builds on monitoring systems that are already in place. It should also be noted that monitoring could provide useful information for future plans and programmes. Effects to be monitored are shown in Table 9.1.

Table 9.1: Discussion of effects to be monitored

Potential adverse Indicator Frequency of Trigger or uncertain effect, monitoring and scale or area to be monitored Ecological value of Area of land Annually, entire plan Year on year greenfield sites and managed for nature area decrease trends in net conservation biodiversity Number of Annually, entire plan Year on year developments area increase or no requiring ecological change mitigation measures Number of Annually, entire plan Year on year developments area decrease or no demonstrating net change gain in biodiversity Rate of visitor Number of visitors Annually, Bracklesham Year on year increase at to Bracklesham Bay Bay increase (in Bracklesham Bay conjunction with SSSI decrease in condition, as below) Contribution of Carbon footprint of Year on year Annually, entire plan East Wittering to East Wittering and area increase or no climate change Bracklesham change Use of sustainable Percentage of Annually, entire plan Year on year modes of transport residents choosing area decrease or no to travel by change sustainable modes of transport Bus service Annually, entire plan Year on year patronage area decrease Capacity of Number of services Annually, all essential No change or year services and and facilities (e.g. services and facilities on year increase facilities schools, GP surgeries) that are oversubscribed Proportion of residents with key services and Accessibility of facilities within No change or services and Annually, all essential decrease year on walking distance or services and facilities facilities year on a bus route that stops within 400m of their house Loss of best and Rate of loss of best Annually, entire plan Year on year most versatile and most versatile area increase agricultural land agricultural land Demand for best Annually, entire plan Year on year and most versatile area increase agricultural land

Number of Development in developments in Annually, entire plan Year on year Flood Zone area increase Flood Zone 2 or 3 Average journey Congestion in the time from East Annually, entire plan Year on year plan area Wittering to area increase Chichester

9.2 Links with the Annual Monitoring Report

9.2.1 SEA monitoring and reporting activities can be integrated into the regular planning cycle. As part of the monitoring process, Chichester District Council currently prepare an Annual Authorities Monitoring Report. It is anticipated that the NDP Steering Group could work with Chichester District Council to incorporate elements of the SEA monitoring programme for the NDP into this process.

9.2.2 Details of any monitoring programme are, at this stage, preliminary and may evolve over time based on the results of consultation and the identification of additional data sources (as in some cases information will be provided by outside bodies). The monitoring of individual schemes/proposals should also be addressed at project level.

10 Next Steps

10.1.1 This SEA Report has been published alongside the East Wittering and Bracklesham Pre-Submission Neighbourhood Development Plan (2015). A period of consultation will provide an opportunity for individuals, businesses and other organisations to submit representations regarding the Pre-Submission NDP. These comments will be taken into account in the preparation of a Submission version NDP.

10.1.2 The Submission NDP will be submitted to the local planning authority, Chichester District Council. Once the District Council is satisfied that the NDP complies with all statutory requirements, it will be published for consultation for a minimum of six weeks, in particular inviting representations from any consultation body referred to in the consultation statement. The Neighbourhood Plan will also be sent to an independent examiner who will test whether or not the plan meets the basic conditions27.

10.1.3 Formal representations made through the consultation process will be submitted to the Examiner of Neighbourhood Plans alongside the draft NDP and this SEA Report. This represents Stage D of the SEA, according to the DCLG (2015) guidance. If the examiner of Neighbourhood Plans is satisfied that the basic conditions have been met, the NDP will be subject to local referendum. If over 50% of votes at the referendum are in favour of the NDP, the NDP will become adopted as part of the statutory development plan.

10.1.4 SEA Regulations 16.3c)(iii) and 16.4 require that a ‘statement’ be made available to accompany the plan, as soon as possible after the adoption of the plan or programme, known as a post-adoption statement. The purpose of the SEA statement is to outline how the SEA process has influenced and informed the NDP development process and demonstrate how consultation on the SEA has been taken into account.

10.1.5 As the regulations outline, the statement should contain the following information:

• The reasons for choosing the preferred policies for the NDP as adopted in the light of other reasonable alternatives dealt with;

• How environmental considerations have been integrated into the NDP;

• How consultation responses have been taken into account; and

• Measures that are to be taken to monitor the significant environmental effects of the NDP.

• To meet these requirements, following any further changes before adoption, a Post Adoption Statement will be published with the adopted version of the NDP.

27 Town and Country Planning Act as amended, Schedule 4B

10.2 Commenting on the Environmental Report

10.2.1 Any comments on this SEA Report should be directed through Chichester District Council or the East Wittering and Bracklesham Neighbourhood Plan Steering Group.

11 References

Barton, H., Grant, M. and Guide, R. (2010) Shaping Neighbourhoods for local health and global sustainability

Buglife (2009) Planning for Brownfield Biodiversity: A best practice guide

Chichester District Council (1999) Chichester Local Plan 1999

Chichester District Council (2008) Strategic Flood Risk Assessment

Chichester District Council (2014) Chichester Local Plan Key Policies 2014-2029

Chichester District Council (2014) Infrastructure Delivery Plan 2014-2029

Department for Communities and Local Government (2012) National Planning Policy Framework. Available at: https://www.gov.uk/government/uploads/system/uploads/attachment_data/file/6077/21 16950.pdf

DEFRA (2009) Climate Change Projections. Available at: http://ukclimateprojections.defra.gov.uk/

Department for Communities and Local Government (DCLG; 2013) National Planning Practice Guidance - Strategic environmental assessment and sustainability appraisal; web based guidance to accompany the National Planning Policy Framework. Available at: http://planningguidance.planningportal.gov.uk/blog/guidance/

Environment Agency (2014) What’s in your backyard? (Map): Flood Map for Planning, Available at: http://maps.environment- agency.gov.uk/wiyby/wiybyController?topic=floodmap&layerGroups=default&lang=_e&ep =map&scale=9&x=326995.30208333355&y=125994.2500000007#x=114331&y=125523&lg= 1,&scale=11

Forest Research (2010) Benefits of Green Infrastructure. Available at: http://www.forestry.gov.uk/pdf/urgp_benefits_of_green_infrastructure.pdf/$file/urgp_be nefits_of_green_infrastructure.pdf

Hankinson Duckett Associates (2009) Chichester District AONB Landscape Capacity Study

Hankinson Duckett Associates (2011) Chichester District Landscape Capacity Study Extension

Historic England (2015) The National Heritage List for England

Ian Douglas for UK MAB Urban Forum (2004) Urban Greenspace and mental health

Lepus Consulting (2015) Strategic Environmental Assessment of the East Wittering and Bracklesham Neighbourhood Plan: SEA of Reasonable Alternatives

Lepus Consulting (2015) Strategic Environmental Assessment of the East Wittering Neighbourhood Plan: Final Scoping Report

Lepus Consulting (2015) Strategic Environmental Assessment of the East Wittering and Bracklesham Neighbourhood Plan: Screening Document

Natural England (2013) Nature on the Map. Available at: http://www.natureonthemap.naturalengland.org.uk/map.aspx?m=bap

Natural England (2007) Wildlife on allotments

NHS (2015) NHS Choices Website, ‘Services near you’, available at: http://www.nhs.uk/Service-Search/GP

PAS (2015) Changes to government policy (incorporating Nov 14 and Mar 15 changes)

RIBA (2013) City health check: How design save lives and money

Save Historic Newmarket v. Secretary of State and Forest Heath District Council. Case Number: co/6882/2010

Smith et al (2005) Urban domestic gardens (IX): Composition and richness of the vascular plant flora, and implications for native biodiversity

Appendix A: SEA Framework

East Wittering and Bracklesham Neighbourhood Development Plan SEA Framework

Decision making criteria: Will the SEA Objective Indicators option/proposal…

1 Protect, enhance and manage Q1a Will it lead to a loss of or Extent (and condition) of priority biodiversity and geodiversity. damage to biodiversity habitats interest? Extent of priority species Area and condition of nationally designated sites in appropriate management Q1b Will it lead to habitat creation, Creation of BAP habitats matching BAP priorities? Improvement of habitat conectivity Number of protected species in the area

Q1c Will it maintain and enhance Number, area and condition of sites nationally designated for nationally designated sites in their biodiversity interest and appropriate management increase their area? Is it near to Bracklesham Bay SSSI Q1d Will it increase the area of sites Area designated for geological interest designated for their geodiversity interest? Q1e Will it link up areas of Extent (and condition) of priority fragmented habitat? habitats Q1f Will it increase awareness of Number of school trips to Bracklesham biodiversity and geodiversity Bay SSSI assets? Number of accessibility improvements to nature reserves and local sites (including geodiversity sites) Number of interpretation improvements (including information boards etc) in nature reserves and local sites 2 Protect and conserve natural Q2a Will it include measures to limit Average domestic water consumption resources. water consumption? (l/head/day) Q2b Will it utilise derelict, degraded % of dwellings built on previously and under-used land? developed land Previously developed land that has been vacant or derelict for more than five years

Q2c Will it lead to the more efficient Housing density in new development: use of land? average number of dwellings per hectare

Appendix A, SEA Framework Page 1 2 Protect and conserve natural resources.

