Strategic Environmental
Assessment for the Rogate
and Rake Neighbourhood
Plan
Environmental Report to accompany the submission
version of the Neighbourhood Plan
Rogate and Rake Neighbourhood Plan Steering Group
February 2020
Environmental Report to accompany the
submission version of the Neighbourhood Plan
Prepared for: Rogate and Rake Neighbourhood Plan Steering Group
AECOM
Quality information
Prepared by
Checked by
Approved by
Ryan Putt
Environmental
Consultant
Cheryl Beattie
Senior Environmental
Planner
Nick Chisholm-Batten
Associate Director
Alastair Peattie
Revision History
Revision
Revision date
Details
Authorized
Name
Position
V3.0
18
th
February 2020
Submission
version
18
th
February 2020
Nick Chisholm-
Batten
Associate
Director
Prepared for:
Rogate and Rake Neighbourhood Plan Steering Group
Prepared by:
AECOM Infrastructure & Environment UK Limited
Portwall Place
Portwall Lane
Bristol BS1 6NA
United Kingdom
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© 2020 AECOM Infrastructure & Environment UK Limited. All Rights Reserved.
This document has been prepared by AECOM Infrastructure & Environment UK Limited (“AECOM”) for
sole use of our client (the “Client”) in accordance with generally accepted consultancy principles, the
budget for fees and the terms of reference agreed between AECOM and the Client. Any information
provided by third parties and referred to herein has not been checked or verified by AECOM, unless
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Environmental Report to accompany the
submission version of the Neighbourhood Plan
Prepared for: Rogate and Rake Neighbourhood Plan Steering Group
AECOM
Table of Contents
Non-Technical Summary ..........................................................................................................
1. Introduction .................................................................................................................... 1
Background ............................................................................................................................................................................................... 1
SEA explained .......................................................................................................................................................................................... 2
Structure of this SEA Environmental Report ............................................................................................................................ 3
2. Local Plan context and vision for the Rogate and Rake
Neighbourhood Plan ............................................................................................................... 4
Local Plan context for the Neighbourhood Plan .................................................................................................................... 4
Vision and objectives of the Neighbourhood Plan ................................................................................................................ 5
3. What is the scope of the SEA? ................................................................................ 6
SEA Scoping Report ............................................................................................................................................................................. 6
Key Sustainability Issues .................................................................................................................................................................... 7
SEA Framework .................................................................................................................................................................................... 10
4. What has plan making / SEA involved up to this point? ............................. 14
Introduction ............................................................................................................................................................................................ 14
Housing numbers to deliver through the Neighbourhood Plan ................................................................................... 14
Assessment of reasonable alternatives for site allocations .......................................................................................... 14
SEA site assessment findings ...................................................................................................................................................... 17
Current approach in the Neighbourhood Plan ..................................................................................................................... 30
Neighbourhood Plan policies ........................................................................................................................................................ 30
5. What are the appraisal findings at this current stage? ............................... 32
Introduction ............................................................................................................................................................................................ 32
Approach to the appraisal .............................................................................................................................................................. 32
Biodiversity and Geodiversity ....................................................................................................................................................... 32
Climate Change.................................................................................................................................................................................... 33
Landscape .............................................................................................................................................................................................. 35
Historic Environment ......................................................................................................................................................................... 36
Land, Soil and Water Resources .................................................................................................................................................. 37
Population and Community ........................................................................................................................................................... 38
Health and Wellbeing ......................................................................................................................................................................... 39
Transportation....................................................................................................................................................................................... 39
Conclusion at this current stage ................................................................................................................................................. 40
6. What are the next steps? ....................................................................................... 42
Appendix A Context Review and Baseline ................................................................... 43
Environmental Report to accompany the
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Prepared for: Rogate and Rake Neighbourhood Plan Steering Group
AECOM
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Environmental Report to accompany the
submission version of the Neighbourhood Plan
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Non-Technical Summary
What is Strategic Environmental Assessment (SEA)?
A strategic environmental assessment (SEA) has been undertaken to inform the Rogate and Rake
Neighbourhood Plan. This process is required by the SEA Regulations.
Neighbourhood Plan groups use SEA to assess Neighbourhood Plans against a set of sustainability
objectives developed in consultation with interested parties. The purpose of the assessment is to
avoid adverse environmental and socio-economic effects through the Neighbourhood Plan, and
identify opportunities to improve the environmental quality of the area covered by the Neighbourhood
Plan and the quality of life of residents.
What is the Rogate and Rake Neighbourhood Plan?
The Rogate and Rake Neighbourhood Plan is currently being prepared as a Neighbourhood
Development Plan under the Localism Act 2011 and the Neighbourhood Planning (General)
Regulations 2012. The Neighbourhood Plan is being prepared in the context of the adopted South
Downs Local Plan.
The Neighbourhood Plan will be submitted to the South Downs National Park Authority in autumn
2019.
Purpose of this Environmental Report
This Environmental Report, which accompanies the submission version of the Neighbourhood Plan, is
the latest document to be produced as part of the SEA process. The first document was the SEA
Scoping Report (June 2019), which includes information about the Neighbourhood Plan area’s
environment and community.
The purpose of this Environmental Report is to:
• Identify, describe and evaluate the likely significant effects of the Rogate and Rake
Neighbourhood Plan and alternatives; and
• Provide an opportunity for consultees to offer views on any aspect of the SEA process
which has been carried out to date.
The Environmental Report contains:
• An outline of the contents and main objectives of the Rogate and Rake Neighbourhood Plan
and its relationship with other relevant policies, plans and programmes;
• Relevant aspects of the current and future state of the environment and key sustainability
issues;
• The SEA Framework of objectives against which the Rogate and Rake Neighbourhood Plan
has been assessed;
• The appraisal of alternative approaches for the Rogate and Rake Neighbourhood Plan;
• The likely significant environmental effects of the Rogate and Rake Neighbourhood Plan;
• The measures envisaged to prevent, reduce and as fully as possible offset any significant
adverse effects as a result of the Rogate and Rake Neighbourhood Plan; and
• The next steps for the Rogate and Rake Neighbourhood Plan and accompanying SEA
process.
Environmental Report to accompany the
submission version of the Neighbourhood Plan
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Assessment of reasonable alternatives for the Rogate and Rake
Neighbourhood Plan
Housing numbers to deliver through the Neighbourhood Plan
The South Downs Local Plan highlights that approximately 11 homes are provided for in Rogate. This
is in addition to extant planning permissions granted prior to 1st April 2015 and windfalls. The Local
Plan however also highlights that Neighbourhood Plans that accommodate higher levels of housing
will be supported by the National Park Authority providing that they meet local housing need and are in
general conformity with the strategic policies of the development plan.
To inform the development of the Neighbourhood Plan, a housing needs survey was completed in
June 2017 by Chichester District Council’s housing delivery team on behalf of the parish council. This
highlighted that there was potentially a need for a higher figure, possibly approaching 30 units. The
Housing Needs Survey also identified a need for new housing to provide one, two- or three-bedroom
homes to meet local needs.
In light of discussions with the National Park Authority, and a recognition of the significant constraints
present locally associated with the National Park, it was agreed that in the region of 11-20 homes
should be delivered through the Neighbourhood Plan.
Assessment of sites for potential allocation through the Neighbourhood Plan
To further support the development of a spatial strategy to deliver the 11-20 dwellings proposed for
Rogate and Rake through the Neighbourhood Plan, the Neighbourhood Plan Steering Group has
considered alternative locations for delivering housing in the parish.
To support this process, the Neighbourhood Plan Steering Group has considered potential sites for
allocation through the Neighbourhood Plan for housing. Work to identify sites considered:
• The South Downs National Park Authority’s Strategic Housing Land Availability Assessment
(SHLAA); and
• Further sites identified by the Neighbourhood Plan Steering Group.
Following this process, 16 sites underwent an initial site assessment. Following a consideration of the
availability, delivery and achievability of the sites, six sites were considered as potentially appropriate
for taking forward through the Neighbourhood Plan.
These sites are as follows:
• Site 1: W entrance, Parsonage
• Site 2: Garage units, Parsonage
1
• Site 3: 1-4 Parsonage
• Site 4: Primrose lane/ Flying Bull
• Site 5: Clayton Court
• Site 6: Renault garage
The reasons these six sites were deemed appropriate for further consideration for the Neighbourhood
Plan is set out in the Potential Development Sites Background Paper accompanying the submission
version of the Neighbourhood Plan.
2
1
It should be noted that since these sites were assessed through the SEA process, Site 2 (Garage Units, Parsonage) has
undergone development.
2
Rogate and Rake Neighbourhood Development Plan Potential Development Sites Background Paper
Environmental Report to accompany the
submission version of the Neighbourhood Plan
NTS3
To support the consideration of the suitability of these sites for potential allocation in the
Neighbourhood Plan, the SEA process has undertaken an appraisal of the key environmental
constraints present at each of the sites and potential effects that may arise as a result of development
at these locations. This SEA site assessment was undertaken separately to a site assessment
undertaken by the Rogate and Rake Neighbourhood Plan Steering Group.
The locations of the six sites appraised through the SEA process are presented in Figure 4.1 in the
main body of the Environmental Report. Tables 4.2 to 4.7 subsequently present the findings of the
appraisal.
A summary of the site appraisal findings is presented below.
Table NTS1: Summary of SEA site appraisal findings
Site
Biodiversity
and
geodiversity
Climate
change
Landscape
Historic
environment
Land, soil
and water
resources
Population
and
community
Health
and
wellbeing
Transport
Site 1
Site 2
Site 3
Site 4
Site 5
Site 6
Key
Likely adverse effect (without mitigation measures)
Likely positive effect
Neutral/no effect
Uncertain effects
The submission version of the Neighbourhood Plan allocates two of the above sites for residential
development. These are as follows:
• Renault Garage and adjoining Bungalow South of A272 : Nine houses and either two flats or
two workshops.
• Land on North side of B2070 London Road west of Flying Bull PH, Rake: Four houses.
The allocation of these sites follows consideration of the findings of the site assessments undertaken
for the Neighbourhood Plan, extensive community consultation and a consideration of the types of
development which could be taken forward on each site in conjunction with Neighbourhood Plan
objectives.
Environmental Report to accompany the
submission version of the Neighbourhood Plan
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Assessment of the submission version of the Rogate and Rake
Neighbourhood Plan
The submission version of the Rogate and Rake Neighbourhood Plan presents 18 planning policies for
guiding development in the Neighbourhood Plan area.
Utilising the SEA Framework of objectives and assessment questions developed during the earlier
scoping stage of the SEA, the SEA process assessed the policies put forward through the current
version of the Rogate and Rake Neighbourhood Plan. The Environmental Report has presented the
findings of the assessment under the following SEA Themes:
• Biodiversity;
• Climate Change;
• Landscape
• Historic Environment;
• Land, Soil and Water Resources;
• Population and Community;
• Health and Wellbeing; and
• Transportation.
The assessment has concluded that the current version of the Rogate and Rake Neighbourhood Plan
is likely to lead to significant long term positive effects in relation to the ‘Population and Community’
SEA theme. These benefits largely relate to the Neighbourhood Plan’s focus on providing new housing
to meet local needs, support for improvements to new community infrastructure, the protection and
enhancement of green infrastructure networks in the area and the protection and enhancement of the
quality of the public realm and neighbourhood distinctiveness.
Positive effects are considered likely in relation to the ‘Biodiversity’, ‘Climate Change’, ‘Landscape’,
‘Historic Environment’ and ‘Land, Soil and Water resources’ SEA themes. These positive effects are
linked to the following;
• Long-term protection for biodiversity and geodiversity, including a requirement for project-
level HRA screening in the vicinity of The Wealden Heaths Phase II Special Protection Area
(SPA) and the Woolmer Forest Special Area of Conservation (SAC).
• The redevelopment of previously developed land at the Renault Garage site in Rogate will
support efficient land use and is likely to lead to enhancements to the villagescape,
including adjacent to the designated Rogate Conservation Area.
• Promotion of renewable energy generation and sustainable building techniques will support
climate change mitigation in the Neighbourhood Plan area.
Minor negative effects have also been identified in relation to the Land, Soil and Water Resources and
Climate Change SEA themes:
• The small-scale level of growth proposed in Rake will result in a very limited loss of
greenfield land, which has some (uncertain) potential to include the loss of high-quality
agricultural land. However, this is likely to a negligible effect.
• Very minor increases in greenhouse gas emissions are anticipated as a result of the
increase in the built footprint of the Neighbourhood Plan area and a limited increase in car
use.
Given the scale of proposals, these negative effects are however likely to be insignificant.
Environmental Report to accompany the
submission version of the Neighbourhood Plan
NTS5
Next steps
This Environmental Report accompanies the Rogate and Rake Neighbourhood Plan for submission to
the Local Planning Authority, the South Downs National Park Authority, for subsequent Independent
Examination.
At Independent Examination, the Neighbourhood Plan will be considered in terms of whether it meets
the Basic Conditions for Neighbourhood Plans and is in general conformity with the South Downs
Local Plan.
If Independent Examination is favourable, the Neighbourhood Plan will be subject to a referendum,
organised by the South Downs National Park Authority. If more than 50% of those who vote agree with
the Neighbourhood Plan, then it will be ‘made’. Once made, the Rogate and Rake Neighbourhood Plan
will become part of the development plan for Rogate Parish.
Strategic Environmental Assessment for the Rogate and Rake
Neighbourhood Plan
Environmental Report to accompany the submission version of the
Neighbourhood Plan
Prepared for: Rogate and Rake Neighbourhood Plan Steering Group
AECOM
Environmental Report to accompany the
submission version of the Neighbourhood Plan
Prepared for: Rogate and Rake Neighbourhood Plan Steering Group
AECOM
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1. Introduction
Background
AECOM has been commissioned to undertake an independent Strategic Environmental
Assessment in support of Rogate Parish’s emerging Neighbourhood Plan. The Neighbourhood
Plan area includes the settlements of Rogate and Rake.
The Rogate and Rake Neighbourhood Plan is currently being prepared as a Neighbourhood
Development Plan under the Localism Act 2011 and the Neighbourhood Planning (General)
Regulations 2012. The Neighbourhood Plan is being prepared in the context of the recently
adopted South Downs Local Plan.
It is currently anticipated that the Neighbourhood Plan will be submitted to the South Downs
National Park Authority (SDNPA) later in 2019.
Key information relating to the Rogate and Rake Neighbourhood Plan is presented in Table 1.1.
Table 1.1: Key facts relating to the Rogate and Rake Neighbourhood Plan
Name of Responsible Authority
Rogate Parish Council
Title of Plan
Rogate and Rake Neighbourhood Plan
Subject
Neighbourhood planning
Purpose
The Rogate and Rake Neighbourhood Plan is being
prepared as a Neighbourhood Development Plan under the
Localism Act 2011 and Neighbourhood Planning (General)
Regulations 2012. The plan will be in general conformity
with the adopted South Downs Local Plan (2014-2033)
The Rogate and Rake Neighbourhood Plan will be used to
guide and shape development within the Neighbourhood
Plan area.
Timescale
To 2033
Area covered by the plan
The Rogate and Rake Neighbourhood Plan area covers the
parish of Rogate, within the boundaries of the South Downs
National Park. It incorporates the villages of Rogate and
Rake (the majority), and the hamlets of Fyning, Hillbrow
(part), Durford Wood, Durleighmarsh, Terwick Common,
Tullecombe, Habin, Langley and Nyewood (part).
Figure 1.1 above highlights the boundary of the
Neighbourhood Plan area..
Summary of content
The Rogate and Rake Neighbourhood Plan will set out a
vision, strategy and range of policies for the Neighbourhood
Plan area.
Plan contact point
Name: Steve Williamson
Email address: steve@thestepsrake.co.uk
Environmental Report to accompany the
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AECOM
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SEA explained
1.5 Strategic Environmental Assessment (SEA) is a mechanism for considering and communicating
the impacts of an emerging plan, and potential alternatives in terms of key sustainability issues.
The aim of SEA is to inform and influence the plan-making process with a view to avoiding and
mitigating negative impacts. Through this approach, the SEA for the Rogate and Rake
Neighbourhood Plan seeks to maximise the developing plan’s contribution to sustainable
development.
1.6 SEA is undertaken to address the procedures prescribed by the Environmental Assessment of
Plans and Programmes Regulations 2004 (the SEA Regulations) which transpose into national
law the EU Strategic Environmental Assessment (SEA) Directive
3
. It also widens the scope of the
assessment from focussing on environmental issues to further consider social and economic
issues.
1.7 The Rogate and Rake Neighbourhood Plan has been screened in by the South Downs National
Park Authority as requiring an SEA. To meet this requirement, the Neighbourhood Plan is
undergoing an SEA process which incorporates the requirements of the SEA Directive.
1.8 The SEA will be undertaken to meet specific requirements prescribed by the Environmental
Assessment of Plans and Programmes Regulations 2004 (the SEA Regulations).
1.9 Two key procedural requirements of the SEA Regulations are that:
1. When deciding on ‘the scope and level of detail of the information’ which must be included
in the Environmental Report there is a consultation with nationally designated authorities
concerned with environmental issues; and
2. A report (the ‘Environmental Report’) is published for alongside the Draft Plan (i.e. the
proposed Regulation 14 consultation version of the Rogate and Rake Neighbourhood Plan)
that presents outcomes from the environmental assessment (i.e. discusses ‘likely significant
effects’ that would result from plan implementation) and reasonable alternatives.
3
Directive 2001/42/EC
Environmental Report to accompany the
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Structure of this SEA Environmental Report
1.10 This document is the SEA Environmental Report for the Rogate and Rake Neighbourhood Plan
and hence needs to answer all four of the questions listed below with a view to providing the
information required by the SEA Regulations. Each of the four questions is answered in turn
within this report, as follows:
Table 1.2: Questions that must be answered by the SEA Environmental Report in order to meet
the regulatory
4
requirements
Environmental Report question
In line with the SEA Regulations, the report must
include…
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What’s the
scope of the
SEA?
What is the plan
seeking to
achieve?
• An outline of the contents, main objectives of the plan and
relationship with other relevant plans and programmes.
What is the
sustainability
‘context’?
• The relevant environmental protection objectives
established at international or national level.
• Any existing environmental problems which are relevant to
the plan including those relating to any areas of a
particular environmental importance.
What is the
sustainability
‘baseline’?
• The relevant aspects of the current state of the
environment and the likely evolution thereof without
implementation of the plan.
• The environmental characteristics of areas likely to be
significantly affected.
• Any existing environmental problems which are relevant to
the plan including those relating to any areas of a
particular environmental importance.
What are the key
issues &
objectives?
• Key problems/issues and objectives that should be a
focus of (i.e. provide a ‘framework’ for) assessment.
What has plan-making/SEA
involved up to this point?
• Outline reasons for selecting the alternatives dealt with
(and thus an explanation of the ‘reasonableness’ of the
approach).
• The likely significant effects associated with alternatives.
• Outline reasons for selecting the preferred approach in-
light of alternatives appraisal/a description of how
environmental objectives and considerations are reflected
in the current version of the plan.
What are the assessment findings
at this stage?
• The likely significant effects associated with the
submission version of the plan.
• The measures envisaged to prevent, reduce and as fully
as possible offset any significant adverse effects of
implementing the submission version of the plan.
What happens next?
• The next steps for plan making / SEA process.
4
Environmental Assessment of Plans and Programmes Regulations 2004
5
NB this column does not quote directly from Schedule II of the Regulations. Rather, it reflects a degree of interpretation.
Environmental Report to accompany the
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AECOM
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2. Local Plan context and vision for the
Rogate and Rake Neighbourhood
Plan
Local Plan context for the Neighbourhood Plan
2.1 The Rogate and Rake Neighbourhood Plan is being prepared in the context of the local strategic
policies of the South Downs National Park, namely the South Downs Partnership Management
Plan and the adopted South Downs Local Plan (2014-2033).
2.2 The first South Downs National Park Partnership Management Plan (PMP) was adopted by the
National Park Authority in 2013 following extensive consultation and dialogue with numerous
interested parties and groups. Covering the period between 2014 and 2019, the PMP presents
an overarching strategy for the management of the National Park, setting out how a range of
organisations (including, but not exclusively, the National Park Authority) will work together to
achieve shared objectives for the future management of the National Park.
2.3 The South Downs PMP sets out: a vision and a series of outcomes, which present the ambitions
of the plan; a series of policies which are intended to guide partnership delivery over the five
year plan period, with pointers to a longer-term vision to 2050; a Delivery Framework against
which the partners involved in the plan will deliver these ambitions and policies; and a monitoring
framework against which progress in delivering the PMP’s ambitions can be measured.
2.4 The PMP is now being reviewed. The updated PMP will focus on the development of a new joint
action plan, setting out clear priorities for the practical action that the National Park Authority &
partners will be responsible for delivering by 2024 to reach the PMP’s shared vision.
