Strategic Environmental Assessment of the Pagham Neighbourhood Plan. SEA of Reasonable Alternatives

Transcription

1 Strategic Environmental Assessment of the Pagham Neighbourhood Plan SEA of Reasonable Alternatives July 2015

2 !!!! Strategic Environmental Assessment of the Pagham Neighbourhood Plan Reasonable Alternatives!!! LC-122 Client Report Title Status Document Control Box Arun District Council Strategic Environmental Assessment of the Pagham Neighbourhood Plan: Reasonable Alternatives Final Filename LC-122 Reasonable_alternatives_2_260515SS.docx Date July 2015 Author Sarah Smith, Environmental Consultant, Lepus Consulting Approved Neil Davidson, Managing Director, Lepus Consulting!!

3 SEA of Alternatives for the PNP July 2015 LC-122 Reasonable_alternatives_5_020915SS.docx Contents 1 Introduction Introduction Strategic Environmental Assessment SEA process to date Reasonable alternatives Methodology Best Practice Guidance Updates to scoping SEA framework Assessment of alternatives Assessment Results Mitigation suggestions Conclusion Best performing options Barriers to assessment Next stages Appendix A: Update to scoping Appendix B: SEA Framework Appendix C: Assessment Protocol Appendix D: Plans, Policies and Programmes Appendix E: Photos from site visits Lepus Consulting for Arun District Council i

4 SEA of Alternatives for the PNP July 2015 LC-122 Reasonable_alternatives_5_020915SS.docx Tables 1.1 Reasonable alternatives identified for all policies in the PNP 2.1 Key to the matrix assessment 3.1 Summary matrix of reasonable alternatives SEA assessment results A.1 Pagham bus services A.2 SEA framework from the 2014 SEA Report and relevant SEA topics B.1 Objectives from the updated SEA framework that are relevant to the SEA topics Acronyms ADC ANOGS DCLG GI LNR NPPF ODPM PPC PPG PNP SEA SPA SSSI Arun District Council Accessible Natural Open Green Spaces Department for Communities and Local Government Green Infrastructure Local Nature Reserve National Planning Policy Framework Office of the Deputy Prime Minister Pagham Parish Council Planning Practice Guidance Pagham Neighbourhood Plan Strategic Environmental Assessment Special Protection Area Site of Special Scientific Interest Lepus Consulting for Arun District Council ii

5 SEA of Alternatives for the PNP July 2015 LC-122 Reasonable_alternatives_5_020915SS.docx 1 Introduction 1.1 Introduction Lepus Consulting is conducting the Strategic Environmental Assessment (SEA) of the Pagham Neighbourhood Plan (PNP), on behalf of Arun District Council (ADC) This report presents an assessment of the reasonable alternatives for the PNP, otherwise known as options. Reasonable alternatives constitute the range of policies and sites identified by the PNP group and ADC as having potential to be included in the plan. This includes a range of potential policies as well as a range of sites that could be allocated for development. Examples of what may be considered reasonable include sites and policies that; Must be compatible with the adopted Local Plan; Must be possible considering current land uses on and around the site; and Must not pose unreasonable risk of harm to the existing residents, economy and environment. 1.2 Strategic Environmental Assessment The basis for Strategic Environmental Assessment legislation is European Directive 2001/42/EC and was transposed into English law by the Environmental Assessment of Plans and Programmes Regulations 2004, or SEA Regulations. Detailed guidance of these regulations can be found in the Government publication A Practical Guide to the Strategic Environmental Assessment Directive (ODPM, 2005).! Under the requirements of the European Union Directive 2001/42/EC and Environmental Assessment of Plans and Programmes Regulations (2004), certain types of plans that set the framework for the consent of future development projects, must be subject to an environmental assessment.! The 2008 Planning Act requires plan-making bodies to comply with the SEA Directive by screening the plan s potential effects on the environment.! 1.3 SEA process to date Pagham parish, in its entirety, was designated as a neighbourhood plan area in December Pagham Parish Council (PPC) has led the planmaking process. The plan intends to set out policies to manage development in the area, as well as allocation of specific sites for development. Lepus Consulting for Arun District Council 1

6 SEA of Alternatives for the PNP July 2015 LC-122 Reasonable_alternatives_5_020915SS.docx The PPC prepared the following documents, which were submitted to Arun District Council in September 2014: Consultation Statement; Basic Conditions Statement; Habitat Regulations Assessment; Strategic Environmental Assessment; and The Pagham Parish Neighbourhood Plan On receipt of these documents, ADC advised that the PNP was not taken forward to the examination stage. This was due to a number of factors, including the fact that alternative options were unclear and were not considered equally. There were also concerns that the PNP needed to consider further mitigation measures, particularly in relation to the impacts of visitor pressure on nearby European protected sites, including Pagham Harbour SPA and Ramsar Following this, ADC and PPC instructed Lepus Consulting to review the SEA, including updates to the Scoping Report, a review of the SEA and suggestions of any changes to policy wording to increase the environmental sustainability of the plan In revising the Scoping Report, Lepus Consulting felt it necessary to review the SEA framework and objectives, in order to produce a robust environmental assessment of the plan. The assessments in this document are based on the updated framework and draw on the most up to date evidence base available, as explained in Chapter Reasonable alternatives The Pagham Neighbourhood Plan was submitted to Arun District Council in September 2014 and subject to consultation. Arun District Council recommended that the PNP did not continue through to Independent Examination due to representations received at this stage. Key representations included that from Natural England, Barton Wilmore on behalf of Taylor Wimpey and Aspect Ecology on behalf of Barton Wilmore. These representations suggested that implications of the plan on Pagham Harbour had not been adequately considered in that Natural England suggested too much emphasis was put on ANOGS as mitigation. In addition, concerns were raised that alternative options for site allocations had not been considered to the same degree as the preferred options. Lepus Consulting for Arun District Council 2