Decision making criteria: Will the SEA Objective Indicators option/proposal…

Q2d Will it lead to reduced Percentage of commercial buildings consumption of materials and meeting BREEAM Very Good Standard resources? or above or equivalent Percentage of housing developments achieving a four star or above sustainability rating as stipulated by the Code for Sustainable Homes

Q2e Will it lead to the loss of the Area of Grades 2 and 3a agricultural best and most versatile land lost to new development agricultural land?

3 Reduce waste generation and Q3a Will it provide facilities for the Type and capacity of waste disposal, and achieve the seperation and recycling of management facilities sustainable management of waste? waste. Household waste (a) arisings and (b) recycled or composted

Q3b Will it encourage the use of Reuse of recycled materials from former recycled materials in building stock and other sources construction?

4 Reduce air, soil and water Q4a Will it lead to improved water % of watercourses classified as good or pollution. quality of both surface water very good biological and chemical groundwater features? quality

% change in pollution incidents

Q4b Will it lead to improved air No. of days when air pollution is

quality? moderate or high for NO2, SO2, O3, CO or PM Q4c Will it maintain and enhance Area10 of contaminated land (ha) soil quality? % of projects (by number and value) involving remediation of any kind Q4d Will it reduce the overall % change in pollution incidents amount of diffuse pollution to air, water and soil? 5 Minimise the district's Q5a Will it help reduce Snitterfield's Proportion of electricity produced from contribution to climate change. carbon footprint? renewable resources Proportion of new homes exceeding a four star or above sustainability rating

for the "Energy/CO2" category as stipulated by the Code for Sustainable Homes Appendix A, SEA Framework Page 2 5 Minimise the district's Q5a Will it help reduce Snitterfield's contribution to climate change. carbon footprint?

Decision making criteria: Will the SEA Objective Indicators option/proposal…

All development likely to exceed BREEAM good standard Per capita greenhouse gas emissions Emission by source Percentage of people aged 16-74 who usually travel to work by driving a car or van Percentage increase of car use resulting from development

CO2 , methane and nitrous oxide emissions per sector Q5b Will it help raise awareness of Number of initiatives to increase climate change mitigation? awareness of energy efficiency 6 Plan for the anticipated levels Q6a Will it help limit potential Amount of new development (ha) of climate change. increases in flood risk likely to situated within a 1:100 flood risk area, take place in the district as a including an allowance for climate result of climate change? change Number of planning permissions granted contrary to the advice of the Environment Agency on flood defence grounds Number of properties at risk of flooding.

Q6b Will it encourage the Thermal efficiency of new and retro development of buildings fitted development; % planning prepared for the impacts of permissions for projects designed with climate change? passive solar design, building orientation, natural ventilation Q6c Will it retain existing green Amount of new greenspace created per infrastructure and promote the capita expansion of green infrastructure to help facilitate climate change adaptation?

Q6d Will it help prevent flood risk Amount of new development (ha) present in the district from situated within a 1:100 flood risk area fluvial flooding? (Flood Zone 3), including an allowance for climate change Q6e Will it help prevent flood risk Number of properties at risk of flooding present in the district from surface water flooding?

Appendix A, SEA Framework Page 3 6 Plan for the anticipated levels of climate change.

Decision making criteria: Will the SEA Objective Indicators option/proposal…

Q6f Will it help limit potential Number of planning permissions increases in flood risk likely to granted contrary to the advice of the take place in the district as a Environment Agency on flood defence result of climate change? grounds 7 Improve the efficiency of Q7a Will it reduce the need to Percentage of completed significant transport networks by travel? local service developments located increasing the proportion of within a defined centre travel by sustainable modes Average distance (km) travelled to fixed and by promoting policies place of work which reduce the need to Percentage of new residential travel. development within 30 minutes public transport time of a GP, hospital, primary and secondary school, employment and major health centre. Percentage of residents surveyed finding it easy to access key local services. Q7b Will it encourage walking and Percentage of people aged 16-74 who cycling? usually travel to work by bicycle or on foot Proportion of new development providing cycle parking. Q7c Will it reduce car use? Percentage of people aged 16-74 who usually travel to work by driving a car or van Q7d Will it encourage use of public Percentage of people aged 16-74 who transport? usually travel to work by bus or train Number of journeys made by bus per annum Percentage of development in urban/rural areas within 400m or 5 minutes walk of half hourly bus service Number of journeys made by train per annum Q7e Will it provide adequate means Distance of new development to of access by a range of existing or proposed public transport sustainable transport modes? routes. Provision of new walking and cycling links to accompany new development Q7f Will it help limit HGV traffic HGV traffic flows flows? 8 Protect, enhance and manage Q8a Will it safeguard and enhance Application of detailed characterisation the character and appearance the character of the landscape studies to new development (West of the landscape and and local distinctiveness and Sussex LCA) townscape, maintaining and identity? strengthening distinctiveness Appendix A, SEA Framework Page 4 and its special qualities. 8 Protect, enhance and manage Q8aDecisionWill makingit safeguard criteria: and enhanceWill the SEA Objective Indicators the character and appearance theoption/proposal… character of the landscape of the landscape and and local distinctiveness and townscape, maintaining and identity? Sensitivity of the area to commercial strengthening distinctiveness and residential development as stated in and its special qualities. Landscape Sensitivity Assessment Q8b Will it preserve or enhance the Developments resulting in loss of setting of cultural heritage landscape features defined as locally assets? distinctive in the West Sussex Local Distinctiveness Study Q8c Will it help limit noise pollution? Tranquillity assessments

Q8d Will it help limit light pollution? Tranquillity assessments Qe Will it reuse degraded Re-use of derilict buildings or areas landscape/townscape? Q8f Will it retain or enhance local Development contributes to existing townscape? townscape 9 Protect, enhance and manage Q9a Will it preserve buildings of Number of Grade I and Grade II* sites, features and areas of architectural or historic interest buildings at risk. archaeological, historical and and, where necessary, Number of Grade II and locally listed cultural heritage importance. encourage their conservation buildings at risk. and renewal? Areas of historic interest at risk Number of buildings of local historic interest demolished/restored as a result of planning permission granted Q9b Will it preserve or enhance Proportion of scheduled monuments at archaeological sites/remains? risk from damage, decayor loss Number/proportion of development proposals informed by archaeological provisions, including surveys Q9c Will it preserve or enhance the Proportion of conservation areas setting of cultural heritage covered by up-to-date appraisals (less assets? than five years old) and published management plans.

10 Provide affordable, Q10a Will it ensure all groups have Affordable housing completions environmentally sound and access to decent, appropriate good quality housing for all. and affordable housing? Q10b Will it identify an appropriate Net additional dwellings for the current supply of land for new housing? year.

Q10c Will it ensure that all new Number of major housing applications development contributes to refused on design grounds. local distinctiveness and Accessible Natural Greenspace improve the local environment?

Appendix A, SEA Framework Page 5 10 Provide affordable, environmentally sound and good quality housing for all.

Decision making criteria: Will the SEA Objective Indicators option/proposal…

Q10d Will it reduce the number of Number of households on the Housing households on the Housing Register Register? Q10e Will it encourage well-designed, % development meeting Building for high quality developments that Life standards. enhance the built and natural environment?