2.5 The South Downs Local Plan (2014-2033) was adopted in July 2019. It provides the broad
policy framework and a long-term strategy to manage development, protect the environment,
deliver infrastructure and promote sustainable communities within the South Downs National
Park.
2.6 In the context of the Neighbourhood Plan area, Rogate is within the ‘Western Weald’ area of the
National Park. Strategic Policy SD25 ‘Development Strategy’ states that the principle of
development within settlements (including Rogate) will be supported, providing that proposals:
• Are of a scale and nature appropriate to the character and function of the settlement in its
landscape context;
• Make best use of suitable and available previously developed land in the settlement; and
• Make efficient and appropriate use of land.
2.7 Strategic Policy SD26 ‘Supply of Homes’ confirms that the SDNPA will make overall provision for
approximately 4,750 net additional homes during the Local Plan period. The policy states a
target of 11 new dwellings for Rogate (in addition to extant planning permissions granted prior to
1
st
April 2015 and windfalls), to be delivered through the emerging Neighbourhood Plan.
2.8 Neighbourhood plans will form part of the development plan for the South Downs National Park,
alongside, but not as a replacement for the Local Plan. Neighbourhood plans are required to be
in general conformity with the Local Plan and can develop policies and proposals to address
local place-based issues. In this way it is intended for the Local Plan to provide a clear overall
strategic direction for development in the South Downs, whilst enabling finer detail to be
determined through the neighbourhood planning process where appropriate.
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Vision and objectives of the Neighbourhood Plan
2.9 The vision for the Rogate and Rake Neighbourhood Plan, which was developed during the early
stages of plan making, is as follows:
“During the Plan period, the quality, tranquillity and character of the natural and built
environments will be safeguarded and improved for future generations, and the parish will
become a more environmentally sustainable, vibrant and cohesive community for the benefit of
all people living in, working in and visiting the area.”
2.10 Implementing this vision, the Neighbourhood Plan focuses on eight objectives. These
objectives are:
• Sustainability: To ensure new development is sustainable through maintaining and supporting
the natural environment, natural resources, landscape and tranquillity of the parish
• Natural Environment: To conserve and enhance heathlands, woodlands, hedgerows, wildlife
habitats and species, water systems, natural and agricultural resources and cycles; including
how they combine to form the characterising views and tranquillity of the parish.
• Built Environment: To retain, respect and strengthen the cultural heritage and rural character
of the existing built form of settlements and their settings within the landscape whilst also
encouraging high quality, including contemporary, designs, sustainable building practices and
the use of local renewable materials.
• Housing: To meet the changing housing needs of the community, especially for young people
and the elderly wishing to remain in the parish.
• Economy and Work: To support local enterprises and employment opportunities, including
agriculture and horticulture, which contribute positively to the parish and are delivered without
detriment to the local environment.
• Transport: To enhance the attractiveness of walking, cycling and public transport use and to
create a safe and efficient environment for all road users.
• Energy: To reduce carbon emissions and encourage the use of sustainable building
techniques and renewable energy sources wherever possible.
• Community Health, Wellbeing and Amenity: To provide, maintain and improve access to the
local countryside, public open spaces, public footpaths and bridleways, outdoor and indoor
recreational facilities, playgrounds and rivers, and all other means to support a diverse and
mixed community.
Environmental Report to accompany the
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3. What is the scope of the SEA?
SEA Scoping Report
3.1 The SEA Regulations require that: “When deciding on the scope and level of detail of the
information that must be included in the report, the responsible authority shall consult the
consultation bodies”. In England, the consultation bodies are Natural England, the Environment
Agency and Historic England.
6
These authorities were consulted on the scope of the Rogate and
Rake Neighbourhood Plan SEA in June 2019.
3.2 The purpose of scoping was to outline the ‘scope’ of the SEA through setting out:
• A context review of the key environmental and sustainability objectives of national, regional
and local plans and strategies relevant to the Neighbourhood Plan;
• Baseline data against which the Neighbourhood Plan can be assessed;
• The key sustainability issues for the Neighbourhood Plan; and
• An ‘SEA Framework’ of objectives against which the Neighbourhood Plan can be assessed.
3.3 Responses received on the Scoping Report, and how they were addressed, have been
summarised below.
Table 3.1: Consultation responses received on the SEA Scoping Report
Consultation response
How the response was
considered and addressed
Natural England
Victoria Kirkham, Consultations Team (email response received on 22
nd
July 2019)
Natural England has no specific comments to make on this
neighbourhood plan SEA scoping. However, we refer you to the
advice in the attached annex which covers the issues and
opportunities that should be considered when preparing a
Neighbourhood Plan
Comments noted. The annex
has been a useful source of
reference during the SEA
process.
Historic England
Robert Lloyd-Sweet, Historic Places Advisor (email response received on 25
th
July 2019)
I'm happy to confirm I don't have any negative comments and
feel the assessment of the historic environment baseline,
including identification of evidence gaps is a helpful starting
point for assessing the plan. I'm also happy that the Key
sustainability issues and SEA objective are appropriate.
Comments noted.
Environment Agency
Sophie Brown, Planning Advisor (email response received on 30
th
July 2019)
6
In-line with Article 6(3).of the SEA Directive, these consultation bodies were selected because ‘by reason of their specific
environmental responsibilities,[they] are likely to be concerned by the environmental effects of implementing plans and
programme’.’
Environmental Report to accompany the
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Consultation response
How the response was
considered and addressed
We have reviewed your Scoping Report and are pleased to see
that issues within our remit have been included within your
specific objectives, notably biodiversity, flood risk and climate
change, and water quality.
Comments noted
Please also find attached a Neighbourhood Plan Checklist we
have produced for Neighbourhood Plan groups which you may
find useful in progressing the SEA and Neighbourhood Plan
itself.
Comments noted. The
Neighbourhood Plan
Checklist has been a useful
source of reference during
the SEA process.
3.4 Baseline information (including the context review and baseline data) is presented in Appendix A.
The key sustainability issues and SEA Framework are presented below.
Key Sustainability Issues
3.5 Drawing on the review of the sustainability context and baseline, the SEA Scoping Report was
able to identify a range of sustainability issues that should be a focus of the SEA. These issues
are as follows, presented by nine SEA themes.
Air Quality
• There are no AQMAs within the Neighbourhood Plan area. However, the ASR notes that the
road network within the Chichester is vulnerable to air pollution issues associated with
congestion.
• Emissions associated with road transport (primarily NO2) are the main pollutant of concern.
• There are two European designated sites surrounding the Neighbourhood Plan area which are
sensitive to air pollution issues associated with traffic emissions. This is further considered
under the ‘biodiversity and geodiversity’ SEA theme’.
• Given air quality issues are primarily linked to potential effects on European designated sites
for biodiversity, and not human factors, aspects relating to air quality have been considered
under the biodiversity theme for the purposes of the current SEA process.
Biodiversity and Geodiversity
• There are two European designated sites within close proximity to the Neighbourhood Plan
area: the Wealden Heaths Phase II SPA and the Woolmer Forest SAC.
• The integrity of the European designated sites located within and surrounding the
Neighbourhood Plan area are threatened by a variety of factors, including (but not limited to):
public disturbance, invasive species, water pollution and air pollution issues.
• There are five Sites of Special Scientific Interest (SSSI) within or within proximity to the
Neighbourhood Plan area: Woolmer Forest SSSI, Forest Mere SSSI, Chapel Common SSSI,
Rake Hanger SSSI and Fyning Moor SSSI.
• The whole of the Neighbourhood Plan area overlaps with a SSSI IRZ for residential, rural
residential and rural non-residential development types.
• At the local level, there are several LWS also located within the Neighbourhood Plan area,
containing habitats and species listed in the annexes of both the European Habitats Directive
(92/43/EEC) and the European Birds Directive (79/409/EEC).
Environmental Report to accompany the
submission version of the Neighbourhood Plan
Prepared for: Rogate and Rake Neighbourhood Plan Steering Group
AECOM
8
• The Neighbourhood Plan area also contains a variety of BAP Priority Habitats and areas of
ancient and semi-natural woodland.
Climate Change
• Based on DECC statistics, the sector with the highest overall energy consumption in the
Chichester District is transport, accounting for 37.2% of energy consumption. The largest
consuming sector was transport, accounting for 37.2% of overall consumption.
• Chichester District has seen a 33.7% reduction in the percentage of total emissions per capita
between 2005 and 2016, lower than the reductions for West Sussex (36.6%), the South East
of England (36.7%) and England (37.6%).
• Any increases in the built footprint of the Neighbourhood Plan area (associated with the
delivery of new housing and employment land) has the potential to increase overall
greenhouse gas emissions.
• The Environment Agency’s Flood Map for Planning highlights that while most of the
Neighbourhood Plan area lies in Flood Zone 1, some areas in the south of the Plan area
adjacent to the River Rother are located in Flood Zone 3a, indicating a high risk of flooding.
• Surface water flooding is an issue for parts of the Neighbourhood Plan area, including areas of
medium and high risk.
• The Rogate and Rake Neighbourhood Plan should seek to increase the resilience of the
Neighbourhood Plan area to the effects of climate change by supporting and encouraging
adaptation strategies.
Landscape
• The Neighbourhood Plan area is located within the South Downs National Park, which has six
special qualities outlined in the 2014-2019 Management Plan.
• The Neighbourhood Plan area overlaps with two LCAs, ‘WG2 Rother Farmlands’ and ‘WG4
Wealden Greensand’, with a variety of landscape sensitivity issues identified for each LCA
within land management guidelines prepared alongside the assessment for West Sussex.
• There are several TPOs in the Neighbourhood Plan area, which have been designated n the
interest of their amenity value.
• The draft Neighbourhood Plan has defined 19 characteristic viewpoints of local significance
within the parish, which have been identified to ensure that the character of Rogate and Rake
is retained.
• The views across the Neighbourhood Plan area are an important consideration in the planning
process as the scale, height and mass of development can ultimately impact important views
if they are not considered and assessed through the process.
Historic Environment
• The Neighbourhood Plan area contains several nationally designated heritage assets
including one Grade I, three Grade II* and 54 Grade II listed buildings, and three scheduled
monuments.
• It is not currently possible to determine whether the 54 Grade II listed buildings within the
Neighbourhood Plan area are ‘at risk’.
• The Rogate Conservation Area covers the central section of the settlement and was
designated in November 1984 to conserve the recognisable character of the village centre
and its environs.
• As of May 2019, an appraisal or management plan has not been completed for the Rogate
Conservation Area and it is therefore difficult to identify its special architectural and historic
interest.
Environmental Report to accompany the
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Prepared for: Rogate and Rake Neighbourhood Plan Steering Group
AECOM
9
• The HER for West Sussex lists 38 records within Rogate parish, including: Palaeolithic
findspots; Roman findspots; the Chichester to Silchester Roman Road; medieval monasteries,
buildings, earthworks and findspots; post-medieval gardens and parks, limekilns, water wheels
and ironstone workings; the post-medieval to modern Petersfield to Midhurst railway; minepits;
and, a Royal Observer Corps monitoring post.
Land, Soil and Water Resources
• In terms of the location of the best and most versatile agricultural land, a detailed classification
has not been undertaken for most of the Neighbourhood Plan area.
• There is a lack of evidence to ascertain agricultural land quality for the whole of the
Neighbourhood Plan area. National provisional quality datasets indicate the Neighbourhood
Plan area comprises mostly Grade 3 agricultural land, with some small areas of Grade 2
agricultural land. Therefore, as part of a precautionary approach it is noted that there is the
potential for loss of ‘best and most versatile’) agricultural land.
• Within the western section of the Neighbourhood Plan area there is a Zone I ‘Inner Protection
Zone’, Zone II ‘Outer Protection Zone’ and Zone III ‘Total Catchment’ Groundwater SPZ.
• The section of the River Rother flowing through the Neighbourhood Plan area, the ‘Western
Rother Durford’, is classified as having a Good chemical status and a Moderate ecological
status. The RNAGs are attributed to various activiites.
• The Neighbourhood Plan area overlaps with the Soft Sand and Building Stone MSAs.
Population and Community
• The population of Rogate and Rake increased by 2.8% between 2001 and 2011, lower than
the observed increases for Chichester (6.9%), the South East (7.9%) and England (7.9%).
• 33.7% of residents within the Neighbourhood Plan area are within the 60+ age category, higher
than the totals for the South East (23.4%) and England (22.3%)
• Both LSOAs which cover the Neighbourhood Plan area are within the 20% most deprived in
the country for the ‘Living Environment’ and ‘Barriers to Housing and Services’ IMD domains.
• Rogate and Rake has a range of local services, facilities and community assets which serve
the needs of the local residents and play a vital role in supporting the parish’s sense of identity.
Health and Wellbeing
• 84.8% of residents in the Neighbourhood Plan area consider themselves as having ‘very good
health’ or ‘good health’, slightly higher than totals for Chichester (82.6%), the South East of
England (83.7%) and England (81.4%).
• 83.2% of residents in the Neighbourhood Plan area report their activities are not limited, which
is broadly in line with regional and national trends.
• The 2018 Public Health Profile for Chichester states that the rate of people killed or seriously
injured on roads in the district is worse than average.
• The JSNA highlights that annual changes in the 65+ population averaged +2,500 per year
between 2002 and 2017, projecting averages of +4,800 per year between 2017 and 2032.
Transportation
• There are no railway stations within the Neighbourhood Plan area. The nearest mainline railway
station is Liss, located approximately 5 km north-west of Rogate.
• The Traffic and Travel background paper notes a material traffic volume and speed problems
within the villages of Rogate and Rake, and a significant amount of through traffic on the A272
and B2070 roads, despite a traffic calming scheme implemented in 2018.
Environmental Report to accompany the
submission version of the Neighbourhood Plan
Prepared for: Rogate and Rake Neighbourhood Plan Steering Group
AECOM
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• Over 90% of households in the Neighbourhood Plan area have access to at least one car or
van, higher than the totals for Chichester (84.4%), the South East (81.4%) and England (74.2%).
• Fewer economically active residents within the Neighbourhood Plan area choose to walk or
cycle to work in comparison to the regional and national trends.
• 8.4% of economically active residents in the Neighbourhood Plan area work mainly at or from
home, higher than the totals for Chichester (6.3%), the South East (4.5%) and England (3.0%).
SEA Framework
3.6 The issues were then translated into an ‘SEA Framework’. This SEA Framework provides a
methodological framework for the appraisal of likely significant effects on the baseline. The SEA
framework for the Rogate and Rake Neighbourhood Plan is presented below.
Table 3.2: SEA Framework for the Rogate and Rake Neighbourhood Plan
SEA Objective
Assessment questions
Biodiversity and Geodiversity
Protect and enhance
all biodiversity and
geodiversity
Will the option/proposal help to:
• Support the integrity of the European designated sites located
adjacent to the Neighbourhood Plan area?
• Support the status of the nationally and locally designated sites
within and/or adjacent to the Neighbourhood Plan area?
• Protect and enhance priority habitats and species, including those
listed in the annexes of the European Habitats Directive and the
European Birds Directive?
• Achieve a net gain in biodiversity?
• Support enhancements to multifunctional green infrastructure
networks?
• Support access to, interpretation and understanding of biodiversity
and geodiversity?
Climate change
Reduce the
contribution to climate
change made by
activities within the
Neighbourhood Plan
area
Will the option/proposal help to:
• Reduce the number of journeys made?
• Reduce the need to travel?
• Promote the use of sustainable modes of transport, including
walking, cycling and public transport?
• Increase the number of new developments meeting or exceeding
sustainable design criteria?
• Generate energy from low or zero carbon sources?
• Reduce energy consumption from non-renewable resources?
Environmental Report to accompany the
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AECOM
11
SEA Objective
Assessment questions
Support the resilience
of the Neighbourhood
Plan area to the
potential effects of
climate change,
including flooding
Will the option/proposal help to:
• Ensure that inappropriate development does not take place in areas
at higher risk of flooding, considering the likely future effects of
climate change?
• Improve and extend green infrastructure networks in the plan area to
support adaptation to the potential effects of climate change?
• Sustainably manage water run-off, reducing surface water runoff
(either within the plan area or downstream)?
• Ensure the potential risks associated with climate change are
considered through new development in the Neighbourhood Plan
area?
• Increase the resilience of biodiversity in the area to the effects of
climate change, including through enhancements to ecological
networks?
Landscape
Protect and enhance
the character and
quality of landscapes
and villagescapes.
Will the option/proposal help to:
• Conserve and enhance the natural beauty and special qualities of the
South Downs National Park, in line with the Management Plan?
• Conserve and enhance locally important landscape and villagescape
features within the Neighbourhood Plan area?
• Conserve and enhance local diversity and character?
• Protect locally important viewpoints contributing to the sense of
place and visual amenity of the Neighbourhood Plan area?
Historic Environment
Protect, conserve and
enhance heritage
assets within the
Neighbourhood Plan
area
Will the option/proposal help to:
• Conserve and enhance the significance of buildings and structures
of architectural or historic interest, both designated and non-
designated, and their setting?
• Conserve and enhance the special interest, character and
appearance of locally important features and their settings?
• Support the integrity of the historic setting of key buildings of cultural
heritage interest as listed on the West Sussex HER?
• Support access to, interpretation and understanding of the historic
evolution and character of the environment?
• Conserve and enhance archaeological remains, including historic
landscapes?
• Support the undertaking of archaeological investigations and, where
appropriate, recommend mitigation strategies?
Environmental Report to accompany the
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Land, Soil and Water Resources
Ensure the efficient
and effective use of
land.
Will the option/proposal help to:
• Promote the use of previously developed land?
• Avoid the development of the best and most versatile agricultural
land, which in the parish may comprise Grade 1 to 3a agricultural
land?
• Protect the integrity of mineral safeguarding areas?
Promote sustainable
waste management
solutions that
encourage the
reduction, re-use and
recycling of waste.
Will the option/proposal help to:
• Reduce the amount of waste produced?
• Support the minimisation, reuse and recycling of waste?
• Maximise opportunities for local management of waste to minimise
export of waste to areas outside?
• Encourage recycling of materials and minimise consumption of
resources during construction?
Use and manage water
resources in a
sustainable manner.
Will the option/proposal help to:
• Support improvements to water quality?
• Minimise water consumption?
• Protect surface water resources?
Population and Community
Cater for existing and
future residents’ needs
as well as the needs of
different groups in the
community, and
improve access to
local, high-quality
community services
and facilities.
Will the option/proposal help to:
• Encourage and promote social cohesion and encourage active
involvement of local people in community activities?
• Minimise fuel poverty?
• Maintain or enhance the quality of life of existing residents?
• Improve the availability and accessibility of key local facilities?
Reduce deprivation
and promote a more
inclusive and self-
contained community.
Provide everyone with
the opportunity to live
in good quality,
affordable housing,
and ensure an
appropriate mix of
dwelling sizes, types
and tenures.
Will the option/proposal help to:
• Support the provision of a range of house types and sizes?
• Support enhancements to the current housing stock?
• Meet the needs of all sectors of the community?
• Provide quality and flexible homes that meet people’s needs?
• Promote the use of sustainable building techniques, including use of
sustainable building materials in construction?
• Provide housing in sustainable locations that allow easy access to a
range of local services and facilities?
• Support a reduction in the proportion of second homes?
Environmental Report to accompany the
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Prepared for: Rogate and Rake Neighbourhood Plan Steering Group
AECOM
13
Health and Wellbeing
Improve the health and
wellbeing residents
within the
Neighbourhood Plan
area.
Will the option/proposal help to:
• Promote accessibility to a range of leisure, health and community
facilities, for all age groups?
• Address the key challenges identified in the JSNA for West Sussex?
• Provide and enhance the provision of community access to green
infrastructure in accordance with Accessible Natural Greenspace
Standards?
• Protect and enhance access to nature via greenspace and
footpaths?
• Promote the use of healthier modes of travel?
• Improve access to the countryside for recreational use?
• Avoiding any negative impacts to the quality and extent of existing
recreational assets, such as formal or informal footpaths?
Transportation
Promote sustainable
transport use and
reduce the need to
travel.
Will the option/proposal help to…
• Support the key objectives within the Local Transport Plan for West
Sussex?
• Reduce the need to travel through sustainable patterns of land use
and development?
• Enable sustainable transport infrastructure enhancements?
• Facilitate working from home and remote working?
• Improve road safety?
• Reduce the impact on residents from the road network?
Environmental Report to accompany the
submission version of the Neighbourhood Plan
Prepared for: Rogate and Rake Neighbourhood Plan Steering Group
AECOM
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4. What has plan making / SEA involved
up to this point?
Introduction
4.1 The ‘narrative’ of plan-making / SEA up to this point is told within this part of the Environmental
Report.