7 SEA of Alternatives for the PNP July 2015 LC-122 Reasonable_alternatives_5_020915SS.docx This document seeks to address these comments by supporting a return to the alternatives stage of plan making. PPC have identified all reasonable alternatives for housing site allocations, as presented in Table 1.1. Identification of options was carried out jointly between PPC and ADC. This document does not identify additional options; rather it assesses all options for each policy of the plan, some of which were not previously subject to SEA (i.e. alternative options for Policy 2). This report will be reviewed by the PPC and should be used to review the plan and its current preferred options A list of all reasonable alternatives identified is presented in Table 1.1. Each of these alternatives has been subject to the SEA process, the results of which are presented in Chapter 3 of this report The location of site allocation options for Policy 2 are shown in Figures 1.1 to 1.4. Table 1.1: Reasonable alternatives identified for all policies in the PNP. Policies taken from Pagham Parish Council (2014) Pagham Neighbourhood Plan , September 2014 and Pagham Parish Council (2014) Pagham Neighbourhood Plan : Strategic Environmental Assessment. Reasonable alternatives for Policy 2 were communicated directly from the Pagham Neighbourhood Plan Steering Group. Policy reference Description Policy 1: A Spatial Plan for the Parish Policy 1a The Neighbourhood Plan directs development proposals within the Built Up Area Boundary, as shown on the Proposals Map, provided they accord with other provisions of the Neighbourhood Plan and development plan. Development proposals outside of the Built Up Area Boundary will be required to conform to development plan policy in respect of the control of development in the countryside. This policy includes a review of the boundary using the evidence of the PNP Site Assessments Report and the following criteria: 1. Proximity to the Pagham Harbour Special Protection Area beyond the designated 400m buffer zone (in accordance with saved Policy AREA13 of the 2003 Local Plan and pursuant to NPPF para 118) 2. Flood risk Flood Zone 1 only (in accordance with saved Policy GEN11 and pursuant to NPPF para 100) 3. Relative landscape sensitivity to development medium or above (in accordance with saved Policy GEN7 and pursuant to NPPF para 110) 4. Proximity to existing village services site boundary in close proximity to Pagham Road village services (in accordance with saved Policy GEN7 and pursuant to NPPF para 58) Lepus Consulting for Arun District Council 3

8 SEA of Alternatives for the PNP July 2015 LC-122 Reasonable_alternatives_5_020915SS.docx Policy 1b This alternative would involve an alternative spatial options, derived from reviewing the development boundary using criteria I and II above Policy 2: Housing Site Allocations Site 125 Site P15 Site 117 Site 31 Site P20 Site 69 Orchard Land South of Laurel Drive Including Orchard Land South of Laurel Drive Excluding Orchard Land at Morrells Farm Also known as BREQ or Land North West of Chalcraft Lane North of Hook Lane Land West of Pagham Road Land at Sefter Road Also referred to as the Taylor Wimpey/Barton Wilmore site Pinecroft Stables Land at 251 Pagham Road and North of Summer Lane (also referred to as Land South of Inglenook Hotel) This part of Site 69 that is owned by Orchard (developer). Also referred to as Land at rear of 251 Pagham Road Referred to in the Plan as Land North of Summer Lane. This site is an extension of Site 69 to include the field between Summer Lane and Laurel Drive. Note that this field is also part of Site 117. Referred to in the Plan as Land North of Summer Lane. Also referred to as the Hanbury (Langmeads) site. This site is an extension of Site 69 to include the field between Summer Lane and Laurel Drive as above. This site excludes the area of land owned by Orchard, to the west of the Inglenook Hotel. Policy 3: Land at Osborne Refrigeration (Site 27) Site 27 as a reserve site: A proposal for a mixed-use scheme of employment and housing development on land at Osborne Refrigeration, Sefter Road, as shown on the Proposals Map, has been considered in depth. However there are the reasons why this proposal has not been brought forward at this time: Policy 3a 1. Over development in Pagham there is an overwhelming desire in Pagham to keep the numbers as close to 100 as possible (Community Survey 2013). 2. The pressure on the Parish to restrict housing numbers because of the onerous restrictions placed upon it because of the SHLAA, RAMSAR site and nature reserves. This means that however attractive that small site may be, its inclusion would provide unnecessary and difficult additional complexities in trying to justify its inclusion. 3. Planning for the site is sketchy and more of a wish list at present so it is sensible to omit the site from the NP and Lepus Consulting for Arun District Council 4