11 Reduce barriers for those living Q11a Will it increase provision of Percentage of residents surveyed in rural areas local services and facilities and finding it easy to access key local reduce centralisation? services Q11b Will it improve accessibility by a Percentage of rural households within range of transport modes to 800m of an hourly or better bus service services and facilities from rural areas? Q11c Will it support the provision of Affordable housing completions in rural affordable housing in rural areas areas? Q11d Will it prevent the degradation Area of derelict or underutilised land on of land on the urban fringe? the urban fringe Q11e Will it lead to a loss of Area of agricultural land not in use or agricultural land? under active management. Q11f Will it safeguard local Application of detailed characterisation distinctiveness and identity? studies to new development 12 Safeguard and improve Q12a Will it improve access for all to Travel time by public transport to community health, safety and health, leisure and recreational nearest health centre and sports facility. well being. facilities? Q12b Will it improve and enhance the Area of parks and green spaces per district's green infrastructure 1,000 head of population network? Accessible Natural Greenspace Area of playing fields and sports pitches. Amount of land needed to rectify deficiencies in Open Space Standards Percentage(ha) of eligible open spaces managed to green flag award standard Percentage of residents that are satisfied with the quantity/quality of open space Q12c Will it improve long term Life expectancy at birth health?

Appendix A, SEA Framework Page 6 12 Safeguard and improve community health, safety and well being.

Q12c Will it improve long term Decisionhealth? making criteria: Will the SEA Objective Indicators option/proposal…

Standardised mortality rates Q12d Will it ensure that risks to Area of contaminated land (ha) human health and the environment from contamination are identified and removed? Q12e Will it encourage healthy and % of adults (16+) participating in at least active lifestyles? 30 minutes of moderate intensity sport and active recreation (including recreational walking) on three or more days of the week The number of sports pitches available to the public per 1,000 population Q12f Will it reduce obesity? Percentage of adult population classified as obese Q12g Does it consider the needs of Percentage of older people being the district's growing elderly supported intensively to live at home population? Q12h Will it enable communities to Percentage of adults surveyed who feel influence the decisions that they can influence decisions affecting affect their neighbourhoods their own local area and quality of life? Q12i Will it improve the satisfaction % respondents very or fairly satisfied of people with their with their neighbourhood neighbourhoods as a place to live? Q12j Will it reduce crime and the Indices of Multiple Deprivation: Crime fear of crime? domain Q12k Will it reduce deprivation in the Indices of Multiple Deprivation district? Q12l Will it improve road safety? Number of people killed or seriously injured on the roads per year 13 Develop a dynamic, diverse and Q13a Will it ensure that new Proportion of residential development knowledge-based economy employment, office, retail and within 30 minutes public transport time that excels in innovation with leisure developments are in of key services higher value, lower impact locations that are accessible to activities. those who will use them by a choice of transport modes?

Q13b Will it help ensure an adequate Ha of new employment land provision supply of employment land?

Appendix A, SEA Framework Page 7 SEA of the East Wittering and Bracklesham NDP March 2016 LC-176_EWB_NDP_SEA_15_070316FG.docx

Appendix B: Assessment Protocol

SA Objectives with assessment protocol criteria

1. Biodiversity and geodiversity: Protect and enhance geodiversity, biodiversity, natural habitats and wild fauna and flora, including (but not only): international, national and local designated sites; and protected species and habitat types identified as priorities for biological conservation Potential for a significant net increase in biodiversity by an increase in the population size, extent, quality and connectivity of: • UK BAP priority species • UK BAP priority habitats • European Protected Species OR ++ Potential for an increase in the number, extent and/or quality of internationally or nationally designated sites, including: • SPA • SAC • Ramsar • SSSI Development will maintain and increase in biodiversity by increasing the population size, extent, quality, condition and connectivity of: • BAP species • BAP habitats + OR Potential for an increase in the number, extent and/or quality of local nature reserves (LNRs) OR Protection and enhancement of ecological networks, e.g. hedgerows Development may decrease biodiversity by fragmenting or reducing: • BAP species • BAP habitats - OR Potential loss, fragmentation or damage to local nature reserves (LNRs) OR Loss or fragmentation of ecological networks, e.g. hedgerows Development may decrease biodiversity by fragmenting or reducing: • UK BAP priority species • UK BAP priority habitats • European Protected Species OR -- Potential for an decrease in the number, extent and/or quality of internationally or nationally designated sites, including: • SPA • SAC • Ramsar • SSSI

1 2. Natural Resources: Protect and conserve natural resources Development is on previously developed land or non-agricultural land

++ OR Development will re-use derelict, degraded and under-used land

Development is on Grade 4 or 3b agricultural land OR Protection of mineral deposits OR + Development will lead to more efficient use of land OR Development will lead to reduced consumption of water, materials and resources Development is on Grade 3a agricultural land OR - Development will lead to less efficient use of land OR Development will increase consumption of water, materials and resources Development is on Grade 1 or 2 agricultural land -- OR Development will sterilise known mineral deposits 3. Waste: Reduce waste generation and disposal, and achieve the sustainable management of waste Development encourages recycling AND waste minimisation Development encourages recycling OR ++ Development encourages waste minimisation OR Development encourages use of recycled materials

Development will lead to a decrease in recycling rates + OR Development is likely to use materials that cannot be recycled

- Development does not encourage recycling AND/OR waste minimisation

Development encourages recycling

-- OR Development encourages waste minimisation

2 OR Development encourages use of recycled materials 4. Pollution: Reduce air, soil and water pollution Development will improve air, water and soil quality OR Development will actively remediate or prevent environmental pollution Development will improve one or more of air, water or soil quality ++ OR Development will maintain air, water and soil quality where this is already good OR Development will reduce congestion and associated pollutants Development will improve one or more of air, water or soil quality OR Development will maintain air, water and soil quality where this is already + good OR Development will reduce congestion and associated pollutants

Development will reduce one or more of air, water or soil quality - OR Development will increase congestion and associated pollutants

Development will reduce air, water and soil quality -- OR Development is likely to lead to environmental pollution

5. Minimise Climate Change: Minimise the plan area’s contribution to climate change

Development will reduce East Wittering’s carbon footprint (including energy and gas consumption) AND ++ Will increase energy efficiency OR Will provide renewable energy generation Development will reduce East Wittering’s carbon footprint (including non- renewable energy consumption and greenhouse gas generation) OR

+ Development will increase energy efficiency Development has poor potential for renewable energy provision OR Development is likely to decrease the carbon footprint of East Wittering

3 Development is likely to increase the carbon footprint per resident of East - Wittering AND has poor potential for renewable energy provision

Development will increase East Wittering’s carbon footprint (including energy and gas consumption) AND -- Will decrease energy efficiency OR Will not provide renewable energy generation

6. Plan for Climate Change: Plan for the anticipated levels of climate change

More than one of the following will apply to development:

++ • Development provides green infrastructure • Development will prevent potential increases in flood risk

Development protects existing green infrastructure

+ OR Development will help limit potential increases in flood risk

- Development has poor access to existing green infrastructure

Development will result in a loss of existing green infrastructure -- OR Development will increase or exacerbate flood risk

7. Transport: Improve the efficiency of transport networks by increasing the proportion of travel by sustainable modes and by promoting policies which reduce the need to travel Development will include provision of key services that would not otherwise be available to residents OR Development is within 400m of a high frequency (More than 2 buses per hour) bus route ++ OR Development will incorporate new pedestrian, cycling and bus routes OR Development is within 600m of a local centre