4.2 A key element of the SEA process is the appraisal of ‘reasonable alternatives’ for the Rogate and
Rake Neighbourhood Plan. The SEA Regulations
7
are not prescriptive as to what constitutes a
reasonable alternative, stating only that the Environmental Report should present an appraisal of
the ‘plan and reasonable alternatives taking into account the objectives and geographical scope
of the plan’.
4.3 In accordance with the SEA Regulations the Environmental Report must include…
• An outline of the reasons for selecting the alternatives dealt with; and
• The likely significant effects on the environment associated with alternatives / an outline of
the reasons for selecting the preferred approach in light of alternatives appraised.
4.4 The following sections therefore describe how the SEA process to date has informed the
preferred development strategy for the Neighbourhood Plan area and potential locations for
development. Specifically, this chapter explains how the Rogate and Rake Neighbourhood Plan’s
development strategy has been shaped through considering alternative approaches for the
location of housing in the Neighbourhood Plan area.
Housing numbers to deliver through the Neighbourhood Plan
4.5 Strategic Policy SD26 (Supply of Homes) of the South Downs Local Plan highlights that
approximately 11 homes are provided for in Rogate. This is in addition to extant planning
permissions granted prior to 1st April 2015 and windfalls. The policy also highlights that
Neighbourhood Plans that accommodate higher levels of housing will be supported by the
National Park Authority providing that they meet local housing need and are in general
conformity with the strategic policies of the development plan.
4.6 To inform the development of the Neighbourhood Plan, a housing needs survey was completed
in June 2017 by Chichester District Council’s housing delivery team on behalf of the parish
council. This highlighted that there was potentially a need for a higher figure, possibly
approaching 30 units. The Housing Needs Survey also identified a need for new housing to
provide one, two- or three-bedroom homes to meet local needs.
4.7 In light of discussions with the National Park Authority, and a recognition of the significant
constraints present locally associated with the National Park, it was agreed that in the region of
11-20 homes should be delivered through the Neighbourhood Plan.
Assessment of reasonable alternatives for site allocations
4.8 To further support the development of a spatial strategy to deliver the 11-20 dwellings
proposed for Rogate and Rake through the Neighbourhood Plan, the Neighbourhood Plan
Steering Group has considered alternative locations for delivering housing in the parish.
7
Environmental Assessment of Plans and Programmes Regulations 2004
Environmental Report to accompany the
submission version of the Neighbourhood Plan
Prepared for: Rogate and Rake Neighbourhood Plan Steering Group
AECOM
15
4.9 To support this process, the Neighbourhood Plan Steering Group has considered potential sites
for allocation through the Neighbourhood Plan for housing. Work to identify sites considered:
• The South Downs National Park Authority’s Strategic Housing Land Availability Assessment
(SHLAA); and
• Further sites identified by the Neighbourhood Plan Steering Group.
4.10 Following this process, 16 sites underwent an initial site assessment. Following a consideration
of the availability, delivery and achievability of the sites, six sites were considered as potentially
appropriate for taking forward through the Neighbourhood Plan.
4.11 These sites are as follows:
Table 4.1: Sites assessed for the purposes of the SEA
8
Name
Size
Site 1: W entrance, Parsonage
0.25 ha
Site 2: Garage units, Parsonage
0.15 ha
Site 3: 1-4 Parsonage
0.20 ha
Site 4: Primrose lane/ Flying Bull
0.5 ha
Site 5: Clayton Court
6.2 ha
Site 6: Renault garage
0.23 ha
4.12 The reasons these six sites were deemed appropriate for further consideration for the
Neighbourhood Plan is set out in the Potential Development Sites Background Paper
accompanying the submission version of the Neighbourhood Plan.
9
4.13 To support the consideration of the suitability of these six sites for potential allocation in the
Neighbourhood Plan, the SEA process has undertaken a separate appraisal of the key
environmental constraints present at each of the sites and potential effects that may arise as a
result of housing development at these locations. In this context the sites have been
considered in relation to the SEA Framework of objectives and decision-making questions
developed during SEA scoping (Chapter 3) and the baseline information. This SEA site
assessment was undertaken separately to the site assessment undertaken by the Rogate and
Rake Neighbourhood Plan Steering Group.
4.14 The locations of the six sites assessed through the SEA process are presented in Figure 4.1
below. The tables which follow present a summary of this appraisal and provide an indication of
each site’s sustainability performance in relation to the seven SEA themes.
8
It should be noted that since these sites were assessed through the SEA process, Site 2 (Garage Units, Parsonage) has
undergone development.
9
Rogate and Rake Neighbourhood Development Plan Potential Development Sites Background Paper
Strategic Environmental Assessment for the
Rogate and Rake Neighbourhood Plan
Environmental Report to accompany the
submission version of the Neighbourhood Plan
Prepared for: Rogate and Rake Neighbourhood Plan Steering Group
AECOM
16
Environmental Report to accompany the
submission version of the Neighbourhood Plan
Prepared for: Rogate and Rake Neighbourhood Plan Steering Group
AECOM
17
SEA site assessment findings
4.15 The tables below present a summary of this assessment and provide an indication of each site’s
sustainability performance in relation to the eight SEA themes.
Table 4.2: Site 1: W entrance, Parsonage
SEA theme
Commentary, Site 1: W entrance, Parsonage
Biodiversity and
Geodiversity
There are no European or nationally designated biodiversity or geodiversity sites within or
adjacent or close to the boundary of the site. The site is within a SSSI impact risk zone for
residential development of 100 units or more and rural residential development of 50 or
more houses outside existing settlements/ urban areas. However, this is higher than the
number of units which would be developed at the site.
There are no BAP Priority Habitats on or in the vicinity of the site.
Housing delivery at this location may facilitate opportunities for biodiversity
enhancements, such as green infrastructure improvements and enhancements to
ecological networks through developer-led contributions.
Climate change
Development of the site will lead to inevitable increases in greenhouse gas emissions from
an increase in the built footprint of the village and an intensification of uses at this location,
These are however unlikely to be significant given the size of the site and the scale of likely
development.
In relation to adapting to the effects of climate change, the site is not located within
identified flood risk zones for fluvial or surface water flooding.
The site is located approximately 190m from Rogate village centre, around which there is
a primary school, a church, a pub, the village hall, a community centre, recreation ground,
village shop and post office. The location is also accessible to the bus links serving the
Neighbourhood Plan area.
An allocation at this location is therefore unlikely to significantly increase the reliance of
privately-owned vehicles for use of these particular services. However, due to limited
services and amenities, use of privately-owned vehicles is likely to continue to be
necessary to access most amenities.
Landscape
The site is located within South Downs National Park which is a nationally designated
landscape. As the site is flat and open countryside lies to the north and north west, there
are some long views in from the National Park to the north and north west.
However, due to the relatively small size of the site and given its location within the existing
built-up area of Rogate, development at this location is less likely to significantly change
the character of the landscape or affect any key viewpoints over the village. The site has
limited exposure to the surrounding landscape as it is screened by existing planting and
development. The A272 borders the northern boundary and Parsonage Estate borders the
east and south boundary.
There will be short views in from the two existing dwellings already located on the site and
other properties located opposite on Parsonage Estate.
Historic
Environment
The nearest nationally designated listed building is located approximately 104m to the
east of the site (Corner Cottage Red Lion Cottage). This is however screened from the
site by the A272 and trees/hedgerows.
The site is located approximately 70m from Rogate Conservation Area. Key heritage
assets within the Conservation Area are screened by trees and roads.
Land, Soil and
Water
Resources
A detailed Agricultural Land Classification for this site has not been undertaken in this
loacation and there is therefore a need to rely on the national ‘Provisional Agricultural Land
Quality’ dataset. The Provisional Agricultural Land Quality dataset shows that the site is
predominantly covered by Grade 3 agricultural land, however, without the subset grading
(3a or 3b) it is not possible to tell at this stage whether the agricultural land is considered
to be ‘best and most versatile’. It is also important to note that the national dataset is of
very low resolution and may not necessarily provide an accurate reflection of the
agricultural land quality within the Neighbourhood Plan area.
The site is located within a nitrate vulnerable zone (NVZ).
Environmental Report to accompany the
submission version of the Neighbourhood Plan
Prepared for: Rogate and Rake Neighbourhood Plan Steering Group
AECOM
18
SEA theme
Commentary, Site 1: W entrance, Parsonage
Population and
Community
Allocation of the site will contribute positively towards meeting local housing needs,
through the delivery of affordable housing.
The site is located at relative proximity to services and facilities in Rogate village centre
(c.190m) which will limit the need for residents to travel for services and facilities provided
here. However, amenities in the village are very limited, and there will be necessity to
travel outside of Rogate to access key services and facilities. In this respect the site is
accessible to the bus services which serve the Neighbourhood Plan area.
Health and
Wellbeing
The site is approximately 480m from Rogate Village Hall and Rogate recreation ground
where there are a number of sports and leisure opportunities.
The site is accessible to open countryside and Public Rights of Way which can be used
for recreational use.
Transportation
The site is located at relative proximity to services and facilities in Rogate village centre
(c.120m) which will limit the need for residents to travel for these services and facilities.
However, the services in Rogate are limited and the use of the private vehicle is likely for
accessing other services and facilities.
The site is in close proximity to a bus stop at the Post Office (c. 160m) which provides
services into Petersfield and Midhurst.
The A272, which is a key route for residents, passes through the village centre. It is unlikely
that development at this site will cause a significant increase in traffic on the route.
Key
Likely adverse effect (without mitigation measures)
Likely positive effect
Neutral/no effect
Uncertain effects
Environmental Report to accompany the
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Table 4.3: Site 2: Garage units, Parsonage
10
SEA theme
Commentary, Site 2: Garage units, Parsonage
Biodiversity and
Geodiversity
There are no European or nationally designated biodiversity or geodiversity sites within or
adjacent or close to the boundary of the site. The site is within a SSSI impact risk zone for
residential development of 100 units or more and rural residential development of 50 or
more houses outside existing settlements/ urban areas. However, this is higher than the
number of units which would be taken forward at the site through the Neighbourhood Plan.
There are no BAP Priority Habitats on or in the vicinity of the site.
Housing delivery at this location may facilitate opportunities for biodiversity
enhancements, such as green infrastructure improvements and enhancements to
ecological networks through developer led contributions.
Climate change
Development of the site will lead to inevitable increases in greenhouse gas emissions from
an increase in the built footprint of the village and an intensification of uses at this location,
although these are unlikely to be significant given the size of the site and the scale of likely
development.
In relation to adapting to the effects of climate change, the site is not located within
identified flood risk zones for fluvial flooding. The southern border of the site is at low risk
from surface water flooding.
The site is located approximately 260m from Rogate village centre, around which there is
a primary school, a church, a pub, the village hall, a community centre, recreation ground,
village shop and post office.
An allocation at this location is therefore unlikely to significantly increase the reliance of
privately-owned vehicles for use of these particular services. However, due to limited
services and amenities, use of privately-owned vehicles is likely to be necessary to
access most amenities.
Landscape
The site is located within South Downs National Park which is a nationally designated
landscape. As the site is relatively flat and open countryside lies to the south, there are
some long views in from the National Park to the south.
However, due to the relatively small size of the site, its previously developed nature, and
given its location within the existing built-up area of Rogate, development at this location
is less likely to significantly change landscape character or impact on any viewpoints over
the village. Other than long views in from the south, the site has limited exposure to the
north, east and west by due to screening of existing development.
However, there are multiple short views in from neighbouring properties.
Historic
Environment
The nearest nationally designated listed building is located approximately 185m to the
east of the site (Corner Cottage Red Lion Cottage). This is however screened from the
site by the existing development and trees.
The site is located approximately 115m from Rogate Conservation Area. Key heritage
assets in the Conservation Area are screened by trees and existing development.
Land, Soil and
Water
Resources
The site, which comprises redundant vehicle garages, comprises previously developed
land. Development of the site will support the efficient use of land.
The site is located within a nitrate vulnerable zone (NVZ).
Population and
Community
Allocation of the site will contribute positively towards meeting local housing needs,
through the delivery of affordable housing.
The site is located at relative proximity to services and facilities in Rogate village centre
(c.260m) which will limit the need for residents to travel for services and facilities provided
here. However, amenities in the village are very limited, and there will be necessity to
travel outside of Rogate to access key services and facilities.
Health and
Wellbeing
The site is approximately 500m from Rogate Village Hall and Rogate recreation ground
where there are a number of sports and leisure opportunities.
10
It should be noted that since these sites were assessed through the SEA process, this site has undergone development.
Environmental Report to accompany the
submission version of the Neighbourhood Plan
Prepared for: Rogate and Rake Neighbourhood Plan Steering Group
AECOM
20
SEA theme
Commentary, Site 2: Garage units, Parsonage
The site is accessible to open countryside and Public Rights of Way which can be used
for recreational use.
Transportation
The site is located at relative proximity to services and facilities in Rogate village centre
(c.260m) which will limit the need for residents to travel for these services and facilities.
However, the services in Rogate are limited and the use of the private vehicle is likely for
accessing other services and facilities. The site is in close proximity to a bus stop at the
Post Office (c. 220m) which provides services into Petersfield and Midhurst.
The A272, which is a key route for residents, passes through the village centre. It is unlikely
that development at this site will cause a significant increase in traffic on the route.
Key
Likely adverse effect (without mitigation measures)
Likely positive effect
Neutral/no effect
Uncertain effects
Environmental Report to accompany the
submission version of the Neighbourhood Plan
Prepared for: Rogate and Rake Neighbourhood Plan Steering Group
AECOM
21
Table 4.4: Site 3: 1-4 Parsonage
SEA theme
Commentary, Site 3: 1-4 Parsonage
Biodiversity and
Geodiversity
There are no European or nationally designated biodiversity or geodiversity sites within or
adjacent or close to the boundary of the site. The site is within a SSSI impact risk zone for
residential development of 100 units or more and rural residential development of 50 or
more houses outside existing settlements/ urban areas. However, this is higher than the
number of units which would be delivered at the site through the Neighbourhood Plan.
There are no BAP Priority Habitats on or in the vicinity of the site.
Housing delivery at this location may facilitate opportunities for biodiversity
enhancements, such as green infrastructure improvements and enhancements to
ecological networks through developer led contributions.
Climate change
Development of the site will lead to inevitable increases in greenhouse gas emissions from
an increase in the built footprint of the village and an intensification of uses at this location,
although these are unlikely to be significant given the size of the site and the scale of likely
development.
In relation to adapting to the effects of climate change, the site is not located within
identified flood risk zones for fluvial or surface water flooding.
The site is located approximately 120m from Rogate village centre, around which there is
a primary school, a church, a pub, the village hall, a community centre, a recreation
ground, village shop and post office.
An allocation at this location is therefore unlikely to significantly increase the reliance of
privately-owned vehicles for use of these particular services. However, due to limited
services and amenities, use of privately-owned vehicles is likely to be necessary to
access most amenities.
Landscape
The site is located within South Downs National Park which is a national designed
landscaped. As the site is flat and open countryside lies to the north and north west,
there are long views in from the National Park to the north and north west.
However, due to the relatively small size of the site and given its location within the existing
built-up area of Rogate, development at this location is less likely to significantly change
landscape character or affect viewpoints over the village. The site has limited exposure to
the surrounding landscape as it is screened by existing planting and development. The
A272 borders the northern boundary and Parsonage Estate borders the east and south
boundary.
There will be short views in from the two existing dwellings already located on the site and
other properties located opposite on Parsonage Estate.
Historic
Environment
The nearest nationally designated listed building is located approximately 43m to the
north east of the site (Corner Cottage Red Lion Cottage). This is however screened from
the site by the A272 corridor and trees/hedgerows.
The Rogate Conservation Area is located adjacent to the site on the eastern border.
Therefore, development on the site has the potential to impact on the setting and key
characteristics of the conservation area in the absence of sensitive design mitigation
measures. However, it is appropriate to note that many key heritage assets in the
Conservation Area are screened from view by the trees located along the site
boundaries.
Land, Soil and
Water
Resources
A detailed Agricultural Land Classification for this site has not been undertaken and there
is therefore a need to rely on the national ‘Provisional Agricultural Land Quality’ dataset.
The Provisional Agricultural Land Quality dataset shows that the site is predominantly
covered by Grade 3 agricultural land, however; without the subset grading (3a or 3b) it is
not possible to tell at this stage whether the agricultural land is considered to be ‘best and
most versatile’. It is also important to note that the national dataset is of very low resolution
and may not necessarily provide an accurate reflection of the agricultural land quality within
the Neighbourhood Plan area.
The site is located within a nitrate vulnerable zone (NVZ).
Environmental Report to accompany the
submission version of the Neighbourhood Plan
Prepared for: Rogate and Rake Neighbourhood Plan Steering Group
AECOM
22
SEA theme
Commentary, Site 3: 1-4 Parsonage
Population and
Community
Allocation of the site will contribute positively towards meeting local housing needs,
including through the delivery of affordable housing.
The site is located at relative proximity to services and facilities in Rogate village centre
(c.120m) which will limit the need for residents to travel for services and facilities provided
here. However, amenities in the village are very limited, and there will be necessity to
travel outside of Rogate to access key services and facilities.
Health and
Wellbeing
The site is approximately 480m from Rogate Village Hall and Rogate recreation ground
where there are a number of sports and leisure opportunities.
The site is accessible to open countryside and Public Rights of Way which can be used
for recreational use.
Transportation
The site is located at relative proximity to services and facilities in Rogate village centre
(c.120m) which will limit the need for residents to travel for these services and facilities.
However, the services in Rogate are limited and for other services use of the private vehicle
is likely to be encouraged.
The A272, which is a key route for residents, passes through the village centre. It is not
likely that development at this site will cause a significant increase in traffic on the route.
The site is in close proximity to a bus stop at the Post Office (c. 100m) which provides
services to Petersfield and Midhurst.
Key
Likely adverse effect (without mitigation measures)
Likely positive effect
Neutral/no effect
Uncertain effects
Environmental Report to accompany the
submission version of the Neighbourhood Plan
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AECOM
23
Table 4.5: Site 4: Primrose lane/ Flying Bull
SEA theme
Commentary, Site 4: Primrose lane/ Flying Bull
Biodiversity and
Geodiversity
The site is within a SSSI impact risk zone for any residential and rural residential
developments with a total net gain in residential units. This is significant given the SSSI
covers the European designated Wealden Heaths Phase II SPA.
There are areas of Broadleaved and Deciduous Woodland BAP Priority Habitat located
close to the site. Whilst direct impacts on the woodland from landtake and fragmentation
are not anticipated, disturbance may take place from new development at this location
from noise, light pollution or trampling from enhanced access. These effects are unlikely
to be significant however given the size of the site.
Climate change
Development of the site will lead to inevitable increases in greenhouse gas emissions from
an increase in the built footprint of the village and an intensification of uses at this location,
although these are unlikely to be significant given the size of the site and the scale of likely
development.
In relation to adapting to the effects of climate change, the site is not located within
identified flood risk zones for fluvial or surface water flooding.
The site is located in Rake village centre, around which there is a primary school, a pub, a
tennis club and the village hall. An allocation at this location is therefore unlikely to
significantly increase the reliance of privately-owned vehicles for use of these particular
services. However, due to the limited services and amenities present in the village, and
poor public transport links from the village, use of privately-owned vehicles is likely to be
necessary to access most amenities.
Landscape
In terms of location, the site adjoins the built-up part of Rake village and would provide a
linear pattern of small-scale continual development.
The site is located within South Downs National Park which is a nationally designated
landscape. As the site slopes down to the south west, it is likely that the site will have an
open aspect from the road and as such, new development at this location would likely
affect local villagescape character. However, the site is small in size and is screened from
open countryside, limiting wider effects on landscape character.
Historic
Environment
The nearest nationally designated listed buildings are located approximately 85m to the
north of the north eastern border of the site (Rake War Memorial) and 35m to the south of
the site on the other side of the B2070 (The Sun Inn). Rake War Memorial is unlikely to be
visible from the site, however the Sun Inn, which is on the opposite site of the B2070, has
the potential to be visible.
The site is not located within or within close proximity to a Conservation Area.
Land, Soil and
Water
Resources
A detailed Agricultural Land Classification for this site has not been undertaken and there
is therefore a need to rely on the national ‘Provisional Agricultural Land Quality’ dataset.
The Provisional Agricultural Land Quality dataset shows that the site is predominantly
covered by Grade 3 agricultural land, however; without the subset grading (3a or 3b) it is
not possible to tell at this stage whether the agricultural land is considered to be ‘best and
most versatile’. It is also important to note that the national dataset is of very low resolution
and may not necessarily provide an accurate reflection of the agricultural land quality within
the Neighbourhood Plan area.
Population and
Community
Allocation of the site will contribute positively towards meeting local housing needs,
through the delivery of affordable housing.
