EAST WITTERING & BRACKLESHAM PARISH COUNCIL Ref. No: 21/01090/EIA. Land At Stubcroft Farm Wessex Avenue East Wittering West Sussex PO20 8NP. EIA Screening Opinion in response to development of up to 320 no. residential dwellings along with public open space and new means of vehicular access onto Church Road. The Parish Council OBJECT to the developer assertion that a full Environmental Impact Assessment (EIA) is not required for this site and request that before a planning application is submitted a full EIA is completed, addressing the following relevant factors: 1. The EIA process is intended to be cumulative and other relevant developments should therefore be considered when assessing any impacts. On this basis the EIA should also incorporate the relevant additional sites at 18/00753/OUT Redevelopment of the former South Downs Holiday Park, Bracklesham Lane, Bracklesham Bay, Chichester West Sussex (under construction) 20/03125/OUT Land South of Clappers Lane, Earnley, West Sussex 20/2491/OUT: Land to the West of Church Road, East Wittering, West Sussex Land Behind Middleton Close, Bracklesham Lane, Bracklesham, West Sussex (application submitted 28/4/2021, not yet validated by planning authority) These should be considered in the round and an EIA of the cumulative effects of all developments, yielding nearly 650 homes should be completed. Planning Inspectorate Advice Note 17, Cumulative Effects Assessment, Aug. 19 para. 1.2: “Schedule 3 paragraph 1(b) of the EIA Regulations, which refers to the selection criteria for screening Schedule 2 development, states that ‘the characteristics of development must be considered with particular regard to... ...(b) the cumulation with other existing development and/or approved development’. Schedule 3 paragraph 3(g), which relates to the ‘Types and characteristics of the potential impact’ also requires ‘(g) the cumulation of the impact with the impact of other existing and/or approved development’ to be taken into account. The EIA Regulations expand the definition set out in Annex III of the Directive, which simply refers to ‘the cumulation with other projects’. Para 1.5: NPS EN-1 paragraph 4.2.6 goes on to state that the Secretary of State should consider how the “accumulation of, and interrelationship between effects might affect the environment, economy or community as a whole, even though they may be acceptable when considered on an individual basis with mitigation measures in place.” Bracklesham Barn, Beech Avenue, Bracklesham Bay, East Wittering, PO20 8HU Telephone: 01243 673588. [email protected] VAT reg. no. 135837105 2. The site is a candidate site (C63) under the Solent Wader and Brent Goose Strategy (2020). The landowner has considerable scope to skew survey data and results by undertaking land management practices that create adverse conditions for target species – for example by ploughing the fields or leaving stubble in the fields for the duration of the survey period. We have anecdotal evidence from residents that protected species have used the site in the past and are confident that they would again if suitable land management practices promoting grassland and grazing were adopted. We therefore think that the following policies in the Solent Wader and Brent Goose Strategy (2020) are relevant and should apply: W&BG Policy 1: Planning Authorities will recognise the importance of the wading bird and brent goose sites outside of the statutory designated areas in the Solent and will use the Solent Waders and Brent Goose Strategy as a material consideration in the preparation of development plans and in the determination of planning applications. W&GB Policy 2: Planning Authorities will actively encourage the enhancement of existing and potential brent goose and wader sites, and where appropriate the creation of new sites through development control and forward planning functions. W&GB Policy 5: Development proposals which could affect important wading bird and brent goose sites outside of the statutory designated areas need to demonstrate levels of impact, alone and in combination with other proposals. Where a negative impact upon an important wading bird or brent goose site cannot be avoided or satisfactorily mitigated, and the tests of the Habitats Regulations are met as necessary, appropriate compensatory measures will be sought, as per the SW&BGS Guidance on Mitigation and Offsetting Requirements 3. The impact upon road traffic needs to be fully understood and needs to assess the cumulative impacts of any additional sites already in development or awaiting determination. The cumulative effects of over 650 new properties and the additional traffic generated on the Air Quality Management Area (AQMA) at Stockbridge need to be fully modelled and understood. His must include ascertaining if there are sufficient mitigation measures attached to the development that can be delivered within the limited powers of the planning authority. A full methodology and explanation of the developer’s traffic modelling information should have been included within the application documents so that