9 SEA of Alternatives for the PNP July 2015 LC-122 Reasonable_alternatives_5_020915SS.docx consider it in isolation in the future as a windfall site. The detailed consideration of this scheme was as follows: i. the employment development scheme comprises at least 0.5 hectares for small B1 business units, to be completed and made available for occupation before the occupation of the final dwelling; and ii. the housing development scheme comprises: a. a mix of 2 and 3 bed bungalows and houses within the Built Up Area Boundary only; b. a significant landscape buffer on the southern and western sides of the remaining land within the site boundary; and c. makes an appropriate financial contribution to the Accessible Natural Open Green Space of Policy 2 Proposals that will lead to the loss of existing employment land within the site boundary or proposals to place any additional restrictions on the use and occupation of the existing employment use as a result of the adjoining housing allocation will be resisted. Provision must be made towards access management measures designed to mitigate recreational disturbance to the features of the Pagham Harbour SPA. The planning application must include a flood risk assessment to demonstrate how the scheme will not increase pluvial or fluvial flood risk on any adjoining land, to the satisfaction of the local planning authority and the Environment Agency. Allocate Site 27 for mixed-use development: The Neighbourhood Plan allocates Land at Osborne Refrigeration, Sefter Road, as shown on the Proposals Map, for: I. housing development of up to 35 dwellings, comprising a mix of 2,3 and bed bungalows and houses, to be delivered in the period 2019+, provided the scheme: Policy 3b* a. comprises development within the Built Up Area Boundary only and a significant landscape buffer on the remaining land within the site boundary; and b. makes an appropriate financial contribution to Accessible Green Space for Recreation. II. employment development comprising at least 0.5 hectares for small B1 business units, to be completed before the occupation of the final dwelling. The Neighbourhood Plan will resist development proposals that will lead to the loss of existing employment land within the site boundary and it will resist proposals to place any additional restrictions on the use and occupation of the existing employment use as a result of the adjoining housing allocation. Lepus Consulting for Arun District Council 5

10 SEA of Alternatives for the PNP July 2015 LC-122 Reasonable_alternatives_5_020915SS.docx Policy 3c No policy Policy 4: Housing Design Policy 4a The Neighbourhood Plan requires the scale, density, massing, height, landscape design, layout and materials of all development proposals, including alterations to existing buildings, to reflect and enhance the architectural and historic character and scale of the surrounding buildings and landscape, as defined in the adopted Pagham Village Design Statement (VDS). Planning applications must include a flood risk assessment to demonstrate how a scheme will not increase pluvial or fluvial flood risk on any adjoining land, to the satisfaction of the local planning authority and the Environment Agency. Policy 4b No policy Policy 5: Open Spaces The Neighbourhood Plan designates the following locations as Local Green Spaces, as shown on the Proposals Map, and will resist proposals for any development on the land: Policy 5a Pagham Cricket Club, Nyetimber Lane The Football Ground, Nyetimber Lane The Green Sussex Drive /Church Way The Paddock Sandy Road and adjacent land Stables and land adjacent to Mill Farm Drive The Neighbourhood Plan will also resist proposals for development on any open space listed in Appendix A of the adopted Pagham Village Design Statement unless the development is ancillary to its use as an open space. Green Infrastructure provision is a key part of mitigating any impacts on the Pagham Harbour SPA and Ramsar site and as such all opportunities should be made to encourage the provision of new open space and linkages to and from them. In the instance that this cannot be provided as part of a scheme, contributions will be sought. Policy 5b No policy Policy 6: Employment & Enterprise Policy 6a The Neighbourhood Plan will protect existing employment and business uses from a change of use, unless it can be demonstrated their continued use is no longer viable. The Neighbourhood Plan will support proposals to expand existing employment uses and new opportunities, provided their impact on flood risk, local amenity, traffic landscape and the Pagham Harbour Special Protection Area can be satisfactorily mitigated Lepus Consulting for Arun District Council 6

11 SEA of Alternatives for the PNP July 2015 LC-122 Reasonable_alternatives_5_020915SS.docx Policy 6b No policy Policy 7: Local Shops Policy 7a The Neighbourhood Plan will resist proposals to change the use of existing shops, as shown on the Proposals Map, unless it can be demonstrated their continued use is no longer viable. Policy 7b No policy Policy 8: Tourism Development Policy 8a The Neighbourhood Plan will strongly support proposals to broaden the range of attractions for visitors and residents. Initiatives seeking to increase the number and range of holiday accommodations available across the parish will be encouraged. Policy 8b No policy Policy 9: Education The Neighbourhood Plan will support proposals for new educational uses, provided they: Policy 9a are located within or immediately adjoining the Built Up Area Boundary, as shown on the Proposals Map and are closer to the geographic centre of Pagham parish than the existing uses; are accessible to the local community by foot, cycle and car; and are part of a larger, integrated community facility comprising local leisure and recreation facilities for the benefit of the whole community. Proposals that depend upon major housing development that are outside the Built Up Area Boundary as defined in Policy 1 for the provision of land and/or financial contributions will not be supported. Policy 9b No policy Policy 10: Agricultural Land Policy 10a The Neighbourhood Plan will support proposals that ensure the continued efficient use of agricultural land, encouraging appropriate developments thereon that maximise its use for the provision of sustainable energy and horticultural food production, provided: i. they are located away from the immediate built up area, on poorer grade land and are sympathetically landscaped to ensure that open vistas are retained and Lepus Consulting for Arun District Council 7