The site is located at relative proximity to services and facilities in Rake village centre
which will limit the need for residents to travel for services and facilities provided here.
However, amenities in the village are very limited, and there will be necessity to travel
outside of Rake to access key services and facilities.
Health and
Wellbeing
Rake village hall and recreation ground is located behind the site.
The site is accessible to open countryside and Public Rights of Way which can be used
for recreational use.
Environmental Report to accompany the
submission version of the Neighbourhood Plan
Prepared for: Rogate and Rake Neighbourhood Plan Steering Group
AECOM
24
SEA theme
Commentary, Site 4: Primrose lane/ Flying Bull
Transportation
The site is located at relative proximity to services and facilities in Rake village centre which
will limit the need for residents to travel for these services and facilities. However, the
services in Rake are limited and for other services use of the private vehicle is likely to be
necessary.
The B2070, which is a key route for residents, passes through the village centre. It is not
likely that development at this site will cause an increase in traffic on this route.
The site is not in close proximity to any bus stops, reflecting a lack of services running
from Rake.
Key
Likely adverse effect (without mitigation measures)
Likely positive effect
Neutral/no effect
Uncertain effects
Environmental Report to accompany the
submission version of the Neighbourhood Plan
Prepared for: Rogate and Rake Neighbourhood Plan Steering Group
AECOM
25
Table 4.6: Site 5: Clayton Court
SEA theme
Commentary, Site 5: Clayton Court
Biodiversity and
Geodiversity
There are no European or nationally designated biodiversity or geodiversity sites within or
adjacent or close to the boundary of the site.
The site is within a SSSI impact risk zone for any residential or rural residential development
of 10 units or more. This relates to the Rake Hangar SSSI.
There are areas of Broadleaved and Deciduous Woodland BAP Priority Habitat located
within the site. Development at this site has the potential to lead to direct impact on the
woodland areas from land take and fragmentation. Additionally, disturbance may take
place from noise, light pollution or trampling from enhanced access.
Climate change
Development of the site will lead to inevitable increases in greenhouse gas emissions from
an increase in the built footprint of the village and an intensification of uses at this location,
although these are unlikely to be significant given the size of the site and the scale of likely
development.
In relation to adapting to the effects of climate change, the site is not located within an
identified flood risk zones for fluvial flooding. However, the northern part of the site is within
an area of low/medium surfacbergere water flooding.
The site is located 1.5km from Rake village centre, around which there is a primary
school, a pub, a tennis club and the village hall. Due to its poor access to services and
amenities, the use of privately-owned vehicles is likely to be necessary to access most
amenities.
Landscape
The site is located within South Downs National Park which is a nationally designated
landscape.
Although, the site is large and flat, it is bordered by roads and woodland meaning that
views into the site are limited. The site is also relatively screened from the open
countryside.
Historic
Environment
The nearest nationally designated listed building is located approximately 215m to the
west of the site (Milestone on south side of the B2070 London Road, immediately east of
entrance to Sussex Gate). This is however screened from the site by London Road and
existing plantation. The site however includes a locally important historic building (Clayton
Court).
The site is not located within a Conservation Area.
Land, Soil and
Water
Resources
A detailed Agricultural Land Classification for this site has not been undertaken and there
is therefore a need to rely on the national ‘Provisional Agricultural Land Quality’ dataset.
The Provisional Agricultural Land Quality dataset shows that the site is covered by Non-
agricultural land, implying that development at this site will not have an impact on
agricultural land quality. However, it is important to note that the national dataset is of very
low resolution and may not necessarily provide an accurate reflection of the agricultural
land quality within the Neighbourhood Plan area.
The majority of the site is located within a nitrate vulnerable zone (NVZ).
Population and
Community
Allocation of the site will contribute positively towards meeting local housing needs,
through the delivery of affordable housing.
However, the site is not located within either Rogate or Rake village centres. It is located
1.5km from Rake village centre and therefore it will increase the need for residents to travel
for services and facilities.
Health and
Wellbeing
The site is accessible to open countryside and Public Rights of Way which can be used
for recreational use.
Environmental Report to accompany the
submission version of the Neighbourhood Plan
Prepared for: Rogate and Rake Neighbourhood Plan Steering Group
AECOM
26
SEA theme
Commentary, Site 5: Clayton Court
Transportation
The site is not within ready proximity to services and facilities in Rake or Rogate village
centre which will increase the need for residents to travel for these services and facilities.
It is within the settlement of Hill Brow which has limited facilities.
The B2070 which is a key route for residents passes through the village centre. It is not
likely that development at this site will cause a significant increase in traffic.
Hill Brow has some public transport links with two bus stops on Hill Brow Road located
approximately 85m from the site. Stagecoach South provide services to Petersfield and
Alton from these stops four times a day.
Key
Likely adverse effect (without mitigation measures)
Likely positive effect
Neutral/no effect
Uncertain effects
Environmental Report to accompany the
submission version of the Neighbourhood Plan
Prepared for: Rogate and Rake Neighbourhood Plan Steering Group
AECOM
27
Table 4.7: Site 6: Renault garage
SEA theme
Commentary, Site 6: Renault garage
Biodiversity and
Geodiversity
There are no European or nationally designated biodiversity or geodiversity sites within or
adjacent or close to the boundary of the site. The site is within a SSSI impact risk zone for
residential development of 100 units or more and rural residential development of 50 or
more houses outside existing settlements/ urban areas. However, this is higher than the
number of units which would be developed at the site.
The site is adjacent to an area of Deciduous Woodland BAP Priority Habitat, which is
located to the south of the site. Whilst direct impacts on the woodland areas from land
take and fragmentation are not anticipated, disturbance may take place from noise, light
pollution or trampling from enhanced access.
Climate change
Development of the site will lead to inevitable increases in greenhouse gas emissions from
an increase in the built footprint of the village and an intensification of uses at this location,
although these are unlikely to be significant given the size of the site and the scale of likely
development.
In relation to adapting to the effects of climate change, the site is not located within
identified flood risk zones for fluvial or surface water flooding.
The site is located approximately 150m from Rogate village centre, around which there is
a primary school, a church, a pub, the village hall, a community centre, recreation ground,
village shop and post office. An allocation at this location is therefore unlikely to
significantly increase the reliance of privately-owned vehicles for use of these particular
services. However, due to limited services and amenities, the use of privately-owned
vehicles is likely to take place for access to most amenities.
Landscape
The site is located within South Downs National Park which is a nationally designated
landscape.
Generally, the site has limited exposure to the surrounding landscape as it is screened by
existing planting and development. The A272 borders the northern boundary and
plantation borders the remaining boundaries.
There are no short views in from existing dwellings.
The current site detracts from local villagescape quality. As such well-designed
development has the potential to enhance local character.
Historic
Environment
The nearest nationally designated listed buildings are located approximately 77m to the
north west of the site (Church House and The Forecourt Railings at Church House to the
south of the House). These are however screened from the site by the A272 corridor and
trees/hedgerows.
The Rogate Conservation Area is located adjacent to the site on the western border.
Therefore, development on the site has the potential to impact on the setting and special
qualities of the conservation area in the absence of sensitive design mitigation measures.
However, it is useful to note that 1) key heritage assets in the Conservation Area are
screened from view by the trees located along the site boundaries 2) the site currently
detracts from the setting of the Conservation Area. As such well-designed development
has the potential to lead to positive effects on the historic environment.
Land, Soil and
Water
Resources
The site comprises previously developed land. Development of the site will therefore
support the efficient use of land.
The site is located within a nitrate vulnerable zone (NVZ).
Population and
Community
Allocation of the site will contribute positively towards meeting local housing needs,
through the delivery of affordable housing.
The site is located at relative proximity to services and facilities in Rogate village centre
(c.150m) which will limit the need for residents to travel for services and facilities provided
here. However, amenities in the village are very limited, and there will be necessity to
travel outside of Rogate to access key services and facilities.
Environmental Report to accompany the
submission version of the Neighbourhood Plan
Prepared for: Rogate and Rake Neighbourhood Plan Steering Group
AECOM
28
SEA theme
Commentary, Site 6: Renault garage
Health and
Wellbeing
The site is approximately 480m from Rogate Village Hall and Rogate recreation ground
where there are a number of sports and leisure opportunities.
The site is accessible to open countryside and Public Rights of Way which can be used
for recreational use.
Transportation
The site is located at relative proximity to services and facilities in Rogate village centre
(c.150m) which will limit the need for residents to travel for these services and facilities.
However, the services in Rogate are limited and for other services use of the private vehicle
is likely to be necessary.
The A272, which is a key route for residents passes through the village centre. It is not
anticipated that development at this site will cause a significant increase in traffic on this
route.
The site is in close proximity to a bus stop at St Bartholomew's Church (c. 120m) which
provides services into Petersfield and Midhurst.
Key
Likely adverse effect (without mitigation measures)
Likely positive effect
Neutral/no effect
Uncertain effects
Environmental Report to accompany the
submission version of the Neighbourhood Plan
Prepared for: Rogate and Rake Neighbourhood Plan Steering Group
AECOM
29
Table 4.8: Summary of SEA site appraisal findings
Site
Biodiversity
and
geodiversity
Climate
change
Landscape
Historic
environment
Land, soil
and water
resources
Population
and
community
Health
and
wellbeing
Transport
Site 1
Site 2
Site 3
Site 4
Site 5
Site 6
Key
Likely adverse effect (without mitigation measures)
Likely positive effect
Neutral/no effect
Uncertain effects
Environmental Report to accompany the
submission version of the Neighbourhood Plan
Prepared for: Rogate and Rake Neighbourhood Plan Steering Group
AECOM
30
Current approach in the Neighbourhood Plan and the
development of Neighbourhood Plan policies
Current approach in the Neighbourhood Plan
4.16 The submission version of the Neighbourhood Plan allocates two of the above sites for
residential development. These are as follows:
• Renault Garage and adjoining Bungalow South of A272 : Nine houses and either two flats or
two workshops.
• Land on North side of B2070 London Road west of Flying Bull PH, Rake: Four houses.
4.17 The allocation of these sites follows consideration of the findings of the site assessments
undertaken for the Neighbourhood Plan, extensive community consultation and a consideration
of the types of development which could be taken forward on each site in conjunction with
Neighbourhood Plan objectives.
Neighbourhood Plan policies
4.18 To support the implementation of the vision and objectives for the Neighbourhood Plan, the
submission version of the Rogate and Rake Neighbourhood Plan puts forward 18 policies to
guide new development within the Neighbourhood Plan area. These were developed following
extensive community consultation and evidence gathering and are listed below in Table 4.12.
Table 4.9: Rogate and Rake Neighbourhood Plan policies
Policy Reference
Policy Name
Natural Environment
Policy NE1
To Conserve, Protect and Enhance the Natural Environment
Built Environment
Policy BE1
Locally Distinctive Design within the Parish
Policy BE2
Conservation Area
Housing
Policy H1
Settlement Boundary
Policy H2
Residential Development in the Open Countryside
Policy H3
Conversion of Existing Residential Properties
Policy H4
Replacement Dwellings, Extensions and Annexes
Allocation of Sites for Development
Policy H5
Local Housing Needs
Policy H6
Allocation of Sites Suitable for Development
Policy H6 (continued)
Allocation of Sites Suitable for Development
Local Economy and Work
Policy EW1
Supporting the Rural Economy
Transport and Travel
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Policy Reference
Policy Name
Policy T1
Encouraging Sustainable Travel
Policy T2
Safety
Policy T3
Parking
Energy
Policy E1
Renewable Energy
Community Health, Wellbeing and Amenity
Policy CH1
Community Facilities
Policy CH2
Development of Community Facilities
Policy CH3
Public Open Spaces, Village Greens and Local Green Space
4.19 These policies have been assessed in Chapter 5.
Environmental Report to accompany the
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32
5. What are the appraisal findings at
this current stage?
Introduction
5.1 The aim of this chapter is to present appraisal findings and recommendations in relation to the
submission version of the Neighbourhood Plan. This chapter presents:
• An appraisal of the current version of the Neighbourhood Plan under the eight SEA theme
headings; and
• The overall conclusions at this current stage and recommendations for the next stage of
plan-making.
Approach to the appraisal
5.2 The appraisal is structured under the eight SEA themes taken forward for the purposes of the
SEA.
5.3 For each theme, ‘significant effects’ of the current version of the plan on the baseline are
predicted and evaluated. Account is taken of the criteria presented within Schedule 2 of the
Regulations. So, for example, account is taken of the probability, duration, frequency and
reversibility of effects as far as possible. These effect ‘characteristics’ are described within the
assessment as appropriate.
5.4 Every effort is made to identify / evaluate effects accurately; however, this is inherently
challenging given the high-level nature of the plan. The ability to predict effects accurately is
also limited by understanding of the baseline and the nature of future planning applications.
Because of the uncertainties involved, there is a need to exercise caution when identifying and
evaluating significant effects and ensure all assumptions are explained. In many instances it is
not possible to predict significant effects, but it is possible to comment on merits (or otherwise)
in more general terms.
Biodiversity and Geodiversity
5.5 The Neighbourhood Plan area contains a rich variety of habitats that support biodiversity. The
Wealden Heaths Phase II Special Protection Area (SPA) lies adjacent to the northern boundary of
the Neighbourhood Plan area and the Woolmer Forest Special Area of Conservation (SAC) is
located approximately 1.5km to the north. The effects of the development proposed through
the Neighbourhood Plan on European designated sites will be a crucial consideration and has
also informed the Habitat Regulations Assessment (HRA) accompanying the Neighbourhood
Plan. Alongside the European designated sites, the Neighbourhood Plan area contains three
nationally designated Sites of Special Scientific Interest (SSSIs) and several locally designated
sites (Local Wildlife Sites and Sites of Nature Conservation Interest) as well as a variety of
identified Priority Habitats including a significant presence of Ancient Woodland, Deciduous
Woodland and Good Quality Semi-improved Grassland.
5.6 In relation to the potential effects on the internationally designated SPA and SAC, the screening
assessment undertaken through the HRA
11
process highlighted that the potential for negative
effects from residential development by means of recreational pressure and disturbance, air
quality impacts and urbanisation should be considered in more detail. The subsequent
Appropriate Assessment determined that the appropriate policy measures are in place to
11
AECOM (October 2019) Habitat Regulations Assessment, Rogate and Rake Neighbourhood Plan
Environmental Report to accompany the
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33
ensure there are no impacts to the integrity of European sites due to increased residential
development from these pathways. As such, no significant effects as a result of the
Neighbourhood Plan in relation to the internationally designated biodiversity sites are
anticipated.
5.7 More broadly, the Neighbourhood Plan sets out a number of provisions for protecting and
enhancing biodiversity. Policy NE1 (To Conserve, Protect and Enhance the Natural Environment)
seeks to minimise any adverse effects on biodiversity – designated and non-designated –
including through the prevention of increased risk of soil, air, water, light or noise pollution. In
recognition of the sensitivity of European Designated sites, Policy NE1 further requires
residential development in the north of the parish to deliver a project-specific HRA screening
determining any Likely Significant Effects (LSEs) and mitigation strategies.
5.8 The allocation site at Renault Garage (Policy H6) in Rogate is located adjacent to Deciduous
Woodland priority habitat which connects with the designated biodiversity habitats in the south
along the River Rother. The allocation site at London Road (west of the Flying Bull) also is
located close to Deciduous Woodland priority habitat along the roadside border. There is a
strong presence of woodland habitat along the London Road, which connects to nearby Local
Wildlife Sites and a Site of Nature Conservation Interest north in the adjacent Parish of Liss.
5.9 Development at these sites therefore have the potential for minor long-term negative effects
either through habitat loss/ fragmentation, increased disturbance, and noise, light and air
pollution. As such, it will be important for development to protect ecological connectivity, and
there are opportunities to enhance habitats and habitat connectivity at both sites.
5.10 These issues are recognised by the Neighbourhood Plan. In this respect Policy NE1 (To
Conserve, Protect and Enhance the Natural Environment) seeks to ensure that development
minimises any impact on biodiversity and contributes to and enhances the natural environment
in the long-term. It also seeks to ensure that key elements of ecological networks such as
wetlands, water systems, heathland, open spaces, notable trees and geodiversity are conserved
and enhanced. The site allocation policy H6 further identifies that development at the London
Road site should be informed by an “Arboricultural Impact Assessment, Arboricultural Method
Statement and associated Tree Protection Plan”.
5.11 Overall, the policy framework provided through the Neighbourhood Plan is likely to support the
protection of biodiversity and facilitate the effective functioning of ecosystem services in the
Neighbourhood Plan area. It will therefore help ensure that development does not lead to
significant effects in relation to biodiversity and geodiversity with the potential for long-term
minor positive effects. Despite this, it is recognised that more could be done to promote
biodiversity net gain, as a core principle emerging from the NPPF and 25-year Plan for the
Environment. In this respect, it is acknowledged that the provisions of the South Downs Local
Plan have a close focus on environmental net gain, and as such will help provide the framework
for supporting enhancements to habitats and ecological networks in the Neighbourhood Plan
area.
Climate Change
5.12 It is recognised that a significant contributor to emissions in the Neighbourhood Plan area is the
transport sector, with a prevalent reliance on the private vehicle. In terms of climate change
mitigation, it will be important for development planned through the Neighbourhood Plan to
ensure that opportunities to access sustainable transport modes and active travel routes are
maximised. However, the public transport services in parts of the Neighbourhood Plan area are
poor, with access in the north of the Neighbourhood Plan area extremely limited (with no bus
service in Rake). Considering that the housing needs span the whole of the Plan area, alongside
the rural nature of the Parish (where residents are likely to look to larger towns such as
Petersfield and Liphook (and the smaller settlement of Liss) to access a wider range of services,
Environmental Report to accompany the
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34
facilities and employment opportunities) any growth in the Neighbourhood Plan area is deemed
likely to increase car usage to some degree with the potential for residual minor long-term
negative effects in relation to climate change mitigation.
5.13 The Neighbourhood Plan recognises these constraints by seeking to promote sustainable
access and active travel opportunities. Policy T1 (Encouraging Sustainable Travel) seeks
incorporation of “attractive links to the nearest point on the public right-of-way network and
local footway networks” in new development, and exploitation and enhancement of the cycle
network and existing public transport links. The policy further seeks to ensure that development
will not impact on the “amenity value of public rights-of-way, other public non-motorised routes
or publicly accessible land.”
5.14 In terms of the allocations the Renault Garage and Bungalow are accessible to the bus services
running along the A272 (including to Midhurst and Petersfield). The further allocation site at
London Road is located at Rake with no immediate access to bus services. However the site is
in closer proximity to the rail network at Liss. Overall, as identified above, development at the
allocation sites is likely to increase car reliance to some degree, however the minimal level of
development ensures that the negative effects arising in this respect are minor.
5.15 With respect to climate change mitigation, the Neighbourhood Plan also seeks to improve
renewable energy generation within the parish, with Policy E1 (Renewable Energy) supporting
small-scale renewable energy projects “where they can be delivered without permanent
detriment to the local environment”, particularly small solar panel installations and biomass
energy systems. Policy BE1 (Locally Distinctive Design within the Parish) further requires high-
quality development using “sustainable materials and build techniques, including where
appropriate, opportunities for carbon reduction.” These policies support energy efficiency and
climate change mitigation in the long-term with the potential for minor positive effects.
5.16 With regards to climate change adaptation, areas close to the River Rother bordering the parish
in the south are the highest flood risk areas in the Neighbourhood Plan area, and the growth
strategy proposed through the Neighbourhood Plan avoids development within these locations.
Surface water drainage and sewer flooding is also a risk for some parts of the Neighbourhood
Plan area, however the growth strategy proposed through the Neighbourhood Plan also avoids
these areas. In this respect, no significant negative effects are considered likely with regards to
flood risk, and overall residual neutral effects are anticipated at this stage.
5.17 The Neighbourhood Plan provides support for green infrastructure enhancements and
connectivity, and identifying and protecting existing and new Public Open Spaces, Village
Greens and Local Green Spaces through Policy CH3. This will help increase the resilience of the
landscape and villagescape to the likely impacts of climate change, and support the resilience of
ecological networks.
5.18 Overall, no significant effects are identified with regards to climate change mitigation, however
residual minor long-term negative effects are anticipated as a result of minor increases in car
usage in the Neighbourhood Plan area. In the absence of any significant transport
improvements, a continued reliance on the private vehicle is considered likely. It will be
important for the Neighbourhood Plan to recognise that small-scale and piecemeal
development is unlikely to effect any real change in terms of a modal shift, and targeted
interventions may be required in the future to avoid cumulative negative impacts in terms of
accessibility in the Plan area. Minor positive effects are also anticipated through the
Neighbourhood Plan’s promotion of renewable energy generation and sustainable building
techniques – including the use of sustainable materials. The Neighbourhood Plan is also likely to
lead to minor positive effects in relation to climate change adaptation given proposed green
infrastructure enhancements.