4 Development will increase accessibility to local services and amenities OR Development within 400m of a moderate frequency bus service (1 or 2 buses per hour) + OR Development is accessible by existing pedestrian and cycling routes OR Development is within 800m of a local centre Development will increase accessibility to local services and amenities OR Development within 400m of a low frequency bus service (1 bus per hour) - OR Development is accessible by existing pedestrian and cycling routes OR Development is within 800m of a local centre Development is not within 400m of a low frequency bus service (fewer than 1 bus per hour) OR -- Development site is not currently accessible by pedestrian and cycling routes OR Development is further than 800m from a local centre and amenities/facilities are accessible by bus, therefore residents are likely to rely on personal car use 8. Landscape and townscape: Protect, enhance and manage the character and appearance of the landscape and townscape, maintaining and strengthening distinctiveness and its special qualities Potential to re-use degraded landscape/townscape in a prominent location OR ++ Development enhances landscape character of landscape and local distinctiveness Development will maintain landscape character and local distinctiveness OR + Development will meet Building for Life Standards OR Development will not exacerbate noise and/or light pollution Development is not in keeping with local development style OR - Negative impact on area of medium landscape value OR Development has the potential to exacerbate noise and/or light pollution

5 Potential negative impact in an area of high landscape value or distinctiveness OR Development causes light and/or light pollution which cannot be mitigated -- OR Development is at odds with existing townscape, particularly if the area has a distinctive style or many listed and historic buildings 9. Historic and cultural features: Protect, enhance and manage sites, features and areas of archaeological, historical and cultural heritage importance. Conservation and renewal of buildings or features of architectural or historic interest OR Development promotes new uses for currently underused Listed Buildings ++ OR Protection or enhancement of listed buildings and/or scheduled monuments OR Protection of archaeological sites/remains Potential to protect and enhance the setting of heritage assets and/or historic townscapes + OR Broadens access to and understanding of the historic environment Potential negative impact on the setting of heritage assets and/or historic townscapes - OR Reduces access to and understanding of the historic environment Loss of or damage to a listed building and/or scheduled monument, in whole or in part or ridge and furrow OR -- Damage to buildings or features of architectural or historic interest OR Damage to archaeological sites/remains 10. Housing: Provide affordable, environmentally sound and good quality housing for all Development will contribute to local housing demand, including affordable housing ++ AND Reduction in the number of households on the housing register Development will contribute to local distinctiveness and improve the local environment + OR Development will contribute to delivering an appropriate mix of housing for

6 the plan area OR Development will contribute to local housing demand Development will reduce local distinctiveness OR - Development will reduce the mix of housing in the plan area OR Development will lead to a loss of current housing stock Development will reduce the availability of affordable housing -- OR Increase in the number of households on the housing register 11. Rural barriers: Reduce barriers for those living in rural areas Development will provide essential services and facilities in rural areas OR ++ Development is within 400m of a high frequency (More than 2 buses per hour) bus route that serves key services (e.g. local shops, medical centres) Development within 400m of a moderate frequency bus service (1 or 2 buses per hour) OR + Development will provide affordable housing in rural areas/provide high quality, accessible amenities and facilities. OR Development within 800m of the local centre Development is further than 400m of a bus stop OR Development will result in an increase in demand on local facilities/amenities - OR Development will remove affordable housing in rural areas OR Development is further than 800m from the local centre Development will lead to a loss of essential services and facilities in rural areas -- OR Development is further than 400m from a bus stop 12. Health: Safeguard and improve community health, safety and well being Provision of the new and accessible facilities that will help meet the needs of the immediate and wider community, such as:

++ • Doctor’s surgery or hospital • Sports and recreation facilities • Amenity green space

7 • Allotments and community gardens Other Green Infrastructure Existing health AND community facilities, with capacity, are accessible by public transport or within close proximity of the site i.e.:

• Hospital within 8km • Leisure centre within 2km • GP within 1km • Local green space within 600m + • Allotments within 300m (Distances taken from Barton, 2010) OR Development will reduce crime and the fear of crime and road safety OR Provision for an ageing population Development is located far from facilities but there is capacity - OR Development is located further than 1km of a GP Development will lead to a loss of essential services and facilities in rural areas OR Development will result in a loss of greenspace

-- OR Development is further than 400m from a bus stop AND 800m from a local centre OR Development is located further than 1km of a GP AND there is no capacity 13. Economy: Develop a dynamic, diverse and knowledge-based economy that excels in innovation with higher value, lower impact activities Increase in employment in a range of sectors, office, retail and leisure developments ++ AND These new developments are accessible by a range of transport modes Development supports new business sectors OR + Development supports the visitor economy OR Provision of new employment land Barriers to new business sectors - OR Barriers to growth of the visitor economy -- Loss of existing employment, office, retail and leisure floorspace

8 SEA of the East Wittering and Bracklesham NDP March 2016 LC-176_EWB_NDP_SEA_15_070316FG.docx

Appendix C: Reasonable Alternatives: assessment of distribution options

Introduction

This appendix presents the assessment of distribution options. These distribution options are taken from the rCOH Housing Note (November 2015). These were the only reasonable alternative distribution options identified by the East Wittering Neighbourhood Development Plan Steering Group. The assessment methodology used is the same as that presented in Chapter 4 of the Environmental Report (March 2016).

Assessment results

Distribution option 1: A combination of Settlement Focus and Dispersal strategy

1 2 3 4 5 6 7 8 9 10 11 12 13 Clim Clim Rural Biodiv. Nat Res Waste Poll Transp Landsc Cult Her House Health Econ mini adapt Barrier +/- ++ 0 0 +/- -- +/- ++ +/- + 0 +/- +/-

1. Development following this option may lead to a loss of habitat connectivity across the urban area. Species surveys should be undertaken to determine the potential presence of European Protected Species (SEA Objective 1). 2. Developing this option will result in development on previously developed, non-agricultural land, thus reducing the need to develop on greenfield sites and helping to protect best and most versatile land (SEA Objective 2). 3. The East Wittering urban area is generally well connected in terms of travel, with frequent bus stops and footpaths providing links around the parish. The ease of accessibility to sustainable transport methods will be dependent on the location of individual sites. As a result, it is not possible to determine the impact on climate change minimisation and transport at this stage (SA Objectives 5 and 7). 4. Areas that may be developed following this option are located in Flood Zones 2 and 3. Development in these areas would be more susceptible to flooding (SA Objective 6). 5. Development following this option will result in use of previously developed land and is likely to improve the appearance of the area through regeneration. Policy 7 and Policy 40 of the CLPKP serve to ensure that design is in keeping with the local area (SEA Objective 8). 6. Two listed buildings are present within the East Wittering urban area. Any new development near to these designations would need to consider the setting of these protected buildings; without design details it is difficult to determine any positive or negative effects of development (SA Objective 9). 7. Development following this option would contribute to fulfilling the local housing demand (SEA Objective 10). 8. This option is located within the settlement boundary of East Wittering, near to local services, and as such is not considered to be in a rural area (SEA Objective 11). 9. Due to the unknown location of development, it is difficult to assess accessibility of health facilities and recreational space if this option were to be taken forward (SA Objective 12). 10. Development may result in the loss or displacement of employment opportunities. The rCOH housing note suggests that, in line with Policy 26 of CLPKP, employment sites will be retained unless it can be demonstrated that the site is no longer required, or appropriate, for employment use (SA Objective 13).

Distribution option 2: Focussed development to the north of the settlement

1 2 3 4 5 6 7 8 9 10 11 12 13 Clim Clim Rural Biodiv. Nat Res Waste Poll Transp Landsc Cult Her House Health Econ mini adapt Barrier +/- -- 0 0 + -- ++ + 0 + ++ - +/-

11. This option consists of open fields, a residential dwelling and camping site to the west of Bracklesham Lane. Hedgerows provide habitat connectivity; loss of these may have negative effects on biodiversity (SEA Objective 1). 12. The are considered in this option is categorised as Grade 2 and 3 agricultural land, therefore development will result in a loss of best and most versatile agricultural land (SEA Objective 2). 13. This option is within 400 metres of a high frequency bus stop, providing residents with links to key amenities in the local area. This will help to reduce the carbon footprint in East Wittering as well as providing sustainable modes of transport to key services (SEA Objective 5, 7 and 11). 14. A stream borders the western edge of the option and areas of Flood Zone 3 are present along the stream. Development in Flood Zone 3 is at highest risk of flooding. This risk may be exacerbated as a result of climate change (SEA Objective 6). 15. The Landscape Capacity Study assessed this option as having medium to high capacity for development (SEA Objective 8). 16. Housing development following this option will help meet the local housing demand (SEA Objective 10). 17. This option is further than one kilometre from a medical centre, making access to healthcare more difficult, particularly for vulnerable social groups, such as the elderly (SEA Objective 12). 18. The area considered as part of this option includes land that is currently in use as a campsite. Development may result in a loss of local employment and tourist opportunities associated with the campsite. The rCOH Housing Note states that if this part of the site is to be developed, a replacement location for the campsite should be sought (SEA Objective 13). Distribution option 3: Focussed development to the east of the settlement