12 SEA of Alternatives for the PNP July 2015 LC-122 Reasonable_alternatives_5_020915SS.docx enhanced to the west of the Pagham Road; ii. that any ecological or environmental impact of any such development on the green infrastructure is minimised, including, but not limited to, fertilisers, noise pollution, light pollution and traffic movements; iii. that the highest quality and most versatile agricultural land which is outside of immediate flood zones and closest to the built up boundary is retained and protected for agricultural use and production and soil conservation; iv. there is no degradation in biodiversity value or in the integrity of the strategic gap; and v. they help deliver new green infrastructure that is relevant to the rural context, including, but not limited to, the use of farmland, woodland, wetlands or other features to provide such services as flood protection, carbon storage, water purification, bio-digester/power generation or geothermal heat exchangers Planning applications must include a flood risk assessment to demonstrate how a scheme will not increase pluvial or fluvial flood risk on any adjoining land, to the satisfaction of the local planning authority and the Environment Agency. Policy 10b No policy *Description taken from Pagham Parish Council (2014) Pagham Neighbourhood Plan : Pre- Submission Plan, February 2014 Lepus Consulting for Arun District Council 8

13 SEA of Alternatives for the PNP July 2015 LC-122 Reasonable_alternatives_5_020915SS.docx Site 69 Site P20 Site 117 Site 31 Site P15 Site 125 Figure 1.1: Reasonable alternatives for Policy 2, showing Site 69 and Site 117 separately Lepus Consulting for Arun District Council 9

14 Site P15 Site 125 SEA of Alternatives for the PNP July 2015 LC-122 Reasonable_alternatives_5_020915SS.docx Orchard Site P20 Orchard Site 117 Site P20 Site 31 Site 117 Site P15 Site 31 Site Site 125 P15 Site 125 Site 69, Part 117, Including Orchard Site P20 Site 117 Site 31 Site P15 Site 125 Figure 1.2: Location of Orchard Site 69, Part 117, Including Orchard Site P20 Site Land 69, South Part 117, of Laurel Including Drive inc. Orchard Orchard Site 117 Site P20 Site 31 Site 117 Site Site P15 31 Site Site 125 P15 Site 125 Figure 1.3: Location of Land South of Laurel Drive, including Orchard Lepus Consulting for Arun District Council 10

15 Site P15 Site 125 SEA of Alternatives for the PNP July 2015 LC-122 Reasonable_alternatives_5_020915SS.docx Site 69, Part 117, Excluding Orchard (A) Site Site 69, P20 Land South Part 117, of Laurel Excluding Drive ex. Orchard Orchard (A) Site Site P Site 31 Site 117 Site Site 31 P15 Site Site P Site 125 Figure 1.4: Location of Land South of Laurel Drive, excluding Orchard Lepus Consulting for Arun District Council 11

16 SEA of Alternatives for the PNP July 2015 LC-122 Reasonable_alternatives_5_020915SS.docx 2 Methodology 2.1 Best Practice Guidance The approach for carrying out the SEA of the NP is based on current best practice and the following guidance, as presented in Box 1. Box 1: Best Practice Guidance for SEA National Planning Policy Framework (NPPF) (2012) Planning Practice Guidance (PPG) (web-based guidance to accompany the NPPF): Department for Communities and Local Government (DCLG; 2013) National Planning Practice Guidance - Strategic environmental assessment and sustainability appraisal; Office of the Deputy Prime Minister (2005): A Practical Guide to the SEA Directive. 2.2 Updates to scoping Lepus Consulting was instructed to review and update the SEA Scoping Report. The current scoping report for the Pagham Neighbourhood Plan is integrated with the 2013 State of the Parish Report 1, prepared by Pagham Parish Council (PPC). This included identifying additional plans, policies and programmes that are relevant to the plan, as well as collecting any additional baseline information. These were used to provide a baseline against which the reasonable alternatives were assessed and provide evidence for assessment results. A full record of updates to scoping is provided in Appendix A. 2.3 SEA framework Updates to scoping included a review of the current SEA framework. The full, updated SEA Framework for the NP is presented in Appendix B. This has been updated from the framework presented in the 2013 Scoping Report 2. 1 Pagham Parish Council (2013) Pagham Neighbourhood Plan: State of the Parish Report & Strategic Environmental Assessment Scoping Report 2 Pagham Parish Council (2013) Pagham Neighbourhood Plan: State of the Parish Report & Strategic Environmental Assessment Scoping Report Lepus Consulting for Arun District Council 12