Environmental Report to accompany the
submission version of the Neighbourhood Plan
Prepared for: Rogate and Rake Neighbourhood Plan Steering Group
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Landscape
5.19 The Neighbourhood Plan area is located wholly within the South Downs National Park which is
recognised for seven Special Qualities;
• Diverse, inspirational landscapes and breath-taking views
• A rich variety of wildlife and habitats including rare and internationally important species
• Tranquil and unspoilt places
• An environment shaped by centuries of farming and embracing new enterprise
• Great opportunities for recreational activities and learning experiences
• Well-conserved historical features and a rich cultural heritage
• Distinctive towns and villages, and communities with real pride in their area
5.20 Any new development in the Neighbourhood Plan area will need to protect these qualities and
the integrity of the nationally designated landscape character.
5.21 A major landscape characteristic which the community seeks to protect in new development is
the sense of tranquillity. This is reflected in the Neighbourhood Plan’s vision which identifies that
“the quality, tranquillity and character of the natural and built environments will be safeguarded
and improved for future generations”. The parish also rates highly as one of the most important
dark night skies areas within the overall SDNPA Dark Night Sky designation.
5.22 During development of the Neighbourhood Plan the community has identified that it does not
wish to see any significant change to the rural and relatively unspoilt character of the parish. As
such this is reflected as a primary planning consideration featuring in the Neighbourhood Plan.
This is acknowledged through a spatial strategy which seeks domestic scale development,
reflecting landscape capacity, including in terms of the ability to integrate development into the
rural character of the existing settlements. In this context the plan seeks to deliver 15 new
dwellings across two sites.
5.23 The site allocation Policy H6 (Allocation of Sites Suitable for Development) identifies the Renault
Garage site and Bungalow site in Rogate as the largest allocation delivering around 11 new
homes. The site is located adjacent to the Rogate Conservation Area where development is
considered to have the potential for both positive and negative effects on townscape character
in the rural landscape setting. It is however recognised that, as a brownfield site currently used
as a garage, redevelopment of the site delivering a “sympathetic village housing scheme” could
enhance the views from the parkland opposite as well as views at the entrance to the village
from the east. In this respect, it is considered that development at the Renault Garage site has
good potential to deliver long-term positive effects overall due to its current negative
contribution to villagescape character in the area.
5.24 The second allocation site is a greenfield site located on London Road in Rake. Any new
housing at the site will develop an area of previously undeveloped land in the villagescape with
the potential for negative effects with regards to this SEA theme. However, the small-scale
development of 4 new homes should ensure that these effects are minor. Policy H6 identifies
that development at this site should “include soft landscaped boundaries to the rear and side of
the site” and Arboricultural Impact Assessment, which will further support the minimisation of
negative effects.
5.25 Most of the policies proposed through the Neighbourhood Plan are underpinned by landscape
character and its special qualities as a local response to ensure that development integrates
and enhances the key landscape elements that contribute to its overall quality of space. Policy
NE1, as the overarching policy for the natural environment, requires all new development to
conserve and where possible enhance “natural beauty, landscape and scenic beauty”. Policy
Environmental Report to accompany the
submission version of the Neighbourhood Plan
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BE1 further requires development to avoid any “high-powered lighting or external security
lighting, unprotected upward-facing fenestration, and large areas of glazing facing open
countryside.” Under this policy design will need to demonstrate consideration of; the immediate
setting, the space between buildings, its orientation within the plot, the design, scale, roof
structure and built form of any surrounding buildings, the treatment of boundaries and any
related village or hamlet setting and local characterising views. The Neighbourhood Plan also
identifies the key local characterising views in Figure 4.1 that in accordance with the policy
framework should be retained and protected in development.
5.26 Considering the policy framework, it is highly likely that the redevelopment of the Renault Garage
site will lead to minor long-term positive effects with regards to landscape and townscape
character. The additional minor loss of greenfield land in the rural landscape of Rake is however
considered likely to lead to long-term minor negative effects. However given the policy
provisions of the Neighbourhood Plan, the plan is likely overall to lead to long-term positive
effects with regards to landscape and villagescape character in the Neighbourhood Plan area.
Historic Environment
5.27 The character of the Neighbourhood Plan area is largely influenced by its rich historic
environment, including its national and locally designated assets of cultural heritage interest as
well as locally identified non-designated assets.
5.28 The growth strategy for the Neighbourhood Plan proposes the redevelopment of the Renault
Garage site (Policy H6) in Rogate, which is located adjacent to the Rogate Conservation Area.
Effects on the setting of the conservation area ultimately depend upon the design, layout and
massing on site.
5.29 Alongside the provisions of the NPPF and South Downs National Park Local Plan which provide
protections for both designated and non-designated heritage assets and their settings, Policy
BE2 (Conservation Area) of the Neighbourhood Plan requires development to demonstrate that
“it will conserve or enhance the character of the designation” in relation to the conservation
area. In this respect the policy seeks to ensure development takes account of the overall
character of the conservation area, public rights of way and through routes, historic patterns of
thoroughfares and open spaces, distinctive elements including building materials and features
such as walls and gateways, the mix of building types, and the retention of existing views. The
policy therefore provides an additional layer of locally specific detail that will support the delivery
of positive effects in any new development within or surrounding the Conservation Area. It is
also recognised that with its current land use as a garage, redevelopment of the site delivering a
“sympathetic village housing scheme” could enhance the views from the parkland opposite –
parkland that was formerly part of the historic parkland of Rogate Lodge – as well as views at the
entrance to the village from the east. As such, it is considered that development at the Renault
Garage site has good potential to deliver long-term minor positive effects overall in relation to
the setting of the historic environment at this location.
5.30 The Neighbourhood Plan proposes one site allocation in Rake. Whilst the site is not known to
contain any designated heritage assets, it is located opposite to the Grade II listed Sun Inn
Public House. Development has the potential to affect the setting of the listed building both
positively and negatively, which will ultimately be dependent upon design, layout and massing. In
this respect Policy BE1 (Locally Distinctive Design within the Parish) provides protection against
negative effects arising by requiring development to demonstrate high-quality design that takes
account of “the architectural or historic importance of, and the conservation of the significance
of, any historic dwellings”. As a result, the development of around four dwellings at the London
Road site in Rake is not considered likely to lead to any significant negative effects.
5.31 Overall, the limited growth proposed through the Neighbourhood Plan is not considered likely to
lead to any significant negative effects in relation to the historic environment. The
Environmental Report to accompany the
submission version of the Neighbourhood Plan
Prepared for: Rogate and Rake Neighbourhood Plan Steering Group
AECOM
37
redevelopment of the Renault Garage site, given its contribution to poor quality villagescape and
the policy mitigation provided, is also considered to have good potential to positively affect the
setting of the historic environment (including the conservation area. As a result, minor long-
term positive effects are considered likely overall in relation to the Historic Environment SEA
theme.
Land, Soil and Water Resources
5.32 The Neighbourhood proposes (through Policy H6) two sites for development which together will
deliver around 15 new homes. The larger of the two development sites is the Renault Garage
site at Rogate. Development at this site will utilise previously developed land with the potential
for minor long-term positive effects with regards to the efficient use of land. Development at the
second of the two site allocations, at London Road in Rake, will result in the loss of greenfield
land with the potential for long-term negative effects with regards to the efficient use of land.
However, it is recognised that development at the site is small-scale (delivering around 4 new
homes), so the negative effects are anticipated to be minor.
5.33 The settlement boundary designated under Policy H1 will ensure that windfall and future
development is contained within Rogate village area, and the remainder of the Neighbourhood
Plan area will continue to be protected for uses appropriate to the countryside. The use of
settlement boundaries in this respect provides long-term support in limiting the loss productive
agricultural land within the Neighbourhood Plan area.
5.34 The greenfield land at the London Road site allocation lies within an area broadly identified as
Grade 3 agricultural land in provisional national datasets.
12
Whilst the sub-grade (3a or 3b) is
unknown, a precautionary approach is taken which recognises the potential for minor but
permanent loss of best and most versatile agricultural land, and thus permanent minor negative
effects in relation to soil resources.
5.35 The Neighbourhood Plan area lies within Mineral Safeguarded Areas for both soft sand and
building stone. The larger of the two site allocations proposed within the Neighbourhood Plan
will utilise previously developed land within the settlement boundary of Rogate and as such no
significant negative effects are anticipated in relation to mineral resources. Small-scale growth
at Rake is also unlikely to significantly hinder future access to mineral resources, however further
consultation with the County Council may be required prior to development at the sites.
5.36 Neither of the two site allocations are in proximity of the main waterbodies in the area, and
neither site is subject to flood risk constraints (fluvial or surface water). Considered alongside
the policy framework provided through the SDNP Local Plan and NPPF, which includes the
promotion of Sustainable Drainage Systems, the overall effects of development on the water
environment are considered likely to be residual neutral.
5.37 Proposed Policy NE1 (To Conserve, Protect and Enhance the Natural Environment) expects
develop to enhance the natural environment, including by “preventing any new development
from contributing to, or increasing the risk of, soil, air, water, light or noise pollution or land
instability”. This provides an element of protection for the natural resources under consideration
in this SEA theme. Policy BE1 (Locally Distinctive Design within the Parish) also requires high-
quality development using sustainable materials and build techniques, which will contribute to
waste reduction and recycling of materials on-site. Both policies are considered supportive of
maintaining land, soil and water quality and minimising waste, with the potential for long-term
positive effects with respect to this SEA theme.
5.38 Overall, the Neighbourhood Plan directs the majority of growth over the Plan period to
previously developed land, supporting the efficient use of land. The redevelopment of the
12
Natural England (2018) Agricultural Land Classification map London and the South East (ALC007) [online] available at <
http://publications.naturalengland.org.uk/publication/141047?category=5954148537204736> last accessed [13/05/19]
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Prepared for: Rogate and Rake Neighbourhood Plan Steering Group
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Renault Garage site is considered likely to lead to overall minor positive effects in this respect.
Whilst some minor long-term negative effects have the potential to take place as a result of
limited losses of greenfield land, this is unlikely to be significant.
Population and Community
5.39 The Neighbourhood Plan proposes the development of around 15 new homes across two sites.
This will contribute to meeting the local housing needs of the Neighbourhood Plan area, with the
potential for long-term positive effects. The largest of these allocations is in Rogate at the
Renault Garage site, within the settlement boundary with good access to the village centre and
bus services available there. The second allocation is a local response to housing needs in Rake
that seeks to deliver around four new homes. Given this is anticipated to meet locally defined
objectively assessed housing need, it is assumed that this growth quantum will help meet
housing needs arising locally.
5.40 Supporting the delivery of housing for local needs, Policy H5 seeks to ensure that residential
development delivers an appropriate mix of housing types and tenures in accordance with the
most up-to-date evidence available, and in consultation with SDNPA, Rogate Parish Council, the
Housing Authority and the local Rural Housing Enabler where applicable. The policies will
therefore help ensure that development delivers a range of types and tenures in the
Neighbourhood Plan area which reflect local requirements, with the potential for long-term
positive effects for communities.
5.41 A prevalent local response to meeting changing housing needs includes the alteration and
extension of existing dwellings, and this is recognised as a factor that affects the housing
balance. In this context Policy H3 (Conversion of Existing Residential Properties) supports
proposals that that involve conversions to smaller units – supporting the identified need for this
type of housing in the Neighbourhood Plan area. Policy H4 (Replacement Dwellings, Extensions
and Annexes) also seeks to ensure that new annexes remain ancillary to the main property in
perpetuity. This responds to an increasing recent trend for multi-generational living.
5.42 Accessibility to services and facilities is a key influence on the quality of life of residents and
community cohesion. The rural nature of much of the Neighbourhood Plan area is reflected in
its limited service and facility provision, and whilst the Neighbourhood Plan area has some local
services that may meet day-to-day needs, it is likely that new residents will continue to look to
surrounding settlements, such as Petersfield, Liphook and Liss to access a wider range of
services and facilities. As such poor accessibility to public transport is acknowledged as an
issue for the local community, with the Neighbourhood Plan recognising that “heavy reliance has
to be placed on travel by car because of the settlement patterns of the Parish, but this
disadvantages those without a car, such as the less affluent, young adults and the elderly, and
risks increasing their isolation.” One of the two allocations sites (Renault Garage) is located
within Rogate with access to the available bus services and village centre. The other allocation
site (at London Road) is located at Rake with no immediate access to bus services and limited
access to services and facility provisions, but in closer proximity to rail access at Liss.
5.43 Accessibility will be further supported by the Neighbourhood Plan’s focus on supporting
existing and new community provision. A key policy in this regard is Policy CH1 (Community
Facilities) which identifies a number of key community facilities in the Neighbourhood Plan area
and supports their extension and enhancement. This is further supported by Policy CH2
(Development of Community Facilities) which highlights that development proposals resulting in
the loss or conversion of a community facility will only be supported if the existing use is
demonstrated to be not now viable and alternative provision is available in the vicinity or
accessible by sustainable mean. The Neighbourhood Plan also highlights a range of community
projects which will be supported through the Neighbourhood Plan (through “Community
Projects: Community Health, Well-being and Amenity”).
Environmental Report to accompany the
submission version of the Neighbourhood Plan
Prepared for: Rogate and Rake Neighbourhood Plan Steering Group
AECOM
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5.44 Overall therefore, it is considered that the Neighbourhood Plan is likely to lead to long term
positive effects for community vitality in Rogate and Rake. This is given the Neighbourhood
Plan’s focus on delivering a range of new housing to meet locally identified needs, and the
protection and enhancement of community facilities.
Health and Wellbeing
5.45 There is now robust evidence that access to the natural environment improves people’s health
and wellbeing through encouraging healthy outdoor recreation and relaxation. The benefits to
emotional wellbeing and mental health resulting from close contact with the natural environment
are well-documented. Given the location of the Neighbourhood Plan area, any new
development is provided with excellent access to the surrounding National Park landscape. This
will support long term positive effects on health and wellbeing through facilitating good access
to the amenity, leisure and recreational value of the countryside. The Neighbourhood Plan also
has a strong focus on maintaining and improving access to open spaces through the
Neighbourhood Plan. This includes through providing support for green infrastructure
enhancements and connectivity, protecting two village greens and commons, and designating
11 Local Green Spaces which will be safeguarded from development (Policy CH3).
5.46 The Neighbourhood Plan seeks to enhance active travel opportunities. In this respect Policy T1
(Encouraging Sustainable Travel) seeks incorporation of “attractive links to the nearest point on
the public right-of-way network and local footway networks” in new development, and the use
and enhancement of the cycle network and existing public transport links. The policy further
seeks to ensure that development will not impact on the “amenity value of public rights-of-way,
other public non-motorised routes or publicly accessible land”. Whilst effective change is
limited by the small-scale of growth proposed, the measures to improve active travel
opportunities will ultimately support healthier lifestyles with the potential for long-term minor
positive effects.
5.47 In terms of health provision, no health facilities are located within the Neighbourhood Plan area,
and it is likely that new residents will continue to access health facilities in the nearby
settlements of Petersfield and Liphook and Liss.
5.48 Overall, the Neighbourhood Plan sets out a range of provisions which will enhance health and
wellbeing within the Neighbourhood Plan area. This will lead to long term positive effects in
Rogate and Rake.
Transportation
5.49 As a rural parish, transportation presents a key obstacle in terms of sustainable development.
One of the key issues is a prevalent reliance on the private vehicle, with this being the choice
mode of transport for most residents. There are no railway stations within the Neighbourhood
Plan area, and residents generally travel by car to access the stations at Petersfield, Liss and
Liphook. Bus services are only available in Rogate along the A272.
5.50 Whilst a rural setting is considered ideal for active travel opportunities, it is also recognised that
within Rogate village centre there are no continuous footpaths, limited parking and inadequate
space for HGVs to pass each other despite heavy road usage. The A272 is a busy road which is
a key route through the South Downs National Park between Winchester, Petersfield and
Midhurst. These issues contribute to inhibiting free pedestrian and cycle movement and detract
from what should be a pleasant environment for active travel.
5.51 Furthermore, it is also recognised that road widths make the country roads in the
Neighbourhood Plan area hazardous for walkers, riders and cyclists who are often trying to
access the footpaths or bridleways. As such, through the development of the Neighbourhood
Environmental Report to accompany the
submission version of the Neighbourhood Plan
Prepared for: Rogate and Rake Neighbourhood Plan Steering Group
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Plan, residents have indicated considerable interest in improving the footpath network,
especially along the riverside.
5.52 In response to the key issues presented above, the Neighbourhood Plan limits growth to two
sites which together will deliver around 15 new dwellings. One of the two allocation sites
(Renault Garage) is located within Rogate with access to the available bus services in the
Neighbourhood Plan area and the village centre. The other allocation site (at London Road) is
located at Rake with no immediate access to bus services and limited access to services and
facility provisions, but in closer proximity to rail access at Liss. Overall, development at the
allocation sites is likely to increase car reliance to some degree. However, the minimal level of
development ensures that the negative effects arising in this respect are minor, and the growth
in Rogate may also provide minor support for the vitality of the existing bus service.
5.53 The Neighbourhood Plan closely recognises the transport issues present in the Neighbourhood
Plan area. In this respect Policy T1 (Encouraging Sustainable Travel) seeks the incorporation of
“attractive links to the nearest point on the public right-of-way network and local footway
networks” in new development, and exploitation and enhancement of the cycle network and
existing public transport links. The policy further seeks to ensure that development will not
impact on the “amenity value of public rights-of-way, other public non-motorised routes or
publicly accessible land”, recognising the need to focus on and improve active travel
opportunities. Policy T2 (Safety) requires proposals to demonstrate that they will “not
significantly increase the volume of traffic” and “will not have a detrimental impact on the safety
of road users including cyclists, pedestrians and horse riders” further addressing the key issues
prevalent to the Plan area.
5.54 With the scale of growth minimised, the scope of policies and development to affect real change
in terms of a modal shift is limited. The Neighbourhood Plan recognises the limited scope in this
respect and provides identified community projects that will support change and more
sustainable travel choices. Community projects will seek partnership with West Sussex County
Council to develop proposals to; manage traffic flows and traffic speeds on the minor roads of
the parish, maintain and improve the parish’s network of public footpaths, cycle ways and bridle
paths and develop specific measures for traffic calming within Rake and Hillbrow.
5.55 Overall, it is considered likely that the growth proposed through the R&RNDP will lead to minor
long-term positive effects.
Conclusion at this current stage
5.56 The assessment has concluded that the current version of the Rogate and Rake
Neighbourhood Plan is likely to lead to significant long term positive effects in relation to the
‘Population and Community’ SEA theme. These benefits largely relate to the Neighbourhood
Plan’s focus on providing new housing to meet local needs, support for improvements to new
community infrastructure, the protection and enhancement of green infrastructure networks in
the area and the protection and enhancement of the quality of the public realm and
neighbourhood distinctiveness.
5.57 Positive effects are considered likely in relation to the ‘Biodiversity’, ‘Climate Change’,
‘Landscape’, ‘Historic Environment’ and ‘Land, Soil and Water resources’ SEA themes. These
positive effects are linked to the following;
• Long-term protection for biodiversity and geodiversity, including a requirement for project-
level HRA screening in the vicinity of The Wealden Heaths Phase II Special Protection Area
(SPA) and the Woolmer Forest Special Area of Conservation (SAC).
• The redevelopment of previously developed land at the Renault Garage site in Rogate will
support efficient land use and is likely to lead to enhancements to the villagescape,
including adjacent to the designated Rogate Conservation Area.
Environmental Report to accompany the
submission version of the Neighbourhood Plan
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• Promotion of renewable energy generation and sustainable building techniques will support
climate change mitigation in the Neighbourhood Plan area.
5.58 Minor negative effects have also been identified in relation to the Land, Soil and Water
Resources and Climate Change SEA themes:
• The small-scale level of growth proposed in Rake will result in a very limited loss of
greenfield land, which has the (uncertain) potential to include the loss of high-quality
agricultural land. However, this is likely to a negligible effect.
• Very minor increases in greenhouse gas emissions are anticipated as a result of the
increase in the built footprint of the Neighbourhood Plan area and a limited increase in car
use.
Given the scale of proposals, these negative effects are however likely to be insignificant.
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submission version of the Neighbourhood Plan
Prepared for: Rogate and Rake Neighbourhood Plan Steering Group
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6. What are the next steps?
6.1 This Environmental Report accompanies the Rogate and Rake Neighbourhood Plan for
submission to the Local Planning Authority, the South Downs National Park Authority, for
subsequent Independent Examination.
6.2 At Independent Examination, the Neighbourhood Plan will be considered in terms of whether it
meets the Basic Conditions for Neighbourhood Plans and is in general conformity with the
South Downs Local Plan.
