Latest Consultation reveals ongoing concerns from Natural England & South Downs National Park Authority…

Mid Sussex District Council have now published the responses to their Main Modifications Consultation. These reveal that it’s not just concerned citizens who continue to have reservations about the environmental impacts of the Site Allocations DPD – and not just for Sites SA12 & SA13.

One of the modifications was a strengthening of the commitment to “Biodiversity Net Gain” which basically means that any development mustlead to an increase in biodiversity. MSDC have targets, written in black and white, which apply to the housing site allocations:

  • Maximise the biodiversity units gained
  • A minimum 10% biodiversity net gain
  • Secure RELEVANT & MEANINGFUL biodiversity net gain linked to wider nature recovery

It is impossible to see how these can be achieved by destroying the rich and varied wildlife habitat at Sites SA12 & SA13.

Will developers really be able to prove that they can create a net gain in biodiversity by destroying the habitat of protected species such as nightingales, great crested newts anddormice?

As Natural England state in their consultation response:

‘Maximise the biodiversity units gained’ is welcome but should also ensure that appropriate habitat is created or enhanced based on the local context of the site.”

Planting a few trees among the houses, retaining a pond or promising some vague environmental project elsewhere won’t be good enough – how can it possibly match the rich and varied local context? The only way to ensure biodiversity is to retain the existing rewilded nature haven as it is.

The South Downs National Park Authority aren’t happy either. The protection for the setting of the National Park has been strengthened a bit by saying development at SA13 has to “respond to” rather than just “respect” it. But the SDNPA echo our worry that the changes to Landscape Considerations don’t go nearly far enough, saying that they only go “some way” to addressing these concerns. They suggest that MSDC should go further by ensuring that the Landscape & Visual Impact Assessment (LVIA) must pay “particular attention to the increasing sensitivity moving through the site, towards the south, especially in terms of historic field patterns, ecological value and perceptual qualities”

Crucially they state that any development must “take account of and respond to the findings of the LVIA” meaning that the LVIA must be undertaken BEFORE any decision can be made on how many, if any, houses the site can take – ie before policy SA13 and the Site Allocations DPD itself can be finalised.

This is the point we made in the SOFLAG response to the consultation and we hope that the Inspector agrees – if MSDC try to press on without the LVIA, they would be at risk of legal challenge.

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