17 SEA of Alternatives for the PNP July 2015 LC-122 Reasonable_alternatives_5_020915SS.docx The SEA Framework provides a way in which environmental effects can be described, analysed and compared. The SEA Framework consists of SEA objectives, which, where practicable, may be measurable using indicators. SEA objectives and indicators can be revised as further baseline information is collected and sustainability issues and challenges are identified, and are used in monitoring the implementation of the NP The purpose of the SEA objectives is to provide a way of ensuring the proposed NDP policies consider the needs of the Pagham parish in terms of their environmental effects. The SEA objectives have drawn on the baseline information, the key issues and other plans and programmes of particular interest discussed in the Scoping Report 3 and the update to this, as presented in Appendix A. It should be noted that the ordering of the SEA objectives does not infer any prioritisation Lepus Consulting also devised an Assessment Protocol, which acts as a guide as to when a policy should be assessed as +, ++, 0, - or - -. This is derived from the SEA framework and has been included in Appendix C. 2.4 Assessment of alternatives The assessments presented in this document were subject to High Level Assessment, which appraises all options, sites or policies using the SEA Framework of objectives and decision-making criteria. For site allocations (Policy 2), mapped information, derived from constraint maps, was used to provide a finer grain assessment of the option The PNP was assessed through an SEA Framework of objectives, decision-making criteria and indicators. The assessment of the NP was undertaken using a combination of empirical evidence, and to a lesser extent professional judgement. The options for each policy were assessed against each SEA Objective The output of this assessment is a single-line matrix denoting whether or not options and/or policies perform favourably against the SEA Objectives. A written commentary accompanies the matrix to provide reasoning behind the assessment results. Each option was assessed against every objective of the updated SEA framework, as presented in Appendix B 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. The commentary is then used to interpret the matrix findings. Table 2.1 shows the key to identifying whether the effects of an option are positive, adverse or uncertain. 3 Pagham Parish Council (2013) Pagham Neighbourhood Plan: State of the Parish Report & Strategic Environmental Assessment Scoping Report Lepus Consulting for Arun District Council 13

18 SEA of Alternatives for the PNP July 2015 LC-122 Reasonable_alternatives_5_020915SS.docx Table 2.1: 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 +/- 2.5 Site visits Site visits were undertaken by Lepus Consulting staff, accompanied by members of the PNP group, on Monday 13 th July. Each of the reasonable alternative sites were visited in turn and members of the PNP group explained local concerns regarding each site. Site visits were intended for Lepus Consulting to get a feel for the area and first hand experience of each site. The visits did not constitute detailed surveys of ecology, landscape or geology etc. Photos were taken during the site visits, which are presented in Appendix E. Lepus Consulting for Arun District Council 14

19 SEA of Alternatives for the PNP July 2015 LC-122 Reasonable_alternatives_5_020915SS.docx 3 Assessment Results This chapter presents the results of SEA assessments of all reasonable alternatives considered in the PNP. Please note that the assessment below has been compiled using the precautionary principle and is based on the best available information. Table 3.1 presents summary matrices of results for all policies. This has been included to allow easy comparison between policies The only alternatives identified to the a option for policies 4 to 10 are to not have a policy. In all cases, the absence of a policy is unlikely to lead to a negative effect in itself. These policies represent the case if the plan were not in place, which would lead to little change, as policies from the 2014 Arun Local Plan would apply. As such, implications of not having any one of these policies are likely to be negligible It is possible that some policies may influence the sustainability of others. For example, Policy 4, Housing Design may contribute towards mitigating any negative effects of Policy 2 on historic buildings, as sensitive design is required. However, at this stage of plan making all policies are recognised as alternatives and will not necessarily be taken through to the next stage of plan making, thus may not influence the environmental effects of the final plan. For this reason, each option has been considered in isolation at this stage of assessment. Table 3.1: Summary matrix of reasonable alternatives SEA assessment results SEA Objectives Option Historic Environ Biodiversity and geodiversity Climate change Transport and traffic Environmen quality Healthy living Landscape Material assets Policy 1: A Spatial Plan for the Parish Policy 1a Policy 1b Policy 2: Housing Site Allocations Site /- +/ /- Site P15 +/- +/ /- Site 117 +/ /- -- +/- Site / / /- Site P20 0 +/- +/- - +/ /- Site / / /- Orchard 0 +/ /- Land South of Laurel Drive 0 +/- +/- + +/ /- Lepus Consulting for Arun District Council 15

20 SEA of Alternatives for the PNP July 2015 LC-122 Reasonable_alternatives_5_020915SS.docx (including Orchard) Land South of Laurel Drive (excluding Orchard) 0 +/- +/- + +/ /- Policy 3: Land at Osborne Refrigeration, Sefter Road Policy 3a Policy 3b Policy 3c Policy 4: Housing Design Policy 4a Policy 4b Policy 5: Open Spaces Policy 5a Policy 5b Policy 6: Employment & Enterprise Policy 6a Policy 6b Policy 7: Local Shops Policy 7a Policy 7b Policy 8: Tourism Development Policy 8a 0 +/- 0 +/- +/ Policy 8b Policy 9: Education Policy 9a /- ++ Policy 9b Policy 10: Agricultural Land Policy 10a Policy 10b Lepus Consulting for Arun District Council 16