6.3 If Independent Examination is favourable, the Neighbourhood Plan will be subject to a
referendum, organised by the South Downs National Park Authority. If more than 50% of those
who vote agree with the Neighbourhood Plan, then it will be ‘made’. Once made, the Rogate and
Rake Neighbourhood Plan will become part of the development plan for Rogate Parish.
Environmental Report to accompany the
submission version of the Neighbourhood Plan
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Appendix A Context Review and
Baseline
A1 – Air Quality
Context review
Key messages from the National Planning Policy Framework (NPPF) include:
• ‘Planning policies and decisions should sustain and contribute towards compliance with
relevant limit values or national objectives for pollutants, taking into account the presence of
Air Quality Management Areas and Clean Air Zones, and the cumulative impacts from
individual sites in local areas. Opportunities to improve air quality or mitigate impacts should
be identified, such as through traffic and travel management, and green infrastructure
provision and enhancement. So far as possible these opportunities should be considered at
the plan-making stage, to ensure a strategic approach and limit the need for issues to be
reconsidered when determining individual applications. Planning decisions should ensure that
any new development in Air Quality Management Areas and Clean Air Zones is consistent with
the local air quality action plan.’
• ‘Significant development should be focused on locations which are or can be made
sustainable, through limiting the need to travel and offering a genuine choice of transport
modes. This can help to reduce congestion and emissions and improve air quality and public
health.’
• New and existing developments should be prevented from contributing to, being put at
unacceptable risk from, or being adversely affected by unacceptable levels of air pollution.
Published in January 2018 by the UK Government, ‘A Green Future: Our 25 Year Plan to Improve the
Environment’
13
sets out a number of goals and policies in order to help the natural world regain and
retain good health. In this context, Goal 1 ‘Clean Air’ and the policies contained within ‘Chapter 4:
Increasing resource efficiency and reducing pollution and waste’ within the 25-year plan directly relate
to the air quality SEA theme.
Implemented in 2015, the Air Quality Action Plan (AQAP) for Chichester District ‘Towards Better Air
Quality’
14
outlines five priority actions for improving air quality across the district, including:
• Priority 1: Measure, model, and report on air quality;
• Priority 2: Strengthen partnerships, seek funds, pool resources and exploit synergies;
• Priority 3: Encourage low emission technology;
• Priority 4: Encourage and foster behavioural change/modal shift; and
• Priority 5: Be innovative, capitalise on opportunities and reduce emissions by 1%.
At the local level, the following policies within the emerging South Downs Local Plan directly relate to
the air quality SEA theme:
• Strategic Policy SD19: Transport and Accessibility;
• Strategic Policy SD23: Sustainable Tourism;
13
HM GOV (2018) A Green Future: Our 25 Year Plan to Improve the Environment [online] available at:
https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/693158/25-year-
environment-plan.pdf [accessed 20/02/19]
14
Chichester District Council (2015): ‘Towards Better Air Quality: An AQAP for Chichester District (2015-2020)’ [online] available
to access via: <http://chichester.gov.uk/pollutioncontrolairquality> last accessed [14/04/19]
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• Strategic Policy SD45: Green Infrastructure; and
• Development Management Policy SD54: Pollution and Air Quality.
The Chichester Air Quality Action Plan was adopted by Chichester District Council in 2015.
15
The
revised Action Plan was prepared as part of Chichester District Council’s duty under the Environment
Act 1995 subsequent to the declaration of three Air Quality Management Areas in the district. The five
‘Priorities for Action’ of the Action Plan are as follows:
• Priority 1: Measure, model, and report on air quality
• Priority 2: Strengthen partnerships, seek funds, pool resources and exploit synergies
• Priority 3: Encourage low emission technology
• Priority 4: Encourage and foster behavioural change/modal shift
• Priority 5: Be innovative, capitalise on opportunities and celebrate our successes, reduce
emissions by 1%.
Summary of current baseline
Chichester District is required to monitor air quality across the district under Section 82 of the
Environment Act (1995), report regularly to Defra and take action where nationally set levels are likely to
be exceeded. Monitoring is undertaken to assess levels of nitrogen dioxide (NO
2
), sulphur dioxide,
ozone, benzene and particulates. Where exceedances exist, areas are declared as Air Quality
Management Areas (AQMAs) and local authorities are required to produce an Air Quality Action Plan
(AQAP) to improve air quality in the area.
The emerging South Downs Local Plan states that air quality within the National Park is good. However,
NO
2
is a concern in certain areas, with an AQMA designated in ‘Lewes Town Centre’ due to
exceedances in NO
2
associated with traffic emissions. Nonetheless, the AQMA is not located within
the Neighbourhood Plan area.
The 2018 Air Quality Annual Status Report (ASR)
16
for Chichester notes that the road network within
the district is vulnerable to air pollution issues associated with congestion. Due to the location of the
Neighbourhood Plan area within the setting of the National Park, this is likely to be more pronounced
during peak times of year (i.e. public holidays, weekends and summer months), associated with
recreational visitors.
Summary of future baseline
New housing and employment provision within the parish has the potential for adverse effects on air
quality through increasing traffic flows and associated levels of pollutants such as NO
2
, particularly
along the main routes through the Neighbourhood Plan area.
Implementation of the aims, objectives and policies contained in the emerging Local Plan and the
Local Transport Plan (further discussed in Chapter 10), along with the broad air quality mitigation
measures for the European designated sites contained with the Habitats Regulation Assessment
(HRA) for the emerging Local Plan, present opportunities to continue to improve air quality within both
the Neighbourhood Plan area and the wider National Park area.
15
Chichester District Council (2015) Towards Better Air Quality: An Air Quality Action Plan for Chichester District 2015 – 2020
16
Chichester District Council (2018): ‘Air Quality ASR for Chichester District’, [online] available to access via:
<http://chichester.gov.uk/pollutioncontrolairquality> last accessed [14/04/19]
Environmental Report to accompany the
submission version of the Neighbourhood Plan
Prepared for: Rogate and Rake Neighbourhood Plan Steering Group
AECOM
45
A2 – Biodiversity
Context review
At the European level, the EU Biodiversity Strategy
17
was adopted in May 2011 in order to deliver an
established new Europe-wide target to ‘halt the loss of biodiversity and the degradation of ecosystem
services in the EU by 2020’.
Key messages from the National Planning Policy Framework (NPPF) include:
• One of the three overarching objectives of the NPPF is an environmental objective to
‘contribute to protecting and enhancing our natural, built and historic environment’ including
by ‘helping to improve biodiversity.’
• ‘Plans should: distinguish between the hierarchy of international, national and locally
designated sites; allocate land with the least environmental or amenity value […], take a
strategic approach to maintaining and enhancing networks of habitats and green
infrastructure; and plan for the enhancement of natural capital at a catchment or landscape
scape across local authority boundaries.’
• ‘Planning policies and decisions should contribute to and enhance the natural and local
environment by: protecting and enhancing valued landscapes, sites of biodiversity or
geological value and soils (in a manner commensurate with the statutory status or identified
quality in the development plan); and minimising impacts on and providing net gains for
biodiversity, including establishing coherent ecological networks that are more resilient to
current and future pressures.’
• ‘To protect and enhance biodiversity and geodiversity, plans should:
a) Identify, map and safeguard components of local wildlife-rich habitats and wider
ecological networks, including the hierarchy of international, national and locally
designated sites of importance for biodiversity; wildlife corridors and stepping stones that
connect them; and areas identified by national and local partnerships for habitat
management, enhancement, restoration or creation; and
b) Promote the conservation, restoration and enhancement of priority habitats, ecological
networks and the protection and recovery of priority species; and identify and pursue
opportunities for securing measurable net gains for biodiversity’.
The Natural Environment White Paper (NEWP)
18
sets out the importance of a healthy, functioning
natural environment to sustained economic growth, prospering communities and personal well-being.
It was in part a response to the UK’s failure to halt and reverse the decline in biodiversity by 2010 and it
signalled a move away from the traditional approach of protecting biodiversity in nature reserves to
adopting a landscape approach to protecting and enhancing biodiversity. The NEWP also aims to
create a green economy in which economic growth and the health of our natural resources sustain
each other and markets, business and Government better reflect the value of nature. It includes
commitments to:
• Halt biodiversity loss support functioning ecosystems and establish coherent ecological
networks by 2020;
• Establish a new voluntary approach to biodiversity offsetting to be tested in pilot areas;
• Enable partnerships of local authorities, local communities and landowners, the private sector
and conservation organisations to establish new Nature Improvement Areas; and
17
European Commission (2011) Our life insurance, our natural capital: an EU biodiversity strategy to 2020 [online] available at:
<http://ec.europa.eu/environment/nature/biodiversity/comm2006/pdf/EP_resolution_april2012.pdf> last accessed [27/06/18]
18
Defra (2012) The Natural Choice: securing the value of nature (Natural Environment White Paper) [online] available at:
<http://www.official-documents.gov.uk/document/cm80/8082/8082.pdf> last accessed [19/09/18]
Environmental Report to accompany the
submission version of the Neighbourhood Plan
Prepared for: Rogate and Rake Neighbourhood Plan Steering Group
AECOM
46
• Address barriers to using green infrastructure to promote sustainable growth.
Reflecting the commitments within the Natural Environment White Paper and the EU Biodiversity
Strategy, ‘Biodiversity 2020: A strategy for England’s wildlife and ecosystem services’ aims to ‘halt
overall biodiversity loss, support healthy well-functioning ecosystems and establish coherent
ecological networks, with more and better places for nature for the benefit of wildlife and people’
19
.
The recently published 25 Year Environment Plan
20
sets out the Government’s environmental plan of
action over the next quarter century, in the context of Brexit. The Plan aims to tackle the growing
problems of waste and soil degradation, improving social justice through tackling pollution and
promoting the mental and physical health benefits of the natural world. It also sets out how the
Government will address the effects of climate change. These aims are supported by a range of
policies which are focused on the following six key areas:
• Using and managing land sustainably;
• Recovering nature and enhancing the beauty of landscapes;
• Connecting people with the environment to improve health and wellbeing;
• Increasing resource efficiency, and reducing pollution and waste;
• Securing clean, productive and biologically diverse seas and oceans; and
• Protecting and improving the global environment.
In this context, Goal 3 ‘Thriving plants and wildlife’ and the policies contained within Chapter 2
‘Recovering nature and enhancing the beauty of landscapes’ and Chapter 5 ‘Securing clean,
productive and biologically diverse seas and oceans’ directly relate to the biodiversity and geodiversity
SEA theme.
At the local level, the South Downs PMP sets out 11 ‘Outcomes’ through which the Management Plan
is to be delivered. The key Outcomes relevant to the biodiversity and geodiversity theme are as
follows:
• Outcome 2: There is increased capacity within the landscape for its natural resources, habitats
and species to adapt to the impacts of climate change and other pressures. „
• Outcome 3: A well-managed and better-connected network of habitats and increased
population and distribution of priority species now exist in the National Park.
The following policies within the emerging South Downs Local Plan directly relate to the biodiversity
and geodiversity SEA theme:
• Core Policy SD2: Ecosystem Services;
• Strategic Policy SD9: Biodiversity and Geodiversity;
• Strategic Policy SD10: International Sites;
• Strategic Policy SD45: Green Infrastructure; and
• Development Management Policy SD11: Trees, Woodland and Hedgerows.
Summary of current baseline
There are two European designated sites within proximity to the Neighbourhood Plan area: the
Wealden Heaths Phase II Special Protection Area (SPA), adjacent to the northern boundary of the Plan
19
DEFRA (2011): ‘Biodiversity 2020: A strategy for England’s wildlife and ecosystem services’, [online] Available to download
from: <https://www.gov.uk/government/publications/biodiversity-2020-a-strategy-for-england-s-wildlife-and-ecosystem-
services> last accessed [19/0918]
20
HM GOV (2018) A Green Future: Our 25 Year Plan to Improve the Environment [online] available at:
https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/693158/25-year-
environment-plan.pdf [accessed 19/09/18]
Environmental Report to accompany the
submission version of the Neighbourhood Plan
Prepared for: Rogate and Rake Neighbourhood Plan Steering Group
AECOM
47
area between Liss Forest and Langley, and the Woolmer Forest Special Area of Conservation (SAC),
which is located approximately 1.5km to the north of the Plan area. There are also five Sites of Special
Scientific Interest (SSSI) within or within proximity to the Neighbourhood Plan area: Woolmer Forest
SSSI, Forest Mere SSSI, Chapel Common SSSI, Rake Hanger SSSI and Fyning Moor SSSI.
At the local level, there are several Local Wildlife Sites (LWS) also located within the Neighbourhood
Plan area, containing habitats and species listed in the annexes of both the European Habitats
Directive (92/43/EEC) and the European Birds Directive (79/409/EEC). These LWS are also designated
as Sites of Nature Conservation Interest (SNCI).
Additionally, the Neighbourhood Plan area contains a variety of Biodiversity Action Plan (BAP) Priority
Habitats and Species, discussed below.
European and Nationally designated sites
Wealden Heaths Phase II SPA
SPAs are protected sites classified in accordance with Article 4 of the EC Birds Directive (79/409/EEC),
for rare and vulnerable birds listed under Article I of the Directive and for regularly occurring migratory
species
21
. The Wealden Heaths Phase II SPA is described as: “areas of wet and dry heathland, valley
bogs, broad-leaved and coniferous woodland, permanent grassland and open water. Some of these
habitats are themselves of European significance and support nationally important assemblages of
wetland plants, invertebrates and reptiles”. The following internationally important breeding bird
species are listed as designated features of the SPA:
• Nightjar (Caprimulgus europaeus);
• Woodlark (Lullula arborea); and
• Dartford Warbler (Sylvia undata).
The Wealden Heaths Phase II SPA European Site Conservation Objectives
22
aim to maintain or restore:
• The extent and distribution of the habitats of the qualifying features;
• The structure and function of the habitats of the qualifying features;
• The supporting processes on which the habitats of the qualifying features rely;
• The population of each of the qualifying features; and
• The distribution of the qualifying features within the site.
Woolmer Forest SAC
The Woolmer Forest SAC was designated in 2005 and is approximately 670 ha in size. The SAC
encompasses a range of habitats, with the site character dominated by heath, scrub, maquis and
garrigue (over 60%), and smaller areas of coniferous woodland (22%) and dry grassland (10%). Bogs
and marshes, and inland water bodies comprise a small (<5%) percentage of the SAC
23
. There are
three Annex I habitats that are the primary reason for the designation of the site, listed below:
• Natural dystrophic lakes and ponds;
• European dry heaths; and
• Depressions on peat substrates of the Rhynchosporion.
21
JNCC (no date): ‘Special Protection Areas’, [online] available to download via: <http://jncc.defra.gov.uk/page-162> last
accessed [13/05/19]
22
Natural England (2019): ‘European Site Conservation Objectives for Wealden Heaths Phase 2 Special Protection Area’, [online]
available to download via: <http://publications.naturalengland.org.uk/file/5136636291842048> last accessed [13/05/19]
23
JNCC (no date): ‘Woolmer Forest SAC’, [online] available to download via:
<http://jncc.defra.gov.uk/protectedsites/sacselection/sac.asp?EUCode=UK0030304> last accessed [13/05/19]
Environmental Report to accompany the
submission version of the Neighbourhood Plan
Prepared for: Rogate and Rake Neighbourhood Plan Steering Group
AECOM
48
In addition, there are two Annex I habitats present as a qualifying feature, but are not a primary reason
for the designation of the site:
• Northern Atlantic wet heaths with Erica tetralix; and
• Transition mires and quaking bogs.
Site Improvement Plans (SIPSs) have been developed for each Natura 2000 site in England as part of
the Improvement Programme for England’s Natura 2000 sites (IPENS). Although the IPENS project
closed in 2015, the Wealden Heaths Woolmer Forest SIP
24
provides a high-level overview of the issues
(both current and predicted) affecting the condition of the Natura 2000 sites within the Wealden
Heaths Woolmer Forest SIP boundary, which includes the Wealden Heaths Phase II SPA and the
Woolmer Forest SAC. Additionally, the Wealden Heaths Woolmer Forest SIP outlines the priority
actions required to improve the condition of the sites, with timescales for several actions ongoing until
2020. Priority actions are grouped into seventeen categories, reflecting the issues faced by the Natura
2000 sites including (but not limited to): public disturbance, invasive species, water pollution and air
pollution.
The European Site Conservation Objectives: Supplementary advice
25
notes that the Woolmer Forest
SAC is a significant component of the Wealden Heaths Phase II SAC. The Site Conservation Objectives
for the SAC
26
aim to maintain or restore:
• The extent and distribution of the qualifying natural habitats;
• The structure and function (including typical species) of the qualifying natural habitats; and
• The supporting processes on which the qualifying natural habitats rely.
Woolmer Forest SSSI
Designated in June 1994, Woolmer Forest SSSI
27
is approximately 1298.5 ha and shares an
overlapping designation with the Woolmer Forest SAC and the Wealden Heaths Phase II SPA. Located
directly to the north of the Neighbourhood Plan area, the citation for the SSSI states:
“Woolmer Forest SSSI contains the largest and most diverse area of lowland heathland habitats in
Hampshire (outside the New Forest) and is considered the most important area of heathland in the
Weald of southern England. It is the only site in Britain known to support all twelve-native species of
reptiles and amphibians and supports a nationally important heathland flora, with associated birds and
invertebrate fauna”.
Based on the most recently completed condition assessments undertaken between 2011 and 2019,
41.62% of the SSSI is classified as ‘favourable and 58.38% of the SSSI is classified as ‘unfavourable –
recovering’.
Forest Mere SSSI
Designated in June 1984, Forest Mere SSSI
28
is approximately 14.6 ha and is located directly to the
north east of the Neighbourhood Plan area. The citation for the SSSI states:
24
Natural England (2014): ‘Site Improvement Plan: Wealden Heaths Woolmer Forest’, [online] available to download via: <
http://publications.naturalengland.org.uk/file/4738514889474048> last accessed [13/05/19]
25
Natural England (2019): ‘European Site Conservation Objectives: Supplementary advice on conserving and restoring site
features – Woolmer Forest SAC’, [online] available to download via: <
http://publications.naturalengland.org.uk/file/4519224966119424> last accessed [13/05/19]
26
Natural England (2019): ‘European Site Conservation Objectives – Woolmer Forest SAC’, [online] available to download via: <
http://publications.naturalengland.org.uk/file/5639952662790144> last accessed [13/05/19]
27
Natural England (no date): ‘Woolmer Forest SSSI’, [online] available to access via:
<https://designatedsites.naturalengland.org.uk/SiteDetail.aspx?SiteCode=s1004188> last accessed [03/05/19]
28
Natural England (no date): ‘Forest Mere SSSI’. [online] available to access via:
<https://designatedsites.naturalengland.org.uk/SiteDetail.aspx?SiteCode=s1004277> last accessed [03/05/19]
Environmental Report to accompany the
submission version of the Neighbourhood Plan
Prepared for: Rogate and Rake Neighbourhood Plan Steering Group
AECOM
49
“Forest Mere is the only West Sussex example of a shallow, base-poor lake on Lower Greensand. The
lake together with the surrounding woodland and the remaining patches of heath and bog support an
outstanding assemblage of dragonflies and a rich community of breeding birds. Several of the
dragonfly species have a restricted distribution in West Sussex”.
Based on the most recently completed condition assessments undertaken in 2013, 100% of the SSSI
is classified as ‘unfavourable – recovering’.
Chapel Common SSSI
Designated in October 1998, Chapel Common SSSI
29
is approximately 101.0 ha and is located within
the northern section of the Neighbourhood Plan area. The citation for the SSSI states:
“Chapel Common consists of a mosaic of habitats dominated by lowland dry heathland with
secondary woodland and is located close to the West Sussex/ Hampshire border. The Common is part
of a fragmented heathland complex which includes the nearby Woolmer Forest and other
neighbouring commons. Lowland heathland is the most characteristic habitat of the Wealden
Greensand Natural Area. The Lower Greensand and other associated beds provide nutrient poor and
acidic conditions ideal for heathland habitat”.
Reflecting the outcomes of the most recently completed condition assessments undertaken in 2012,
100% of the SSSI is classified as ‘unfavourable – recovering’.
Rake Hanger SSSI
Notified in September 1988, Rake Hanger SSSI
30
is approximately 28.1 ha and is located within the
north western section of the Neighbourhood Plan area, adjacent to the settlement of Rake. The citation
for the SSSI states:
“This is one of the few woods in the Weald where sessile oak (Quercus petraea) is the dominant
species. Sessile oak is more common in the north and west of Britain, but in south east England it
occurs on sandy soils, as at this site where there is a steep scarp of Lower Green-sand (Hythe Beds).
At the foot of the scarp the soils are waterlogged and are covered by alderwood, a nationally
uncommon woodland community”.