their basis can be assessed. The nuisance impact on the wider area of construction noise, dust, heavy goods vehicles and construction traffic from cumulative developments is potentially very serious and has to be considered as a whole to provide a complete picture of the impact upon the environment. Information taken from DEFRA website: The 2008 Ambient Air Quality Directive sets legally binding limits for concentrations in outdoor air of major air pollutants that affect public health such as particulate matter (PM10 and PM2.5) and nitrogen dioxide (NO2). The UK also has national emission reduction commitments for overall UK emissions of 5 damaging air pollutants: fine particulate matter (PM2.5) ammonia (NH3) nitrogen oxides (NOx) sulphur dioxide (SO2) non-methane volatile organic compounds (NMVOCs) …. Whether air quality is relevant to a planning decision will depend on the proposed development and its location. Concerns could arise if the development is likely to have an adverse effect on air quality in areas where it is already known to be poor, particularly if it could affect the implementation of air quality strategies and action plans and/or breach legal obligations (including those relating to the conservation of habitats and species)….” …Considerations that may be relevant to determining a planning application include whether the development would: Lead to changes (including any potential reductions) in vehicle-related emissions in the immediate vicinity of the proposed development or further afield. This could be through the provision of electric vehicle charging infrastructure; altering the level of traffic congestion; significantly changing traffic volumes, vehicle speeds or both; or significantly altering the traffic composition on local roads. Other matters to consider include whether the proposal involves the development of a bus station, coach or lorry park; could add to turnover in a large car park; or involve construction sites that would generate large Heavy Goods Vehicle flows over a period of a year or more; Expose people to harmful concentrations of air pollutants, including dust. This could be by building new homes, schools, workplaces or other development in places with poor air quality: Give rise to potentially unacceptable impacts (such as dust) during construction for nearby sensitive locations; Have a potential adverse effect on biodiversity, especially where it would affect sites designated for their biodiversity value. 4. HELAA (Housing and Employment Land Availability Assessment) documents are being used to support the development, indicating that the site is suitable for sustainable development. Until November 2020 this site was discounted due to unacceptable risks of flooding due to tidal inundation caused by sea level rise. There is still dispute about the revised version of the HELAA map (March 2021) and whether the site is to be regarded as defended in perpetuity and therefore safe from future climate change risks. The current Pagham to East Head Coastal Defence Strategy (2010) states that the policy for the East Wittering frontage is to hold the line, with the caveat that: “Defences would be raised over time to account for the risks from rising sea levels over the next 100 years. The national funding priority is very low for this frontage. There is very little chance within the foreseeable future of securing national funding for a scheme to renew the defences. Funding from public and private sources will need to be explored. If this proves unsuccessful, Chichester District Council will need to develop plans involving potentially affected householders that describe what will be done as the defences fail. While funding is sought to undertake works to renew defences maintenance should continue until their deterioration makes this no longer possible.” Given that the site cannot be demonstrated as protected or safe from future tidal inundation, the EIA should consider the future environmental impacts of having to abandon large numbers of houses to the sea, what the clean-up costs of this would be and the effects this could have upon the protected waters of the Solent. 5. Surface Water drainage and flood risk for the site need more detailed modelling to understand the impact that it will have upon local habitats. The current CDC Strategic Flood Risk Assessment (SFRA) is in the process of re-evaluation by the Environment Agency (EA) to assess the flood risk across land that is drained by the ditch network adjacent to Coney Six in East Wittering. This land includes much of the proposed site. The issues concerned with the outfall at Coney Six and the risk of tide locking which will increase as sea levels rise have not yet been adequately modelled. In addition to this the EA are studying the flow rates through the ditch network which has very shallow gradients and is restricted by the vegetation in the ditches. The network could become overwhelmed during long wet periods thus causing local flooding and salt-water inundation, which needs to be modelled for its potential impact upon the local environment.