21 SEA of Alternatives for the PNP July 2015 LC-122 Reasonable_alternatives_5_020915SS.docx Policy 1: A Spatial Plan for the Parish SEA Objectives Policy 1a Policy 1b In restricting development to outside the designated 400m buffer zone of Pagham Harbour Special Protection Area (SPA), this policy discourages development in or adjacent to this internationally designated site. This reduces impacts associated with immediate vicinity to development, such as the likelihood of urban edge effects, such as litter and nest predation. This policy may contribute to reducing additional recreational pressure from new residents as other parks and green space may be closer than the SPA, although it is expected that visitors would be likely to travel further than 400m to access the SPA (SEA Objective 2) The second criteria under which development may be outside the Built Up Area boundary, flood risk, ensures that any extensions to the current settlement do not encroach on Flood Zones 2 and 3. This is expected to result in developments with a low risk of flooding (SEA Objective 3) Restricting development to within the Built Up Area boundary, and requiring any extensions to this to be within proximity of existing village services in the case of Policy 1a, increases the likelihood that new development will be located near to services and facilities. This includes shopping centres, medical centres and schools. This may reduce the need for new residents to travel to access these thus keeping car use and associated carbon emissions to a minimum (SEA Objectives 3 and 4) Policy 1a restricts development to those areas with lower landscape sensitivity. This would have positive implications for SEA Objective 7, as the most valuable and vulnerable landscapes would be protected from change, which may result from developing in that area. Policy 1b would not include this criteria, but would not lead to degradation of landscape in itself, thus impacts on SEA Objective 7 have been assessed as neutral for Policy 1b Policy 1a does not seem to suggest a particular spatial layout or distribution of development as the previous SEA suggests 4, thus this assessment has focused on implications of the policy wording itself, rather than its spatial implications. For example, whilst proximity to local services is likely to be closer for sites to the west of Pagham, due to the location of the Pagham Road and The Parade local centres, this area has a higher risk of flooding. Policy 2: Housing Site Allocations Due to the number and complexity of options for Policy 2, assessments for each option have been presented separately. 4 Pagham Parish Council (2014) Pagham Neighbourhood Plan : Strategic Environmental Assessment Lepus Consulting for Arun District Council 17

22 SEA of Alternatives for the PNP July 2015 LC-122 Reasonable_alternatives_5_020915SS.docx The majority of site allocations options lie within the strategic gap. The strategic gap was established in the current 2003 Local Plan 5 and the 2012 Arun Green Infrastructure Study 6, and included in the 2014 Arun Local Plan 7 as Gap Between Settlement. Policy SD SP2 in the 2014 Arun Local Plan allows neighbourhood plans to alter the Built-Up Area Boundary defined in the Arun Local Plan. As the future extent of the Built Up Area Boundary is uncertain and may be altered to include preferred options allocations, the following assessments have considered this a neutral, rather than negative implication, unless the site is considered to be an unacceptable extension into the strategic gap that is not in keeping with local settlement patterns NPPF paragraph 112 seeks to protect best and most versatile agricultural land and advises significant development of agricultural land to prioritise poorer quality land. Policy SO DM1 of the 2014 Arun Local Plan protects Grades 1, 2 and 3a agricultural land, unless it can be demonstrated that benefits of development outweigh the value of this resource. Areas of Pagham that are not within the urban area are largely classified as Grade 1 and Grade 2 agricultural land, which are considered to be best and most versatile. A small part of the rural area of Pagham consists of Grade 3 agricultural land, but it is not known whether this is Grade 3a or 3b. As the options for Policy 2 consist entirely, or almost entirely of best and most versatile agricultural land, sites have not been penalised for this All nearby health services, with the exception of The Health Centre on West Street are currently accepting new patients, thus capacity of healthcare facilities is not considered to be a barrier to health in the area The assessments below consider general implications of any development at each site. Detailed developer proposals have been put forward for some of the sites below, namely Site 117, Site 69, 31 and Site 27. Details of these proposals have not been taken into account in the assessments below, for a number of reasons. Firstly, Pagham Parish Council (the planmaking group) do not necessarily endorse these proposals, thus the proposal details will not necessarily form part of the PNP. Whilst developers may promote their sites, the detailed proposals do not represent a definitive and final plan for these sites; they are subject to change. Most importantly, the NPPF requires reasonable alternatives to be 'considered and assessed in the same level of detail as the preferred approach intended to be taken forward in the neighbourhood plan (the preferred approach).' As potential development plans are not available for all options, details contained within these cannot be taken into account in the assessment. 5 Arun District Council (2003) Arun District Local Plan 6 LUC (2012) Arun Green Infrastructure Study 7 Arun District Council (2014) Arun Local Plan Lepus Consulting for Arun District Council 18