1 2 3 4 5 6 7 8 9 10 11 12 13 Clim Clim Rural Biodiv. Nat Res Waste Poll Transp Landsc Cult Her House Health Econ mini adapt Barrier +/- -- 0 0 + -- ++ ++ 0 + ++ - 0

19. This option consists of arable fields on the border of the East Wittering parish. The fields are surrounded by mature, dense trees, which could provide suitable habitat for bats. Surveys should be undertaken to determine potential presence of European Protected Species (SEA Objective 1). 20. This land considered as part of this option is categorised as Grade 2 and 3a agricultural land. Both are examples of the best and most versatile agricultural land and development would result in a permanent loss of this resource (SEA Objective 2). 21. This option is located within 400 metres of a high frequency bus stop. Easy access to modes of sustainable travel will reduce the East Wittering carbon footprint and allow access to key amenities for those living in a rural area (SEA Objectives 5, 7 and 11). 22. The southern part of the area considered as part of this option lies in Flood Zones 2 and 3, which are at highest flood risk. Flood risk in this area may be exacerbated by climate change (SEA Objective 6). 23. This option was assessed as having high capacity for development in the Landscape Capacity Study, and is assessed as having positive effects against SEA Objective 8. 24. Development following this option will contribute to meeting local housing demand (SEA Objective 10). 25. The Witterings Medical Centre is further than one kilometre from this option, making access to healthcare more difficult for those without their own transport (SEA Objective 12).

SEA of the East Wittering and Bracklesham NDP March 2016 LC-176_EWB_NDP_SEA_15_070316FG.docx

Appendix D: Reasonable Alternatives: assessment of sites

Introduction

This appendix presents the assessment of site options. These options were communicated to Lepus Consulting via the rCOH Site Assessment Report28. The assessment methodology used is the same as that presented in Chapter 4 of the Environmental Report (March 2016). These were the only reasonable alternative site options identified by the East Wittering Neighbourhood Development Plan Steering Group.

28 rCOH (2015) East Wittering and Bracklesham Neighbourhood Plan Site Assessment Report, 23rd November 2015. Received by email.

Windmill, Church Road

1 2 3 4 5 6 7 8 9 10 11 12 13 Nat Clim Clim Cult Rural Biodiv. Waste Poll Transp Landsc House Health Econ Res mini adapt Her Barrier +/- ++ 0 0 + + ++ ++ +/- + 0 + 0

1. The site consists of derelict buildings, including East Wittering Windmill, a tower mill built in 1810. The buildings have the potential to support protected species, particularly bats. The site should be surveyed for the presence of European Protected Species prior to any development taking place (SEA Objective 1). 2. Allocating this site will result in development on previously developed, non-agricultural land, thus reducing the need to develop on greenfield sites and helping to protect the best and most versatile agricultural land (SEA Objective 2). 3. Bus services and footpath links within East Wittering help to connect the settlement with the surrounding area. A high frequency bus stop (more than two buses per hour) is located within 400 metres of the site. The East Wittering local centre on Northern Crescent is within 800 metres, which is likely to result in lower dependency on personal car use, thus reducing the carbon footprint per person. This will also allowing those living in the parish to access key amenities more easily as the local centre can be accessed on foot (SEA Objectives 5 and 7). 4. The site is located in Flood Zone 1 and is therefore at low risk of flooding. Building on previously developed land can help to limit flooding as it prevents development on permeable land, which can limit surface run-off from new developments, thus surface water flooding (SEA Objective 6). 5. The site is located on previously developed land, which is currently derelict. Development at the site will result in re-use of a degraded townscape near to the centre of the parish and is likely to improve the appearance of the site through regeneration. Policy 7 and Policy 40 of the CLPKP serve to ensure that design is in keeping with the local area (SEA Objective 8). 6. East Wittering Windmill is a Grade II Listed Building situated in the southwest corner of the site. Any new development would need to consider the setting of this protected building; without design details is it difficult to determine whether the assess any positive or negative effects. It is uncertain at the time of writing whether the windmill will be retained. Potentials impacts on SEA Objective 9 are classified as uncertain. 7. Development at the site will contribute to fulfilling the local housing demand (SEA Objective 10). 8. The site is located within the settlement boundary of East Wittering, near to local services, and as such is not considered to be in a rural area (SEA Objective 11). 9. The site is within one kilometre of The Witterings Medical Centre, which is currently accepting new patients. Greenspace is also present within 600m of the site thus promoting a healthy lifestyle (SEA Objective 12).

Co-op, Stocks Lane

1 2 3 4 5 6 7 8 9 10 11 12 13 Nat Clim Clim Cult Rural Biodiv. Waste Poll Transp Landsc House Health Econ Res mini adapt Her Barrier +/- ++ 0 0 + + ++ ++ 0 + 0 + --

10. The site currently contains the Royal Oak Public House and other retail premises. At the time of writing, it is possible that the Royal Oak Public House may be demolished. The land consists of mostly bare ground and buildings. Buildings with tiled roofs, such as those on site may provide habitat for roosting bats. Surveys of the buildings should be undertaken prior to any development taking place at the site in order to determine if bats are present (SEA Objective 1). 11. The site will result in development on previously developed, non- agricultural land, thus reducing the need to develop on greenfield sites and helping to protect the best and most versatile agricultural land (SEA Objective 2). 12. Frequent bus services and footpaths link the site with the surrounding area. Having good links to the wider community and allowing easy access to key amenities reduces dependency on personal car use, thus reducing carbon footprint per person and reducing barriers to those living in rural areas (SEA Objective 5 and 11). 13. The site lies in Flood Zone 1, therefore is at low flood risk and helps to limit the proportion of developed land subject to increased flood risk due to climate change (SEA Objective 6). 14. The site has is located near to high frequency bus stops and the East Wittering local centre. This reduces the need for personal car use and promotes walking or cycling to amenities (SEA Objective 7). 15. The site is in a prominent location as it is on a busy junction near to the main local centre of East Wittering. Development will make use of previously developed land and policies in the CLPKP are expected to ensure that design of new development is in keeping with the local area (SEA Objective 8). 16. Development at the site will help contribute to fulfilling local housing demand in the area (SEA Objective 10). 17. The site is located within the settlement boundary of East Wittering, near to local services, and as such is not thought be in a rural area (SEA Objective 11). 18. The Witterings Medical Centre is within one kilometre of the site and is currently accepting new patients. Local greenspace is also within 600 metres of the development, thus promoting an active, healthy lifestyle (SEA Objective 12). 19. Demolition of The Royal Oak may result in a loss of public services which contribute to the economy and a loss of local employment opportunities. Loss of employment sites is not in line with Policy 26 of the Chichester Local Plan Key Policies 2014- 2029, which works to resist conversion of land for employment use to residential (SA Objective 13).

School Playing Field

1 2 3 4 5 6 7 8 9 10 11 12 13 Nat Clim Clim Cult Rural Biodiv. Waste Poll Transp Landsc House Health Econ Res mini adapt Her Barrier +/- + 0 0 + + ++ + 0 + ++ - 0

20. The Solent Waders and Brent Goose Strategy (2010) states that amenity grassland is an important feeding habitat for Brent Geese. The site may be used by such species using the area to feed (SEA Objective 1). The site is currently in use as the School Playing Field. Any development would help to protect best and most versatile agricultural land by reducing demand for this (SEA Objective 2). 21. The site is located to the north of the settlement boundary, near to the East Wittering local centre. The site has good links to footpaths and is within 400 metres of high frequency bus stops, promoting sustainable travel around the parish and providing access to key amenities (SEA Objective 5, 7 and 11). 22. The site is located in Flood Zone 1, being at the lowest risk of flooding. Building in an area of low flood risk limits the area of land subject to flooding and the increase in this due to climate change (SEA Objective 6). 23. The site is located in area 146 (East Wittering Northern Coastal Plain)1, which is assessed as having high to medium capacity for development in the Landscape Capacity Study (SEA Objective 8). 24. Development at the site will contribute to meeting the local housing demand (SEA Objective 10). 25. Development on the School Playing Field site will result in a loss of greenspace used by the pupils. Where possible, development on open greenspace should be avoided as this constitutes a loss of Green Infrastructure and space used for social activities. A loss of social space may have negative impacts with regards to health and wellbeing (SEA Objective 12).

