16. Allocation Policy: SD64 is undeliverable (Part 16 of 16) This is part of the Coldwaltham Meadow Conservation comments on the pre-submission Local Plan for the South Downs National Park. We have commented on 14 different Policies and on the HRA and the SA. We have therefore made 16 separate representations, all in the context of Allocation Policy SD64. They consist of the following: 1 The SDNPA Habitat Regulations Assessment 2 The SDNPA Sustainability Appraisal 3 Core Policy SD1: Sustainable Development 4 Core Policy SD2: Ecosystem Services 5 Core Policy SD3: Major Development 6 Strategic Policy SD4: Landscape Character 7 Strategic Policy SD6: Safeguarding Views 8 Strategic Policy SD8: Dark Night Skies 9 Strategic Policy SD9: Biodiversity and Geodiversity 10 Strategic Policy SD10: International Sites 11 Strategic Policy SD12: Historic Environment 12 Strategic Policy SD19: Transport and Accessibility 13 Strategic Policy SD22: Parking Provision 14 Strategic Policy SD23: Sustainable Tourism 15 Strategic Policy SD25: Development Strategy 16 Allocation Policy SD64: Land South of London Road The Coldwaltham Meadow Conservation Group considers the Local Plan is unsound because the delivery requirements for Policy SD64 are not are effective because they are not deliverable. 1. The development requirement 2f of Policy SD64 is not deliverable because Policy SD64 will destroy a flower-rich hay meadow, an inherently biodiverse cultural heritage asset which is now vanishingly scarce in the southeast; 97% of the the UK’s flower-rich hay meadows have disappeared since the 1930s and the site for Policy SD64 is the only flower-rich hay meadow in the Arun Valley. In response to a Freedom of Information query, raised by us under the Environmental Information Regulations 2004, we learn England have “Natural raised concerns with the National Park Authority regarding this allocation primarily with respect to the quality of the allocation site itself, the need to evaluate the clear biodiversity value of the site and the various ecosystems services that it provides. It is for the National Park to this allocation to ensure it is compatible with the various policies within the emerging local plan.” (Source: Access to information Request - Response - Request No RFI
16. Allocation Policy: SD64 is undeliverable (Part 16 of 16) This is part of the Coldwaltham Meadow Conservation comments on the pre-submission Local Plan for the South Downs National Park. We have commented on 14 different Policies and on the HRA and the SA. We have therefore made 16 separate representations, all in the context of Allocation Policy SD64. They consist of the following: 1 The SDNPA Habitat Regulations Assessment 2 The SDNPA Sustainability Appraisal 3 Core Policy SD1: Sustainable Development 4 Core Policy SD2: Ecosystem Services 5 Core Policy SD3: Major Development 6 Strategic Policy SD4: Landscape Character 7 Strategic Policy SD6: Safeguarding Views 8 Strategic Policy SD8: Dark Night Skies 9 Strategic Policy SD9: Biodiversity and Geodiversity 10 Strategic Policy SD10: International Sites 11 Strategic Policy SD12: Historic Environment 12 Strategic Policy SD19: Transport and Accessibility 13 Strategic Policy SD22: Parking Provision 14 Strategic Policy SD23: Sustainable Tourism 15 Strategic Policy SD25: Development Strategy 16 Allocation Policy SD64: Land South of London Road The Coldwaltham Meadow Conservation Group considers the Local Plan is unsound because the delivery requirements for Policy SD64 are not are effective because they are not deliverable. 1. The development requirement 2f of Policy SD64 is not deliverable because Policy SD64 will destroy a flower-rich hay meadow, an inherently biodiverse cultural heritage asset which is now vanishingly scarce in the southeast; 97% of the the UK’s flower-rich hay meadows have disappeared since the 1930s and the site for Policy SD64 is the only flower-rich hay meadow in the Arun Valley. In response to a Freedom of Information query, raised by us under the Environmental Information Regulations 2004, we learn “Natural England have raised concerns with the National Park Authority regarding this allocation primarily with respect to the quality of the allocation site itself, the need to the clear biodiversity value of the site and the various ecosystems services that it provides. It is for the National Park to evaluate this allocation to ensure it is compatible with the various policies within the emerging local plan.” (Source: Access to information Request - Response - Request No RFI
16Allocation-PolicySD64.docx