Reflecting the outcomes of the most recently completed condition assessments undertaken in 2012,
100% of the SSSI is classified as ‘unfavourable – recovering’.
Fyning Moor SSSI
Notified in May 1984, Fyning Moor SSSI
31
is approximately 12.8 ha and is in the south eastern section
of the Neighbourhood Plan area, within proximity to the settlement of Rogate. The citation for the SSSI
states:
“This is an example of a base-rich springline alder wood, a nationally uncommon woodland type, which
lies on the Sandgate and Folkestone Beds of the Lower Greensand. It is the locality of three nationally
uncommon diptera (flies).
“On the north side of the River Rother woodland slopes from high ground to poorly drained lower
slopes where alder carr occurs. The open rides in the wood support a rich community of plants, while
the river margins support a fen community. In the south part of the site a meadow lies on riverside
29
Natural England (no date): ‘Chapel Common SSSI’. [online] available to access via:
<https://designatedsites.naturalengland.org.uk/SiteDetail.aspx?SiteCode=s2000329> last accessed [03/05/19]
30
Natural England (no date): ‘Rake Hanger SSSI’, [online] available to access via:
<https://designatedsites.naturalengland.org.uk/SiteDetail.aspx?SiteCode=s1000652> last accessed [03/05/19]
31
Natural England (no date): ‘Fyning Moor SSSI’, [online] available to access via:
<https://designatedsites.naturalengland.org.uk/SiteDetail.aspx?SiteCode=s1000390> last accessed [03/05/19]
Environmental Report to accompany the
submission version of the Neighbourhood Plan
Prepared for: Rogate and Rake Neighbourhood Plan Steering Group
AECOM
50
terraces. Much of this meadow is unimproved neutral grassland and marshy grassland, which is
seasonally flooded. Areas of drier grassland occur near the river”.
Based on the most recently completed condition assessments completed in 2015, 100% of the SSSI
was classified as ‘favourable’.
SSSI Impact Risk Zones
SSSI Impact Risk Zones (IRZ) are a GIS tool/dataset which maps zones around each SSSI according to
the sensitivities of the features for which it is notified. They specify the types of development that have
the potential to have adverse impacts at a given location, including residential, rural-residential and
rural non-residential. Natural England is a statutory consultee on development proposals that might
impact on SSSIs. The whole of the Neighbourhood Plan area overlaps with a SSSI IRZ for residential,
rural residential and rural non-residential development types.
Locally important sites
Local Wildlife Sites (LWS) are areas of land that are especially important for their wildlife. They are some
of our most valuable wildlife areas which are identified and selected locally using scientifically-
determined criteria and surveys. They are corridors for wildlife, forming key components of ecological
networks. The Wildlife Trusts
32
have worked with local authorities, statutory agencies, landowners and
other local partners to establish effective systems for identifying, managing and monitoring LWS.
There are several LWS within and surrounding the Neighbourhood Plan area, many of which are also
designated as Sites of Nature Conservation Interest (SNCI), including the River Rother corridor and
Durford Heath.
There are a variety of BAP Priority Habitats located within and/or adjacent to the Neighbourhood Plan
area, including: coastal and floodplain grazing marsh; deciduous woodland; good quality and semi-
improved grassland, lowland calcareous grassland; lowland dry acid grassland; lowland fens; lowland
heathland; lowland meadows; and traditional orchard.
Additionally, there are corridors of ancient and semi-natural woodland located within the north western
section of the Neighbourhood Plan area and adjacent to the eastern boundary. Along with further
areas within the southern section, the ancient and semi-natural woodland is recognised as an
‘irreplaceable habitat’ which takes hundreds of years to establish
33
. Examples include Fyning Wood (to
south east of Rogate settlement), Rake Hanger (adjacent to the settlement of Rake), and Durford Wood
(adjacent to the Sussex Border Path) which is managed by the National Trust.
The figure below shows the designated wildlife sites and BAP priority habitats located within and
adjacent to the Neighbourhood Plan area.
Summary of future baseline
Habitats and species will potentially face increasing pressures from future development within the
Neighbourhood Plan area, with the potential for negative impacts on the wider ecological network. This
may include a loss of habitats and impacts on biodiversity networks, which may be exacerbated by the
effects of climate change, which has the potential to lead to changes in the distribution and
abundance of species and changes to the composition of habitats.
The Neighbourhood Plan presents an opportunity to maximise benefits for biodiversity by including
consideration of important habitats, species and designated sites at an early stage of planning for
future growth. To maintain and improve the condition of biodiversity in the future, it will be important to
not only protect and enhance important habitats but the connections between them. It will be crucial
32
The Wildlife Trusts (no date): ‘Local Wildlife Sites’, [online] available to access via: <https://www.wildlifetrusts.org/local-wildlife-
sites> last accessed [09/05/19]
33
GOV.UK (2018): ‘Ancient woodland, ancient trees and veteran trees: protecting them from development’, [online] available to
access via: <https://www.gov.uk/guidance/ancient-woodland-and-veteran-trees-protection-surveys-licences> last accessed
[13/05/19]
Environmental Report to accompany the
submission version of the Neighbourhood Plan
Prepared for: Rogate and Rake Neighbourhood Plan Steering Group
AECOM
51
to effectively coordinate the delivery of housing, employment and infrastructure to ensure that
opportunities to improve green infrastructure and ecological corridors are maximised both within the
Neighbourhood Plan area and in the surrounding areas.
The European protected sites are particularly sensitive to public disturbance, invasive species, water
pollution and air pollution issues. Regarding air quality, exceeding critical values for air pollutants may
result in changes to the chemical status of habitat substrate, accelerating or damaging plant growth,
altering vegetation structure and composition and thereby affecting the quality and availability of
nesting, feeding or roosting habitats. Additionally, the nature, scale, timing and duration of some human
activities can result in the disturbance of birds (i.e. – the notifying features of the SPA) at a level that
may substantially affect their behaviour, and consequently affect the long-term viability of their
populations.
Strategic Environmental Assessment for the
Rogate and Rake Neighbourhood Plan
Environmental Report to accompany the
submission version of the Neighbourhood Plan
Prepared for: Rogate and Rake Neighbourhood Plan Steering Group
AECOM
52
Environmental Report to accompany the
submission version of the Neighbourhood Plan
Prepared for: Rogate and Rake Neighbourhood Plan Steering Group
AECOM
53
A3 – Climate Change
Context review
The UK Climate Change Risk Assessment is published on a 5-yearly cycle in accordance with the
requirements of the Climate Change Act 2008. It required the Government to compile an assessment
of the risks for the UK arising from climate change, and then to develop an adaptation programme to
address those risks and deliver resilience to climate change on the ground. For both the 2012 and the
2017 UK Climate Change Risk Assessment, the Adaptation Sub-Committee commissioned an
evidence report aiming to understand the current and future climate risks and opportunities. The
evidence report contains six priority risk areas requiring additional action in the next five years, see
below
34
:
• Flooding and coastal change risks to communities, businesses and infrastructure;
• Risks to health, well-being and productivity from high temperatures;
• Risk of shortages in the public water supply, and for agriculture, energy generation and
industry;
• Risks to natural capital, including terrestrial, coastal, marine and freshwater ecosystems, soils
and biodiversity;
• Risks to domestic and international food production and trade; and
• New and emerging pests and diseases, and invasive non-native species, affecting people,
plants and animals.
The UK Climate Change Act
35
was passed in 2008 and established a framework to develop an
economically credible emissions reduction path. It also highlighted the role it would take in contributing
to collective action to tackle climate change under the Kyoto Protocol, and more recently as part of the
UN-led Paris Agreement.
The Climate Change Act includes the following:
• 2050 Target. The Act commits the UK to reducing emissions by at least 80% in 2050 from
1990 levels.
• Carbon Budgets. The Act requires the Government to set legally binding ‘carbon budgets’. A
carbon budget is a cap on the amount of greenhouse gases emitted in the UK over a five-year
period. The carbon budgets are designed to reflect the cost-effective path to achieving the
UK’s long-term objectives. The first five carbon budgets have been put into legislation and run
up to 2032.
• The Committee on Climate Change was set up to advise the Government on emissions
targets, and report to Parliament on progress made in reducing greenhouse gas emissions.
• The National Adaptation Programme requires the Government to assess the risks to the UK
from climate change, prepare a strategy to address them, and encourage key organisations to
do the same. For more detail, visit the UK adaptation policy page
36
.
Key messages from the National Planning Policy Framework (NPPF) include:
• One of the three overarching objectives of the NPPF is an environmental objective to
‘contribute to protecting and enhancing our natural, built and historic environment’ including
by ‘mitigating and adapting to climate change’ and ‘moving to a low carbon economy.’ ‘The
34
GOV UK: ‘UK Climate Change Risk Assessment Report January 2017’, [online] available to download from:
<https://www.gov.uk/government/publications/uk-climate-change-risk-assessment-2017> last accessed [20/09/18]
35
GOV.UK (2008): ‘Climate Change Act 2008’, [online] accessible via <http://www.legislation.gov.uk/ukpga/2008/27/contents>
last accessed [19/09/18]
36
Committee on Climate Change (2017): ‘UK Adaptation Policy’ [online] accessible via <https://www.theccc.org.uk/tackling-
climate-change/preparing-for-climate-change/uk-adaptation-policy/> last accessed [19/09/18]
Environmental Report to accompany the
submission version of the Neighbourhood Plan
Prepared for: Rogate and Rake Neighbourhood Plan Steering Group
AECOM
54
planning system should support the transition to a low carbon future in a changing climate,
taking full account of flood risk and coastal change. It should help to: shape places in ways
that contribute to radical reductions in greenhouse gas emissions, minimise vulnerability and
improve resilience; encourage the reuse of existing resources, including the conversion of
existing buildings; and support renewable and low carbon energy and associated
infrastructure.’
• ‘Plans should take a proactive approach to mitigating and adapting to climate change, taking
into account the long-term implications for flood risk, coastal change, water supply,
biodiversity and landscapes, and the risk of overheating from rising temperatures. Policies
should support appropriate measures to ensure the future resilience of communities and
infrastructure to climate change impacts, such as providing space for physical protection
measures, or making provision for the possible future relocation of vulnerable development
and infrastructure.’
• ‘Local planning authorities should support community-led initiatives for renewable and low
carbon energy, including developments outside areas identified in local plans or other
strategic policies that are being taken forward through neighbourhood planning.’
• Direct development away from areas at highest risk of flooding (whether existing or future).
‘Where development is necessary, it should be made safe for its lifetime without increasing
flood risk elsewhere.’
The Flood and Water Management Act
37
highlights that alternatives to traditional engineering
approaches to flood risk management include:
• Incorporating greater resilience measures into the design of new buildings, and retro-fitting
properties at risk (including historic buildings);
• Utilising the environment in order to reduce flooding, for example through the management of
land to reduce runoff and through harnessing the ability of wetlands to store water;
• Identifying areas suitable for inundation and water storage to reduce the risk of flooding
elsewhere;
• Planning to roll back development in coastal areas to avoid damage from flooding or coastal
erosion; and
• Creating sustainable drainage systems (SuDS).
38
Further guidance is provided in the document ‘Planning for SuDS’.
39
This report calls for greater
recognition of the multiple benefits that water management can present. It suggests that successful
SuDS are capable of ‘contributing to local quality of life and green infrastructure’.
At the local level, the South Downs PMP sets out 11 ‘Outcomes’ through which the Management Plan
is to be delivered. The key Outcomes relevant to the climate change theme are as follows:
• Outcome 2: There is increased capacity within the landscape for its natural resources, habitats
and species to adapt to the impacts of climate change and other pressures.
• Outcome 8: More responsibility and action is taken by visitors, residents and businesses to
conserve and enhance the special qualities and use resources more wisely.
The following policies within the emerging South Downs Local Plan directly relate to the climate
change SEA theme:
37
Flood and Water Management Act (2010) [online] available at: <http://www.legislation.gov.uk/ukpga/2010/29/contents> last
accessed [19/09/18]
38
N.B. The provision of Schedule 3 to the Flood and Water Management Act 2010 came into force on the 1st of October 2012
and makes it mandatory for any development in England or Wales to incorporate SuDs.
39
CIRIA (2010) ‘Planning for SuDs – making it happen’ [online] available to access via
<http://www.ciria.org/Resources/Free_publications/Planning_for_SuDS_ma.aspx> last accessed [19/09/18]
Environmental Report to accompany the
submission version of the Neighbourhood Plan
Prepared for: Rogate and Rake Neighbourhood Plan Steering Group
AECOM
55
• Strategic Policy SD45: Green Infrastructure;
• Strategic Policy SD48: Climate Change and Sustainable Use of Resources;
• Strategic Policy SD49: Flood Risk Management;
• Development Management Policy SD14: Climate Change Mitigation and Adaptation of
Historic Buildings;
• Development Management Policy SD50: Sustainable Drainage Systems; and
• Development Management Policy SD51: Renewable Energy.
Summary of current baseline
Contribution to climate change
In relation to greenhouse gas emissions, source data from the Department of Energy and Climate
Change
40
suggests that Chichester has higher per capita emissions than West Sussex but is broadly
in line with per capita emissions covering the South East of England and England since 2005.
Chichester has seen a 33.7% reduction in the percentage of total emissions per capita between 2005
and 2016, lower than the reductions for West Sussex (36.6%), the South East of England (36.7%) and
England (37.6%).
Potential effects of climate change
Following the success of the UK Climate Projections released in 2009 (UKCP09), the Met Office
recently released the UK Climate Projections for 2018 (UKCP18).
41
UKCP18 provides the most up to
date climate observations and projections out to 2100, using cutting-edge climate science.
Projections are broken down to a regional level across the UK and are shown in probabilistic form,
which illustrate the potential range of changes and the level of confidence in each prediction.
As highlighted by the research, the effects of climate change (under medium emissions scenarios 50
th
percentile) for South East England during the period 2040-2059 compared to the period 1981-2000
are likely to be as follows
42
:
• The central estimate of increase in annual mean temperatures of between 2ºC and 3ºC; and
• The central estimate of change in annual mean precipitation of +20 to +30% in winter and -
20% to -30% in summer.
Resulting from these changes, a range of risks may exist for the Neighbourhood Plan area, including:
• Increased incidence of heat related illnesses and deaths during the summer;
• Increased incidence of illnesses and deaths related to exposure to sunlight (e.g. skin cancer,
cataracts);
• Increased incidence of pathogen related diseases (e.g. legionella and salmonella);
• Increase in health problems related to rise in local ozone levels during summer;
• Increased risk of injuries and deaths due to increased number of storm events;
• Effects on water resources from climate change;
• Reduction in availability of groundwater for abstraction;
40
Department of Energy and Climate Change (2018) 2005 to 2016 UK local and regional CO2 emissions – data tables [online]
available at:: <https://www.gov.uk/government/statistics/uk-local-authority-and-regional-carbon-dioxide-emissions-national-
statistics-2005-2016> [accessed 12/04/19]
41
Data released 26
th
November 2018 [online] available at: https://www.metoffice.gov.uk/research/collaboration/ukcp [accessed
10/12/18]
42
Met Office (2018): ‘Land Projection Maps: Probabilistic Projections’, [online map] available to access via:
<https://www.metoffice.gov.uk/research/collaboration/ukcp/land-projection-maps> last accessed [12/04/19]
Environmental Report to accompany the
submission version of the Neighbourhood Plan
Prepared for: Rogate and Rake Neighbourhood Plan Steering Group
AECOM
56
• Adverse effect on water quality from low stream levels and turbulent stream flow after heavy
rain;
• Increased risk of flooding, including increased vulnerability to 1:100-year floods;
• Changes in insurance provisions for flood damage;
• A need to increase the capacity of wastewater treatment plants and sewers;
• A need to upgrade flood defences;
• Soil erosion due to flash flooding;
• Loss of species that are at the edge of their southerly distribution;
• Spread of species at the northern edge of their distribution;
• Deterioration in working conditions due to increased temperatures;
• Changes to global supply chain;
• Increased difficulty of food preparation, handling and storage due to higher temperatures;
• An increased move by the insurance industry towards a more risk-based approach to
insurance underwriting, leading to higher cost premiums for business;
• Increased demand for air-conditioning;
• Increased drought and flood related problems such as soil shrinkages and subsidence;
• Risk of road surfaces melting more frequently due to increased temperature; and
• Flooding of roads.
Flood Risk
Most of the Neighbourhood Plan area is in Flood Zone 1, meaning there is a <0.1% chance of flooding
in a given year. Areas close to the River Rother bordering the Plan area are in Flood Zone 3,
representing areas that have a 1% (1 in 100) or greater annual flood risk
43
.
The West Sussex Local Flood Risk Management Strategy gives an overview of sources of flooding in
the West Sussex area
44
. The report notes the risk of flooding from the River Rother.
Surface water drainage and sewer flooding is also a risk for some parts of the Neighbourhood Plan
area, associated with the River Rother
45
. The highest risk area lies outside the Neighbourhood Plan
area, however in the south of the Plan area (around Habin and and Oldcroft) there is a medium risk of
flooding from surface water. In the north-east of the Plan area, minor streams associated with Combe
Pond (west of Great Trippetts Farm) are at high risk of flooding from surface water. There are a few
high-risk areas adjacent to the main road (the AS272) around Rogate – this could be due to surface
water run-off from the adjacent fields which slope gently towards the road.
Summary of future baseline
Climate change has the potential to increase the occurrence of extreme weather events in the
Neighbourhood Plan area, with increases in mean summer and winter temperatures, increases in mean
precipitation in winter, and decreases in mean precipitation in summer. This is likely to increase the
risks associated with climate change (including fluvial flooding) with an increased need for resilience
and adaptation.
43
GOV UK (2019): ‘Flood Map for Planning’, [online] available from: https://flood-map-for-planning.service.gov.uk/ [accessed
07/05/19]
44
West Sussex County Council (2014) ‘West Sussex Local Flood Risk Management Strategy (2013-2018)’, [online] available at:
<https://www.westsussex.gov.uk/media/1595/local_flood_risk_management_strategy.pdf> [accessed 07/05/19]
45
GOV UK (2017): ‘Long term flood risk assessment for locations in England’, [online] available from: https://flood-warning-
information.service.gov.uk/long-term-flood-risk/ [accessed 07/05/19]
Environmental Report to accompany the
submission version of the Neighbourhood Plan
Prepared for: Rogate and Rake Neighbourhood Plan Steering Group
AECOM
57
In terms of climate change contribution, per capita greenhouse gas emissions generated in the
Neighbourhood Plan area may continue to decrease with wider adoption of energy efficiency
measures, renewable energy production and new technologies, including electric cars. However,
increases in the built footprint of the Neighbourhood Plan area would contribute to increases in the
absolute levels of greenhouse gas emissions.
A4 – Landscape
Context review
Key messages from the National Planning Policy Framework (NPPF) include:
• ‘Great weight should be given to conserving and enhancing landscape and scenic beauty in
National Parks, the Broads and Areas of Outstanding Natural Beauty […]. The conservation
and enhancement of wildlife and cultural heritage are also important considerations in these
areas and should be given great weight in National Parks and the Broads. The scale and extent
of development within these designated areas should be limited.’
• Strategic policies should set out an overall strategy making provision for ‘conservation and
enhancement of the natural, built and historic environment, including landscapes and green
infrastructure.’
• Planning policies and decisions should ensure that developments ‘are sympathetic to local
character and history, including the surrounding built environment and landscape setting, while
not preventing or discouraging appropriate innovation of change (such as increased
densities).’
• ‘Planning policies and decisions should contribute to and enhance the natural and local
environment by:
i. protecting and enhancing valued landscapes, sites of biodiversity or geological value
and soils
ii. recognising the intrinsic character and beauty of the countryside, and the wider benefits
from natural capital and ecosystem services – including the economic and other
benefits of the best and most versatile agricultural land, and of trees and woodland; and
iii. remediating and mitigating despoiled, degraded, derelict, contaminated and unstable
land, where appropriate.’
The policies contained within Chapter 2 ‘Recovering nature and enhancing the beauty of landscapes’
and Goal 6 ‘Enhanced beauty, heritage and engagement with the natural environment’ of the
Government’s ‘‘A Green Future: Our 25 Year Plan to Improve the Environment’ directly relates to the
landscape SEA theme.
The South Downs National Park Partnership Management Plan
46
sets out the South Downs National
Park Authority’s management strategy for the period 2014-2019, with a long-term vision and
outcomes to be achieved by 2050. There are six important sectors that have been prioritised as part
of the Management Plan: Farming; Forestry; Water; Transport; Visitors and Tourism; and, Education and
Learning. The vision for the Plan is broken down into eleven outcomes, five of which directly relate to
the landscape SEA theme, under the theme of ‘A thriving living landscape’. These Outcomes, to be
achieved by 2050, are:
• Outcome 1: The landscape character of the National Park, its special qualities and local
distinctiveness have been conserved and enhanced by effectively managing land and the
negative impacts of development and cumulative change.