1South Downs Joint Committee, ‘South Downs Integrated Landscape Character Assessment’ December 2005 Land north of Briar Avenue

1 2 3 4 5 6 7 8 9 10 11 12 13 Nat Clim Clim Cult Rural Biodiv. Waste Poll Transp Landsc House Health Econ Res mini adapt Her Barrier +/- -- 0 0 - -- -- +/- + + - + 0

26. The site currently consists of an open field with trees. The trees may support roosting bats or nesting birds and this should be investigated before development commences at the site (SEA Objective 1). 27. All land at the site is categorised as Grade 2 agricultural land, which is considered to be best and most versatile. Development at the site would result in an irreversible loss of best and most versatile agricultural land (SEA Objective 2). 28. The site is located approximately 900 metres to the north of the main East Wittering local centre and near to a low frequency bus stop. Being further than the recommended distances (Barton et al, 2010) from key amenities may result in increased dependence on personal car use and may lead to difficulty accessing services such as shops and medical centres (SEA Objective 5 and 7). 29. Almost half of the site lies in Flood Zone 3, the category most susceptible to flooding. This results in a negative sustainability performance in terms of SEA Objective 6. 30. This site is not included in the Landscape Capacity Study. Development at the site is likely to affect the visual amenity of residents in adjacent properties. Without further research and details of design, the overall impact on the landscape is unknown (SEA Objective 8). 31. The Thatched Tavern, a Grade II Listed Building, is situated approximately 200 metres south west of the site. Policies in the CLPKP are likely to ensure that design of any development at the site in in keeping with the surrounding area (SEA Objective 9). 32. Development at the site will contribute to meeting local housing demand in East Wittering (SEA Objective 10). 33. Due to the location of the site outside of the settlement boundary, the nearest local centre is further than 800 metres away, making it difficult for residents to access key amenities such as shops (SEA Objective 11). 34. The Witterings Medical Centre is located within one kilometre of the site, thus providing health services to those who need them (SEA Objective 12).

Land north of Stocks Lane

1 2 3 4 5 6 7 8 9 10 11 12 13 Nat Clim Clim Cult Rural Biodiv. Waste Poll Transp Landsc House Health Econ Res mini adapt Her Barrier +/- -- 0 0 +/- -- - + + + - + 0

35. The site is a series of open arable fields with hedgerows to the north of East Wittering. Features of arable landscapes such as hedgerows and streams can support a variety of species. Ecological surveys should be undertaken to determine potential presence of European Protected Species (SEA Objective 1). 36. Most of the site is Grade 2 agricultural land with a small proportion of Grade 3. Development on Grade 2 agricultural land would result in the loss of best and most versatile agricultural land. Grade 3 land is split into Grade 3a and 3b, although it is not known which of these is present at the site. Grade 3a is classed as best and most versatile and development. If Grade 3a is present at the site, it would be an irreversible loss of best and most versatile land (SEA Objective 2). 37. Due to the large size of the site, certain parts of the development will be nearer to amenities, whereas residents in other parts of the development will have further to travel to these. This is likely to mean that residents in the northern part of the site may rely on personal car use. The provision of sustainable modes of transport such as new cycle paths can remove the need for personal car use (SEA Objective 5). 38. A watercourse flows north to south through the centre of the site and areas around the stream are categorised as Flood Zone 3, which is at high risk of flooding. The flood risk at the site may be exacerbated by climate change (SEA Objective 6). 39. The East Wittering local centre is further than 600 metres from the centre of the site. Bus stops are present on residential estates to the south and east of the site but these are more than 400 metres from the centre of the site. This may lead to the resdients of any development relying on increased personal car use and this may create barriers to living in a rural area (SEA Objective 7 and 11). 40. The site is situated in Landscape Character Area 146 (East Wittering Northern Coastal Plain) of the Landscape Capacity Study, which was assessed as having medium to high capacity for development (SEA Objective 8). 41. Regency House Grade II Listed Building is adjacent to the site boundary. Siting and design will affect the setting of the Listed Building; policies in the CLPKP influence design to ensure development maintains local distinctiveness, which is expected to lead to development that respects the setting of this feature (SEA Objective 9). 42. Development at the site will contribute to meeting local housing demand (SEA Objective 10). 43. The Witterings Medical Centre and open accessible greenspace are present within one kilometre and 600 metres of the site respectively. Having easily accessible health facilities and outdoor space can promote a healthy lifestyle (SEA Objective 12).

Land off Wessex Avenue

1 2 3 4 5 6 7 8 9 10 11 12 13 Nat Clim Clim Cult Rural Biodiv. Waste Poll Transp Landsc House Health Econ Res mini adapt Her Barrier +/- -- 0 0 + -- + + 0 + ++ + 0

44. The site is a series of open arable fields with hedgerows to the north of East Wittering. Features of arable landscapes such as hedgerows and streams can support a variety of species. Surveys should be undertaken to determine potential presence of European Protected Species (SEA Objective 1). 45. The majority of the site is Grade 2 agricultural land with a small portion of Grade 3, although it is not known if this is Grade 3a or 3b. If the Grade 3 is classified as 3a, this too is best and most versatile. Development of the site will result in an irreversible loss of best and most versatile agricultural land (SEA Objective 2). 46. The site is within 800 metres of the East Wittering local centre and 400 metres of a high frequency bus route, thus promoting sustainable travel, decreasing personal car use and providing access to key amenities (SEA Objective 5, 7 and 11). 47. A watercourse runs north to south along the eastern boundary of the site. An area in the northeast corner of the site is categorised as Flood Zone 3, which is at high risk of flooding, and flood risk may increase over time due to the impacts of climate change (SEA Objective 6). 48. The site lies in the East Wittering Northern Coastal Plain Landscape Character Area, which is assessed as having medium to high potential for development (SEA Objective 8). 49. Development at the site will help meet local housing demand (SEA Objective 10). 50. The site is within one kilometre of The Witterings Medical Centre and 600 metres of open greenspace, promoting a healthy lifestyle and providing easy access to healthcare for those who need it (SEA Objective 12).

Land opposite Richardsons

1 2 3 4 5 6 7 8 9 10 11 12 13 Nat Clim Clim Cult Rural Biodiv. Waste Poll Transp Landsc House Health Econ Res mini adapt Her Barrier +/- -- 0 0 + + ++ + 0 + ++ - 0

51. The site is an arable field with hedgerows and trees. Hedgerows help connect habitats as well as provide habitats in their own right. The ecological value of hedgerows present should be investigated in order to determine whether loss of these would lead to a significant loss in biodiversity (SEA Objective 1). 52. The site is situated on Grade 2 agricultural land. Grade 2 agricultural land is an example of the best and most versatile and loss of such soil resource would be irreversible (SEA Objective 2). 53. The site is within 400 metres of a high frequency bus stop that connects the site with the wider area, reducing the need for personal car use, hence minimising the local carbon footprint and allowing access to key services (SEA Objective 5, 7 and 11). 54. The site is located in Flood Zone 1 and is and is less likely to flood. Any development in Flood Zone 1 helps to limit flood risk exacerbated by climate change (SEA Objective 6). 55. The site is located in an area assessed as having medium to high landscape capacity in the Landscape Capacity Study (SEA Objective 8). 56. Developing the site will help to meet housing demand in the local area (SEA Objective 10). 57. The Witterings Medical Centre is located further than one kilometre from the site, which may make access difficult for the vulnerable (SEA Objective 12).