23 SEA of Alternatives for the PNP July 2015 LC-122 Reasonable_alternatives_5_020915SS.docx Whilst there is capacity at the nearest sewage treatment works, off Summer Lane, development sites are unlikely to have existing connections to sewage and wastewater pipes to transport effluent to the sewage works. Without details of how new developments will connect to the existing wastewater and sewage infrastructure, impacts of development on this remain uncertain Note that there are two possible combinations of Land South of Laurel Drive ; including or excluding Orchard. Part of Site 69 is referred to as Orchard as this is the name of the developer that currently owns the land. Orchard has not been assessed in its own right, as PPC felt that this site was not viable unless part of a larger development. SEA Objectives Site /- +/ / Site 125 currently consists of arable land, which is not generally considered to have high biodiversity value. However, hedgerows surrounding the site have potential biodiversity value, particularly as they contribute to a network of hedgerows in the wider landscape and are in close proximity to small wooded areas. Without further investigation into the biodiversity value of these hedgerows, and without knowing if they would be incorporated into the development, implications on biodiversity remain uncertain (SEA Objective 2) Site 125 is located in Flood Zone 1, therefore is at low risk of flooding from rivers and sea. The 2008 SFRA 8 and the 2014 Sequential Exception Test paper 9 identify the site as having high risk of groundwater flooding. The presence of housing development, thus a larger area of impermeable surfaces, on this site may exacerbate this flood risk issue. The SFRA assessment for Northwest Bognor Regis includes a wider area than just this site, thus site-specific details would be necessary to make a fully informed decision regarding the impacts of development (SEA Objective 3) Site 125 is located further than 400m from the Pagham Road centre and the shops on Aldwick Street. This site is approximately 400m from a bus stop. The bus stop is served by low frequency buses that provide a link to Bognor Regis High Street, as well as a public transport link to Tesco in South Bersted and Sainsbury s in Bognor Regis. Site 125 is within 30 minutes public transport time (including walking) to key medical and education facilities. Chalcraft Lane and development to the south of this have a good network of footpaths. This site is assessed as negative overall due to the poor accessibility of local shops and the lack of a high frequency bus service (SEA Objective 4). 8 Arun District Council (2008) Strategic Flood Risk Assessment 9 Arun District Council (2014) Sequential & Exception Tests Lepus Consulting for Arun District Council 19

24 SEA of Alternatives for the PNP July 2015 LC-122 Reasonable_alternatives_5_020915SS.docx The east of this site is bordered by the B2166, which is near its traffic capacity at the junction with Pagham Road 10. Development at the site may lead to increased traffic on the B2166, which could lead to traffic congestion, an increase in car exhaust fumes and a decrease in local air quality. The large size of this site suggests impacts on the road network are likely to be significant, as it is expected that most households will own a car, thus exacerbating congestion on the B2166. It is also uncertain whether bus services have the capacity to accommodate a large increase in the local population (SEA Objectives 4 and 5) Site 125 has good access to healthcare facilities and there are a number of green spaces and playing fields nearby. Unless green space, recreation or community facilities are incorporated into development proposals, this site is unlikely to improve health, but will maintain access to health and recreation facilities for current and future residents (SEA Objective 6) The 2006 Arun Landscape Study determined Site 125 to be within Character Area 6, Rose Green Coastal Plain, which is considered to be of high landscape capacity (SEA Objective 7). Landscape impacts on this site are considered to be negative as development would constitute a large extension of development into the countryside and would alter views from the B2166 as the landscape is flat and open Development at Site 125 would be able to utilise the current infrastructure of Pagham, including roads, communications infrastructure and community facilities, although it is not known if these have capacity to accommodate the number of residents that this site could house. Whilst it is not known whether development would encourage waste minimisation, it is unlike to increase landfill waste production per person. In addition, the development would result in housing development in Pagham, which would contribute to local housing demand. Site 125 is located on Grade 2 agricultural land, which is considered best and most versatile (SEA Objective 8). SEA Objectives Site P15 +/- +/ / Site P15 is adjacent to the Grade II listed Rookery Farmhouse and the locally listed 56/58 Hook Lane. Development at this site would not affect the buildings directly, but it is likely to change the settings of these features. It is likely that setting is an important feature of Rookery Farmhouse. Impacts of development on SEA Objective 1 remain uncertain as they depend on the importance of setting and it is not known how this will be affected without a detailed master plan for the site. 10 WSP (2013) Arun Transport Study for Strategic Development Lepus Consulting for Arun District Council 20

25 SEA of Alternatives for the PNP July 2015 LC-122 Reasonable_alternatives_5_020915SS.docx Site P15 currently consists of arable land, which is not generally considered to have high biodiversity value. However, hedgerows surrounding the site have potential biodiversity value, particularly as they contribute to a network of hedgerows to the north. Without further investigation into the biodiversity value of these hedgerows, and without knowing if they would be incorporated into the development, implications on biodiversity remain uncertain (SEA Objective 2) This site is located in Flood Zone 1, although land to the northwest of the site is designated as Flood Zone 3. The Arun SFRA classifies this site as being within both the Pagham area of the SFRA and the North West Bognor Regis area. Whilst Pagham has a medium risk of groundwater flooding, northwest Bognor Regis is considered to be at high risk of groundwater flooding. Arun District Council have stated that Sefter Road is prone to flooding, thus it is likely that at least part of Site P15 is at risk of flooding (SEA Objective 3) Pagham Road runs along the northwest of the site and the local centre is close to the south western part of the site, thus providing good access to local services. There are bus stops adjacent to the site served by high frequency services to Bognor Regis High Street and town centre, as well as services to supermarkets. This would enable residents of new development at site P15 to be within 30 minutes transport time of key services and facilities. There is a good network of footpaths to the south of the site, although Pagham Road to the north has no designated pedestrian or cycle route. The Pagham Road / B2166 junction is nearing capacity in terms of traffic volume, thus the impacts of this site on traffic and transport have not been assessed as strongly positive (SEA Objectives 4 and 5) The proximity to Pagham Road and good bus services ensure that residents of this site would have good access to healthcare. There are a number of green spaces within 400m of the site, including a play park at Hook Lane Close, in addition to footpaths in the surrounding countryside, giving good access to recreation and open space (SEA Objective 6) The 2006 Arun Landscape Study determined Site P15 to be within Character Area 6, Rose Green Coastal Plain, which is considered to be of high landscape capacity. The site is contained by roads to the northeast and west, which suggests it is a fairly contained extension to the current settlement. Overall landscape impacts of development at this site are considered to be slightly negative as it is a flat, open site and the current hedgerows surrounding the site would not be sufficient to screen housing development. This will particularly affect the visual amenity of residents in dwellings to the south of the site (SEA Objective 7). Lepus Consulting for Arun District Council 21