Land at Church Farm Lane

1 2 3 4 5 6 7 8 9 10 11 12 13 Nat Clim Clim Cult Rural Biodiv. Waste Poll Transp Landsc House Health Econ Res mini adapt Her Barrier +/- -- 0 0 - + -- + +/- + -- + 0

58. The site consists of two separate plots of land. The northern field currently serves as a horse paddock with a stable block. An area of trees is present to the west of the site. The southern field consists of two dwellings and associated gardens. The buildings and woodland may provide suitable habitat for bats or birds. Surveys should be undertaken to determine potential presence of European Protected Species (SEA Objective 1). 59. Although part of the site is developed, the northern field is situated on Grade 2 agricultural land. Any development on this part of the site would result in the loss of best and most versatile agricultural land (SEA Objective 2). 60. The site is located near to an area listed as historic landfill by the Environment Agency. Documentation exists to state that the site does not overlap with an area of historic landfill2 (SEA Objective 4). 61. The site is located outside the main settlement boundary of East Wittering and the nearest bus stop is further than 400 metres away. Development at the site may result in increased personal car dependency to reach key amenities, thus increasing the carbon footprint per person and reducing the likelihood of residents using sustainable modes of travel (SEA Objective 5, 7 and 11). 62. The site lies in Flood Zone 1, thus development at this site is at the lowest risk of flooding and therefore less likely to experience potential flooding impacts associated with climate change (SEA Objective 6). 63. This site is not included in the Landscape Capacity Study. Development of the site would increase the built area around Church Farm Lane but would result in the loss of open farmland. This would result in a change to the immediate landscape, but in the absence of a landscape capacity study, the significance of this is uncertain (SEA Objective 8). 64. The Church of the Assumption of St Mary the Virgin Grade II* Listed Building is situated west of the site. Policy 40 of the CLPKP will ensure development is in keeping with local design, and in turn will reduce any adverse effect on the setting of the Listed Building (SEA Objective 9). 65. Development will contribute to the housing numbers in East Wittering (SEA Objective 10). 66. The development is within one kilometre of The Witterings Medical Centre, which has capacity for new patients (SEA Objective 12).

Martlets, Peerly Road

1 2 3 4 5 6 7 8 9 10 11 12 13 Nat Clim Clim Cult Rural Biodiv. Waste Poll Transp Landsc House Health Econ Res mini adapt Her Barrier +/- ++ 0 0 + -- ++ ++ 0 + 0 + 0

67. The site consists of a house with front and rear garden. Any long grassland at the site should be surveyed for the presence of reptiles and the roof void of the residential dwelling inspected for the presence of bats (SEA Objective 1). 68. The site will result in development on previously developed, non- agricultural land, thus reducing the need to develop on greenfield sites and helping to protect the best and most versatile

2 Personal Communication, (2015), East Wittering and Bracklesham Neighbourhood Plan Steering Group agricultural land (SEA Objective 2). 69. The site is located within 600 metres of East Wittering local centre and within 400 metres of a high frequency bus stop, thus promoting sustainable travel and reducing the carbon footprint per resident. Having a local centre or a bus stop nearby allows easy access to key services for those living in a rural area (SEA Objective 5 and 7). 70. The site is located in Flood Zone 3, which is at high risk of flooding. It is likely that the risk of flooding will be exacerbated by the predicted effects of climate change (SEA Objective 6). 71. Policies in the CLPKP are expected to ensure development at the site will be in keeping with the local area (SEA Objective 8). 72. The site will help to meet the housing demand in East Wittering and Bracklesham (SEA Objective 10). 73. The site is located within the settlement boundary of East Wittering near to local services, and as such is not considered to be in a rural area (SEA Objective 11). 74. The site is within one kilometre of a The Witterings Medical Centre and 600 metres of open accessible greenspace. This allows residents to access health facilities when necessary and promotes a healthy lifestyle (SEA Objective 12).

Cobham, Stocks Lane

1 2 3 4 5 6 7 8 9 10 11 12 13 Nat Clim Clim Cult Rural Biodiv. Waste Poll Transp Landsc House Health Econ Res mini adapt Her Barrier 0 ++ 0 0 + + ++ ++ 0 + 0 - --

75. The site is currently used for industrial purposes and development of this is not anticipated to have any impacts on biodiversity or geodiversity (SEA Objective 1). 76. The site will result in development on previously developed, non- agricultural land, thus reducing the need to develop on greenfield sites and helping to protect the best and most versatile agricultural land (SEA Objective 2). 77. The site is within 400 metres of a moderate frequency bus stop and 800 metres from East Wittering local centre. Residents of development would be within walking distance of services, which is likely to reduce the carbon footprint per person in the parish, promote sustainable transport methods and allow easy access to key services for those living in a rural area (SEA Objective 5, 7 and 11). 78. The site lies in Flood Zone 1, therefore is at low flood risk and helps to limit the proportion of developed land subject to increased flood risk due to climate change (SEA Objective 6). 79. Development will result in removal of the large industrial building currently located at the site and the construction of new residential dwellings. Residential development may add to the character and visual amenity of the area, and policies in the CLPKP serve to ensure that the design is in keeping with the local area (SEA Objective 8). 80. Development at the site will help contribute to fulfilling local housing demand (SEA Objective 10). 81. The site is located within the settlement boundary of East Wittering near to local services, and as such is not considered be in a rural area (SEA Objective 11). 82. The Witterings Medical Centre is located further than one kilometre from the site. Access to health facilities and public open space is important for a healthy lifestyle (SEA Objective 12). 83. Development at the site would result in a loss of local employment opportunities and is contrary to Policy in the CLPKP, which works to retain existing employment land (SA Objective 13).

Gees Camping

1 2 3 4 5 6 7 8 9 10 11 12 13 Nat Clim Clim Cult Rural Biodiv. Waste Poll Transp Landsc House Health Econ Res mini adapt Her Barrier +/- +/- 0 0 + + ++ + 0 + ++ - --

84. The site consists of an open field extending from a residential dwelling and garden. Buildings on the site may provide suitable roosting habitat for bats. Surveys should be undertaken prior to development at the site in order to determine the importance of the site for such species (SEA Objective 1). 85. Although part of the site is developed, the majority of the site is situated on Grade 3 agricultural land. If the Grade 3 land is classified as 3a rather than 3b, this is considered to be as best and most versatile. Development of the site may result in a loss of best and most versatile agricultural land (SEA Objective 2). 86. The site is within 400 metres of a high frequency bus stop, which could help promote sustainable travel, reduce per person carbon footprint and provide connections to the surrounding area and key amenities (SEA Objective 5, 7 and 11). 87. The site is located in Flood Zone 1 and is at the lowest risk of flooding. Any development in Flood Zone 1 helps to limit the increase in flooding from climate change (SEA Objective 6) 88. The site is assessed as having medium to high landscape capacity, as part of the Landscape Capacity Study (SEA Objective 8). 89. Development at the site will contribute to meeting local housing demand (SEA Objective 10). 90. The site is located further than one kilometre from The Witterings Medical Centre. This may limit the ability of new residents on the site to access healthcare (SEA Objective 12). 91. The site is currently in use as a campsite. Development at the site would result in a loss of local employment and tourist opportunities in the local area (SEA Objective 13).

Land west of Bracklesham Lane

1 2 3 4 5 6 7 8 9 10 11 12 13 Nat Clim Clim Cult Rural Biodiv. Waste Poll Transp Landsc House Health Econ Res mini adapt Her Barrier +/- -- 0 0 + -- ++ + 0 + ++ - 0

92. The site is a series of open arable fields with hedgerows to the north of East Wittering. Features of arable landscapes such as hedgerows and streams can support a variety of species. Ecological surveys should be undertaken in order to determine the ecological value of the site (SEA Objective 1). 93. The site is categorised as Grade 2 agricultural land, therefore development will result in a loss of best and most versatile agricultural land (SEA Objective 2). 94. The site is within 400 metres of a high frequency bus stop, providing residents with links to key amenities in the local area. This will help to reduce the carbon footprint of the area and promote sustainable modes of travel (SEA Objective 5, 7 and 11). 95. A stream borders the western edge of the site and areas of Flood Zone 3 are present along the stream, which is at high risk of flooding. Development in Flood Zone 3 is at highest flood risk. The risk may be exacerbated as a result of climate change (SEA Objective 6). 96. The Landscape Capacity Study assessed this site as having medium to high capacity for development (SEA Objective 8). 97. Housing development at the site will help meet the local housing demand (SEA Objective 10). 98. The site is located than one kilometre from a medical centre, making access to healthcare more difficult (SEA Objective 12).