26 SEA of Alternatives for the PNP July 2015 LC-122 Reasonable_alternatives_5_020915SS.docx Development at Site P15 would be able to utilise the current infrastructure of Pagham, including roads, communications infrastructure and community facilities, although capacity of these is not known. Whilst it is not known whether development would encourage waste minimisation, it is unlikely to increase landfill waste production per person. In addition, the development would result in housing development in Pagham, which would contribute to local housing demand. This site is located on Grade 2 agricultural land, which is considered best and most versatile (SEA Objective 8). SEA Objectives Site 117 +/ /- -- +/ This site is adjacent to a number of listed buildings, including White Rock, The Old Cottage and Millstone Cottage on Church Lane 11. Beckett s Barn and adjoining earthworks is a Scheduled Ancient Monument that lies to the south of the site, just off Church Lane. Development could have a negative impact on the setting of these features, particularly the listed buildings along Church Lane as their setting, backing onto open countryside, would be altered to being in the middle of a built up area. In order to determine the significance of this impact, the importance of setting for the features should be investigated further, in collaboration with Historic England (SEA Objective 1) Site 117 is assessed as having strong negative impacts on biodiversity (SEA Objective 2), due to the presence of Pagham Harbour SPA, Pagham Harbour SSSI, Pagham Harbour LNR and Pagham Harbour Ramsar site within the northwest corner of the site. Units 8 and 22 of the SSSI lie within the site area. These are in favourable and unfavourable recovering conditions respectively. Development at this location is likely to lead to loss of biodiversity at these sites. In addition, recreational pressure on these designated sites is likely to increase as more residents may use them for recreation, as suggested in the Appropriate Assessment of the 2014 Arun Local Plan. In particular, it is expected that dogs and their walkers will disturb wintering birds. Biodiversity may further be adversely affected by urban edge effects, such as littering and predation of nests by pets and foxes. 11 Historic England (2015) The National Heritage List for England Lepus Consulting for Arun District Council 22

27 SEA of Alternatives for the PNP July 2015 LC-122 Reasonable_alternatives_5_020915SS.docx Parts of Site 117 lie in Flood Zone 3, which is considered to have a high risk of flooding. Bunds have been constructed at Pagham Harbour to reduce flood risk from the sea to approximately 1 in 200 probability 12, although this is still equivalent to Flood Zone 3. Whilst the remainder of the site is within Flood Zone 1, increasing the area of impermeable surfaces through development would increase the chance of floodwater from Flood Zone 3 running further into the site. This risk may be exacerbated by climate change, as sea levels are expected to rise and flooding events are expected to become more common (SEA Objective 3). The western side of the site, that incorporates Pagham Harbour, is identified as a GI asset, thus developing this part of the site would lead to loss of this resource The eastern part of the site lies adjacent to the Pagham Road local centre. Due to the large size of the site, the furthest point of the site from Pagham Road is over 1.5km away, thus access to local retail services varies throughout the site. Likewise, there are bus stops adjacent to the southern part of the site, which provide high frequency links to Bognor Regis town centre and to supermarkets, but there are no services passing to the north of the site. There is a good network of footpaths to the east of the site, although transport routes to the north of the site are limited. As the Pagham Road / B2166 junction is nearing capacity in terms of traffic volume, additional traffic from new development at Site 117 is likely to lead to congestion issues on this road, if appropriate additional road infrastructure is not incorporated into the development, for example if residents cannot easily access public transport or there is only a singular access road for all residents (SEA Objectives 4 and 5) Due to the variation in accessibility across the site, it cannot be known if residents would have good access to healthcare as this depends on the transport links incorporated into the development. If the Green Infrastructure features of the site are removed, this may have negative implications for recreational space available to residents, although the LNR/SSSI/Ramsar/SPA provides a large recreational resource for residents at this site (SEA Objective 6) Site 117 lies primarily within the Pagham Harbour character area, as identified in the Arun Landscape Study (2006). The Landscape Study identified this site as having negligible landscape capacity, meaning that any development is likely to have severe consequences on the local landscape. The proximity of this site to Pagham Harbour and the fact that it would represent large extension of the settlement into the countryside, which is highly visible from Pagham Road, Church Lane and the countryside to the north, result in strong negative impacts against SEA Objective Hendry, M. on behalf of Pagham Parish Council (2014) personal communication, 27 April Lepus Consulting for Arun District Council 23