Land west of Bracklesham Lane 1

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99. The site is an open field with hedgerows to the west of Bracklesham Lane. Hedgerows connect habitats and provide habitat; loss of such is likely to have negative effects on biodiversity. Surveys should be undertaken to determine the impact of development on biodiversity (SEA Objective 1). 100. The site is categorised as Grade 2 agricultural land, therefore development will result in a loss of best and most versatile agricultural land (SEA Objective 2). 101. The site is within 400 metres of a high frequency bus stop, providing residents with links to key amenities in the local area. This will help to reduce the carbon footprint in East Wittering as well as providing sustainable modes of transport to key services (SEA Objective 5, 7 and 11). 102. The majority of the site lies in Flood Zone 1, therefore is at low flood risk and helps to limit the proportion of developed land subject to increased flood risk due to climate change. Part of the site is in Flood Zone 3, which is at the highest risk of flooding (SEA Objective 6). 103. The Landscape Capacity Study assessed this site as having medium to high capacity for development (SEA Objective 8). 104. Housing development at the site will help meet the local housing demand (SEA Objective 10). 105. The site is within one kilometre of a medical centre, resulting in good access to healthcare (SEA Objective 12).

Sunlands

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106. The site is an area of land on Bracklesham Lane. The land consists of long grassland and scrub, which may support reptiles. Surveys should be undertaken prior to development to determine the value of the site for such species (SEA Objective 1). 107. The site is categorised as Grade 3 agricultural land. If the site were found to be Grade 3a, development of the site would result in the loss of best and most versatile agricultural land (SEA Objective 2). 108. A high frequency bus stop is adjacent to the site on Bracklesham Lane and will reduce the need for personal car use, hence minimising the carbon footprint per person in East Wittering and providing sustainable modes of transport (SEA Objective 5, 7 and 11). 109. The site is located in Flood Zone 1 and is at the lowest risk of flooding. Any development in Flood Zone 1 helps to limit the increase in flooding from climate change (SEA Objective 6). 110. Due to the site’s close proximity to a high frequency bus stop, personal car use is less of a necessity and amenities in the wider area are easily accessible by public transport (SEA Objective 7). 111. The site is located on the end of a row of housing. Policies in the CLPKP serve to ensure that the design of the development is in keeping with the local area (SEA Objective 8). 112. Development of the site would help contribute to meeting local housing demand (SEA Objective 10). 113. The Witterings Medical Centre is located further than one kilometre from the site, making access to healthcare difficult for the vulnerable (SEA Objective 12).

Land north of Lively Lady

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114. The site is an area of long grassland in East Wittering. Long grassland has the potential to support reptiles and should be surveyed for such prior to development (SEA Objective 1). 115. Allocation of this site would result in development on non- agricultural land, thus helping to protect the best and most versatile agricultural land (SEA Objective 2). 116. A high frequency bus stop is situated adjacent to the site. Easy access to sustainable travel reduces the need for personal car use thus the carbon footprint per person in an area (SEA Objective 5). 117. The site is located in Flood Zone 1, which is at low risk of flooding. Development in Flood Zone 1 is less likely to be impacted by increasing flood risk as a result of climate change (SEA Objective 6). 118. A high frequency bus stop next to the bus stop provides sustainable travel options to those wishing to access amenities (SEA Objective 7 and 11). 119. The site is located within the urban area of East Wittering, making use of a prominent area of the village. Design policies set out in the CLPKP serve to ensure that development is in keeping with the surrounding area and will protect local distinctiveness (SEA Objective 8). 120. Development of the site will contribute to meeting local housing demand (SEA Objective 10). 121. The site is located within the settlement boundary of East Wittering near to local services, and as such is not considered to be in a rural area (SEA Objective 11). 122. Healthcare facilities are located further than one kilometre from the site, making access difficult for the vulnerable or elderly (SEA Objective 12).

Land south of Grasmere

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123. The site currently contains mature trees and a residential dwelling. Both trees and dwellings can provide roosting habitat for bats and as such should be surveyed prior to removal and development (SEA Objective 1). 124. The site is situated on Grade 2 agricultural land, which is considered to be best and most versatile. Any development would result in the loss of the best and most versatile land (SEA Objective 2). 125. A high frequency bus stop lies within 400 metres of the site. Easily accessible sustainable travel will reduce the need for personal car use and in turn, the carbon footprint in the plan area (SEA Objective 5). 126. The site lies in Flood Zone 1, which is at low risk of flooding. Development in Flood Zone 1 is less likely to be impacted by rising flood risk caused by climate change (SEA Objective 6). 127. The high frequency bus route adjacent to the site provides easy access to sustainable travel, thus allowing easy access to amenities and the wider area (SEA Objective 7 and 11). 128. The Landscape Capacity Study assessed this site as having low to medium capacity for development (SEA Objective 8). 129. Regency House Grade II Listed Building lies to the south of the site. Inappropriate development may impact on the setting of the building but policies set out in the CLPKP will control development to ensure the setting of the listed building is preserved and enhanced (SEA Objective 9). 130. Development at the site will help to meet the local housing demand (SEA Objective 10). 131. The site is further than one kilometre from The Witterings Medical Centre. This may mean that residents of the site find it difficult to access healthcare facilities (SEA Objective 12).

Land north of Grasmere

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132. The site is currently serving a purpose as a horse paddock and is not thought that development would have an impact on biodiversity or geodiversity (SEA Objective 1). 133. The site is situated on Grade 2 agricultural land. Any development at the site would result in the loss of the best and most versatile land (SEA Objective 2). 134. A high frequency bus stop lies adjacent to the site. Accessible sustainable transport routes are likely to reduce the need for personal car use, hence reducing the carbon footprint of the parish and providing sustainable travel to those wishing to access key amenities (SEA Objective 5, 7 and 11). 135. The site lies in Flood Zone 1, which is at low risk of flooding. Development in Flood Zone 1 is less likely to be impacted by rising flood risk caused by climate change (SEA Objective 6). 136. The Landscape Capacity Study assessed this site as having low to medium capacity for development (SEA Objective 8). 137. Regency House Grade II Listed Building lies to the north of the site. Inappropriate development may impact on the setting of the building but policies set out in the CLPKP will control development to ensure the setting of the listed building is preserved and enhanced (SEA Objective 9). 138. Development at the site will help to meet the local housing demand (SEA Objective 10). 139. The site is further than one kilometre from The Witterings Medical Centre. This may mean that residents of the site find it difficult to access healthcare facilities (SEA Objective 12).

Land south of Clappers Lane

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140. The site consists of arable fields on the border of the East Wittering parish. The site is surrounded by mature, dense trees, which could provide suitable habitat for bats. Surveys should be undertaken to determine potential presence of European Protected Species (SEA Objective 1). 141. The site is categorised as being Grade 2 and 3a agricultural land. Both are examples of the best and most versatile agricultural land and development would result in a permanent loss of this resource (SEA Objective 2). 142. The site is located within 400 metres of a high frequency bus stop. Easy access to modes of sustainable travel will both reduce the East Wittering carbon footprint and allow access to key amenities for those living in a rural area (SEA Objectives 5, 7 and 11). 143. The southern part of the site lies in Flood Zones 2 and 3. These areas are those of the highest flood risk and this may be exacerbated by climate change (SEA Objective 6). 144. The site was assessed as having high capacity for development as part of the Landscape Capacity Study, and is assessed as having positive effects against SEA Objective 8. 145. Development at the site will contribute to meeting local housing demand (SEA Objective 10). 146. The Witterings Medical Centre is further than one kilometre from the site, making access to health amenities difficult for the elderly or vulnerable (SEA Objective 12).

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1 Bath Street Cheltenham GL50 1YE

T: 01242 525222

E: [email protected]

www.lepusconsulting.com

CHELTENHAM

Lepus Consulting t: 01242 525222 1 Bath Street w: www.lepusconsulting.com Cheltenham e: [email protected] Gloucestershire GL50 1YE