46
South Downs National Park Authority (2013): ‘Shaping the future of your South Downs National Park – Partnership
Management Plan 2014-2019’, [online] available to download via: <https://www.southdowns.gov.uk/wp-
content/uploads/2015/01/SDNP-Partnership-Management-Plan-2014-19.pdf> last accessed [13/05/19]
Environmental Report to accompany the
submission version of the Neighbourhood Plan
Prepared for: Rogate and Rake Neighbourhood Plan Steering Group
AECOM
58
• Outcome 2: There is increased capacity within the landscape for its natural resources, habitats
and species to adapt to the impacts of climate change and other pressures.
• Outcome 4: The condition and status of cultural heritage assets and their settings is
significantly enhanced, many more have been discovered and they contribute positively to
local distinctiveness and sense of place.
• Outcome 6: There is widespread understanding of the special qualities of the National Park
and the benefits it provides.
• Outcome 8: More responsibility and action is taken by visitors, residents and businesses to
conserve and enhance the special qualities and use resources more wisely.
The following policies within the emerging South Downs Local Plan directly relate to the landscape
SEA theme:
• Strategic Policy SD4: Landscape Character;
• Strategic Policy SD5: Design;
• Strategic Policy SD6: Safeguarding Views;
• Strategic Policy SD7: Relative Tranquillity;
• Strategic Policy SD8: Dark Night Skies;
• Strategic Policy SD12: Historic Environment;
• Strategic Policy SD17: Protection of the Water Environment
• Strategic Policy SD18: The Open Coast;
• Strategic Policy SD45: Green Infrastructure; and
• Development Management Policy SD11: Trees, Woodland and Hedgerows.
Summary of current baseline
National Character Areas
National Character Areas (NCAs) are landscape areas which share similar characteristics, following
natural lines in the landscape rather than administrative boundaries. Developed by Natural England,
NCA profiles describe the natural and cultural features that shape each of these landscapes, providing
a broad context to its character. The Neighbourhood Plan area is located within the ‘Wealden
Greensand’ NCA, a curved belt of land passing through Kent (parallel to the North Downs), Surrey,
alongside Hampshire and through the South Downs National Park (of which 51% of the NCA is within
its boundaries). The NCA Profile for the ‘Wealden Greensand’
47
lists several key characteristics, with
the following of relevance to the Neighbourhood Plan area:
• A long, narrow belt of Greensand, typified by scarp-and-dip slope topography, including
outcrops of Upper Greensand, Gault Clay and Lower Greensand. The Greensand forms
escarpments separated by a clay vale: the overall undulating and organic landform –
particularly in the west – gives a sense of intimacy to the landscape;
• There are extensive areas of ancient mixed woodland of hazel, oak and birch, with some areas
having been converted to sweet chestnut coppice in past centuries.
• Semi-natural habitats include: remnant lowland heathland, mostly concentrated in West
Sussex, Hampshire and West Surrey; and unimproved acid grasslands found in commons,
parklands, heathland and other areas of unimproved pasture;
47
Natural England (2013): ‘NCA Profile 120: Wealden Greensand (NE465)’, [online] available to access via:
<http://publications.naturalengland.org.uk/publication/5331490007154688?category=587130> last accessed [03/05/19]
Environmental Report to accompany the
submission version of the Neighbourhood Plan
Prepared for: Rogate and Rake Neighbourhood Plan Steering Group
AECOM
59
• Fields are predominantly small or medium, in irregular patterns derived from medieval
enclosure. Boundaries are formed by hedgerows and shaws, with character and species
reflecting the underlying soils;
• The rural settlement pattern is a mixture of dispersed farmsteads, hamlets and some
nucleated villages;
• There are a range of historic landscape features, including field monuments, old military
defences, prehistoric tumuli, iron-age hill forts, Roman forts, the Royal Military Canal, small
quarries and relics of the iron industry (including hammer ponds); and
• Surface water is an important feature across the Greensand, with many streams and rivers
passing through the NCA, including the Western Rother, Wey, Arun, Medway and the Great and
East Stour.
South Downs National Park
The whole of the Neighbourhood Plan area is within the boundaries of the South Downs National Park.
With an area of 1,653km
2
and extending across south east England, the South Downs National Park
Partnership Management Plan
48
describes the landscape character as:
“Rich and complex, with 18 general landscape types and 49 more place-specific ‘character areas’.
These have changed through time, and have been greatly influenced or affected by land-use change,
such as those impacting on agriculture and settlement patterns.
“The Eastern Downs has an open and expansive character, with scenic views across the Weald and out
to sea and includes 21 kilometres of coastline. In the Central and Western Downs, woodland is a more
characteristic feature. The character of the Wealden Greensand is more enclosed and intimate, with
remnant heathland and sunken lanes”.
The South Downs National Park Partnership Management Plan outlines the following special qualities
of the National Park:
• Distinctive towns and villages, and communities with real pride in their area;
• Well-conserved historical features and a rich cultural heritage;
• Great opportunities for recreational activities and learning experiences;
• Tranquil and unspoilt places;
• A rich variety of wildlife and habitats including rare and internationally important species; and
• An environment shaped by centuries of farming and embracing new enterprise.
Landscape Character
The West Sussex Landscape Character Assessment (LCA)
49
describes the variations in character
between different areas and types of landscape in the county. It provides an evidence base for local
development frameworks and plans, articulating what people perceive as distinctive and special about
the landscape, including the South Downs National Park. Additionally, it also sets out strategies and
guidelines for the protection, management and planning of the landscape. The characteristics and
sensitivities of the LCAs which overlap with the Neighbourhood Plan area, are described below:
WG2 ‘Rother Farmlands’ is located within the southern section of the Neighbourhood Plan area,
encompassing the Rogate settlement and the farmland to the east and west. The overall character of
48
South Downs National Park Authority (2013): ‘Shaping the future of your South Downs National Park – Partnership
Management Plan 2014-2019’, [online] available to download via: <https://www.southdowns.gov.uk/wp-
content/uploads/2015/01/SDNP-Partnership-Management-Plan-2014-19.pdf> last accessed [13/05/19]
49
West Sussex County Council (2003): ‘Landscape Character Assessment of West Sussex’, [online] available to access via:
<https://www.westsussex.gov.uk/land-waste-and-housing/landscape-and-environment/landscape-character-assessment-of-
west-sussex/> last accessed [13/05/19]
Environmental Report to accompany the
submission version of the Neighbourhood Plan
Prepared for: Rogate and Rake Neighbourhood Plan Steering Group
AECOM
60
the LCA is summarised in the Land Management Guidelines
50
as a “rolling vale” where “large arable
fields form a broad grid across the rolling relief, providing long views across the area. Sunken lanes
bordered by hedgerows with stag headed oaks form hidden corridors. The unifying influence of the
large estates of Cowdray Park and Petworth Park is evident in many of the small villages and towns
with well detailed estate stone cottages and walls.” The key characteristics of the LCA are:
• Distinctive sandy yellow or red soils.
• Large arable fields with fragmented hedgerow boundaries, typically containing over-mature
stag-headed oak trees.
• Individual isolated mature hedgerow oaks.
• Scattered woodland cover.
• Long views across the large arable fields.
• Small sandstone villages clustered at road junctions. Numerous small hamlets, scattered
farms and cottages.
• Parks, estates and manor houses which influence the vernacular styles of boundaries and
buildings.
• Small streams with woodland fringes.
• Deeply sunken lanes, running north to south, with bracken clad banks and sandstone walls.
The Land Management Guidelines identify several key landscape and visual sensitivities, which are
summarised below:
• The mostly open character of the farmland allows long views across the area. Any
development or agricultural buildings or material, such as fleece, is therefore highly visible.
• The loss of hedgerows and hedgerow trees affects biodiversity, visibility and scale within the
landscape.
• Large estates and landowners have created locally distinct vernacular styles of estate stone
buildings, walls and boundary treatments of a high quality.
• The use of suburban styles and materials in new developments degrades the quality of
existing settlements.
• Localised visual intrusion, changes in landform and road improvements from sand quarry
operations.
• Changes in land management due to new recreational uses such as golf courses.
WG4 ‘Wealden Greensand’ covers the wooded areas of the Neighbourhood Plan area, including Hill
Brow in the west, Rogate Common, skirting just east of the settlement of Rake, and encompassing
Langley in the north. The LCA is described in the Land Management Guidelines
51
as forming “part of a
much bigger complex of wooded sandstone hills and valleys of the Lower Greensand at the Western
edge of the Weald, stretching north into Surrey (The Surrey Hills)”.
“The undulating dip-slope of these wooded ridges rises steadily to the north of the Rother Valley
before dropping away abruptly at a steep, deeply indented escarpment which curves around to the
north, enclosing the Milland and Fernhurst Basins. The escarpment is cut by deep, sometimes ravine-
like stream valleys. The area is heavily wooded throughout with extensive conifer plantations, mixed
woodlands and ancient broadleaved woodlands, which include oak-birch-chestnut mixes, distinctive
stands of beech, and chestnut and hazel coppice.
50
West Sussex County Council (2003): ‘Sheet WG2 Rother Farmlands’, [online] available to download via: <
http://www2.westsussex.gov.uk/environment/heritage/WG2.pdf> last accessed [13/05/19]
51
West Sussex County Council (2003): ‘Sheet WG4 North Western Ridges’, [online] available to download via: <
http://www2.westsussex.gov.uk/environment/heritage/WG4.pdf> last accessed [13/05/19]
Environmental Report to accompany the
submission version of the Neighbourhood Plan
Prepared for: Rogate and Rake Neighbourhood Plan Steering Group
AECOM
61
The settlement pattern comprises scattered, isolated farms and smallholdings, together with small
groups of cottages linked by often deeply sunken narrow, twisting lanes. Whilst there is some localised
suburban development along the main roads, the Character Area retains a remote, tranquil quality”.
The key characteristics of the LCA are summarised below:
• Prominent, wooded sandstone ridges and plateaux.
• Steep, horseshoe-shaped escarpment enclosing the Milland and Fernhurst Basins.
• Dense woodland cover with coniferous forestry and chestnut on higher slopes.
• Amongst the woodland are areas of fragmented heathland.
• Pasture and rough grazing in clearings and at the woodland edges.
• Hidden valleys and streams in deep gullies within the upper catchments.
• Narrow, twisting, often deeply-sunken lanes.
• Scattered, isolated farmsteads and small groups of cottages.
• Localised linear, suburban development along roads.
• Highly enclosed, secluded landscape, but with some long views across the basins.
• Historic parkscapes.
• Small horse paddocks and small ponds.
The Land Management Guidelines identify several key landscape and visual sensitivities, summarised
below:
• Long views from high ground have a high sensitivity to the impact of new urban development,
modern farm buildings, masts and pylons and new roads.
• Loss of woodland along ridge slopes and ridge tops.
• Heathland remnants and significant areas of rich woodland biodiversity are vulnerable to loss
and change.
• Erosion of narrow country lanes.
• Loss of parkland features such as specimen trees and tree belts.
• Cumulative impact of small-scale change.
Characteristic Viewpoints
Views are an important consideration in the planning process as the scale, height and mass of
development can ultimately impact important views if they are not considered and assessed through
the process. Changes, such as development and landscape change can see these views degraded
over time.
Within more rural communities, ‘key’ or important views normally include the views to and from focal
points such as a church, windmill, large manor and estate houses, collection of trees, open spaces and
along linear streets and lanes.
In this context, the draft Neighbourhood Plan defines 19 characterising views of local significance
within the parish, which have been identified to ensure that the character of Rogate and Rake is
retained. These are:
• Viewpoint 1: North Langley (Shipwrights Way Bridleway 3684/1187 looking south);
• Viewpoint 2: Chapel Common (Bridleway 1180-1 looking south east);
• Viewpoint 3: Oliver’s Piece (B2070 looking south east);
Environmental Report to accompany the
submission version of the Neighbourhood Plan
Prepared for: Rogate and Rake Neighbourhood Plan Steering Group
AECOM
62
• Viewpoint 4: Rake Road / Canhouse Lane Junction (looking south east);
• Viewpoint 5: Bull Hill (Brick Kiln Farm looking north);
• Viewpoint 6: Fyning Recreation Ground (Bridleway 1163 looking south);
• Viewpoint 7: Rake / Rogate Road (asparagus field looking south);
• Viewpoint 8: Southern edge of Durford Wood (Bridleway 3290-1 looking south);
• Viewpoint 9: Southern edge of Durford Wood (Footpath 1151/1153 looking south east);
• Viewpoint 10: Wenham Common (Footpath 861 looking east);
• Viewpoint 11: St Peters Church (A272 looking south across Lupin Field);
• Viewpoint 12: Fyning Lane (looking south west);
• Viewpoint 13: North Street, Rogate (looking south);
• Viewpoint 14: Rogate Village (Footpath 1160 looking south east);
• Viewpoint 15: Rogate Village (Footpath 1162 looking south);
• Viewpoint 16: Fyning Moor (Footpath 1147 looking south);
• Viewpoint 17: Fyning Moor (River Rother Black Bridge looking east);
• Viewpoint 18: River Rother (Mizzards Footpath 1149 east and west); and
• Viewpoint 19: Habin Hill (Footpath 1150/1147 looking south and north).
The figure overleaf shows the landscape designations and characteristic viewpoints within the
Neighbourhood Plan area.
Tree Preservation Orders
Implemented by local planning authorities, Tree Preservation Orders (TPOs) are designated to protect
specific trees, groups of trees or woodlands in the interests of their amenity value. When considering
‘amenity; the local planning authority will likely take into consideration the following criteria
52
:
• Visibility: the extent to which the trees or woodlands can be seen by the public; and
• Individual, collective and wider impact: considering the importance of the trees or woodlands
in relation to their cultural or historic value, contribution to and relationship with the landscape
and/or their contribution to the character or appearance of a conservation area.
In this context, there are several TPOs within the Neighbourhood Plan area.
Summary of future baseline
New development has the potential to lead to incremental but small changes in landscape and
villagescape character and quality in and around the Neighbourhood Plan area. This includes from the
loss of landscape features and areas with an important visual amenity value.
In the absence of the plan, inappropriate levels of development within the open countryside could
negatively impact upon the landscape features which contribute to the distinctive character and
special qualities of the South Downs National Park and the characteristic viewpoints.
52
GOV.UK (2014): ‘Tree Preservation Orders – General’, [online] available to access via: <https://www.gov.uk/guidance/tree-
preservation-orders-and-trees-in-conservation-areas> last accessed [16/04/19]
Strategic Environmental Assessment for the
Rogate and Rake Neighbourhood Plan
Environmental Report to accompany the
submission version of the Neighbourhood Plan
Prepared for: Rogate and Rake Neighbourhood Plan Steering Group
AECOM
63
Environmental Report to accompany the
submission version of the Neighbourhood Plan
Prepared for: Rogate and Rake Neighbourhood Plan Steering Group
AECOM
64
A5 – Historic Environment
Context review
Key messages from the National Planning Policy Framework (NPPF) include:
• Heritage assets should be recognised as an ‘irreplaceable resource’ that should be conserved
in a ‘manner appropriate to their significance’, taking account of ‘the wider social, cultural,
economic and environmental benefits’ of conservation, whilst also recognising the positive
contribution new development can make to local character and distinctiveness.
• Plans should set out a ‘positive strategy’ for the ‘conservation and enjoyment of the historic
environment’, including those heritage assets that are most at risk.
• ‘When considering the impact of a proposed development on the significance of a designated
heritage asset, great weight should be given to the asset’s conservation (and the more
important the asset, the greater the weight should be). This is irrespective of whether any
potential harm amounts to substantial harm, total loss of less than substantial harm to its
significance.’
The policies contained within Chapter 2 ‘Recovering nature and enhancing the beauty of landscapes’
and Goal 6 ‘Enhanced beauty, heritage and engagement with the natural environment’ of the
Government’s ‘‘A Green Future: Our 25 Year Plan to Improve the Environment’ directly relates to the
historic environment SEA theme.
The Government’s Statement on the Historic Environment for England
53
sets out its vision for the
historic environment. It calls for those who have the power to shape the historic environment to
recognise its value and to manage it in an intelligent manner in light of the contribution that it can make
to social, economic and cultural life.
Historic England is the statutory body that helps people care for, enjoy and celebrate England’s
spectacular historic environment. Guidance and advice notes provide essential information for local
planning authorities, neighbourhood groups, developers, consultants, landowners and other interested
parties on historic environment considerations, and are regularly reviewed and updated in light of
legislative changes. The following guidance and advice notes are particularly relevant and should be
read in conjunction with the others.
Conservation Area Designation, Appraisal and Management: Historic England Advice Note 1 (February
2016)
54
outlines ways to manage change that conserves and enhances historic areas in order to
positively contribute to sustainable development. Principally, the advice note emphasises the
importance of:
• Understanding the different types of special architectural and historic interest which underpin
the designations; and
• Recognising the value of implementing controls through the appraisal and/or management
plan which positively contribute to the significance and value of conservation areas.
Sustainability Appraisal (SA) and Strategic Environment Assessment (SEA): Historic England Advice
Note 8 (December 2016)
55
provides support to all stakeholders involved in assessing the effects of
certain plans and programmes on the historic environment. It offers advice on heritage considerations
53
HM Government (2010) The Government’s Statement on the Historic Environment for England [online] available at:
<http://webarchive.nationalarchives.gov.uk/+/http://www.culture.gov.uk/reference_library/publications/6763.aspx> last
accessed [20/0918]
54
Historic England (2016): ‘Conservation Area Designation, Appraisal and Management: Advice Note 1’, [online] available to
download via: <https://historicengland.org.uk/images-books/publications/conservation-area-designation-appraisal-
management-advice-note-1/> last accessed [11/12/18]
55
Historic England (2016): ‘SA and SEA: Advice Note 8’ [online] available to download via:
<https://historicengland.org.uk/images-books/publications/sustainability-appraisal-and-strategic-environmental-assessment-
advice-note-8/> last accessed [11/12/18]
Environmental Report to accompany the
submission version of the Neighbourhood Plan
Prepared for: Rogate and Rake Neighbourhood Plan Steering Group
AECOM
65
during each stage of the SA/SEA process and helps to establish the basis for robust and
comprehensive assessments.
Historic Environment Good Practice Advice in Planning Note 3: The Setting of Heritage Assets (2
nd
Edition) (December 2017)
56
provides general advice on understanding setting, and how it may
contribute to the significance of heritage assets and allow that significance to be appreciated, as well
as advice on how views can contribute to setting. Specifically, Part 2 of the advice note outlines a five
stepped approach to conducting a broad assessment of setting:
• Step 1: Identify which heritage assets and their settings are affected;
• Step 2: Asses the degree to which these settings make a contribution to the significance of
the heritage asset(s) or allow significance to be appreciated;
• Step 3: Assess the effects of the proposed development, whether beneficial or harmful, on
that significance or on the ability to appreciate it;
• Step 4: Explore ways to maximise enhancement and avoid or minimise harm; and
• Step 5: Make and document the decision and monitor outcomes.
Neighbourhood Planning and the Historic Environment: Historic England Advice Note 11 (October
2018)
57
outlines the importance of considering the historic environment whilst preparing the plan
(section 1), which culminates in a checklist of relevant of issues to consider, followed by an overview of
what this means in terms of evidence gathering (section 2). Sections 3 to 5 of the advice note focus
on how to translate evidence into policy, understand the SEA process and Historic England’s role in
neighbourhood planning.
At the local level, the South Downs PMP sets out 11 ‘Outcomes’ through which the Management Plan
is to be delivered. The key Outcomes relevant to the historic environment theme are as follows:
• Outcome 4: The condition and status of cultural heritage assets and their settings is
significantly enhanced, many more have been discovered and they contribute positively to
local distinctiveness and sense of place.
• Outcome 6: There is widespread understanding of the special qualities of the National Park
and the benefits it provides.
• Outcome 8: More responsibility and action is taken by visitors, residents and businesses to
conserve and enhance the special qualities and use resources more wisely.
The following policies within the emerging South Downs Local Plan directly relate to the historic
environment SEA theme:
• Strategic Policy SD12: Historic Environment;
• Development Management Policy SD13: Listed Buildings;
• Development Management Policy SD14: Climate Change Mitigation and Adaptation of
Historic Buildings;
• Development Management Policy SD15: Conservation Areas;
• Development Management Policy SD16: Archaeology; and
• Development Management Policy SD21: Public Realm, Highway Design and Public Art.
56
Historic England (2017): ‘Setting of Heritage Assets: 2
nd
Edition’, [online] available to download via:
<https://historicengland.org.uk/images-books/publications/gpa3-setting-of-heritage-assets/> last accessed [11/12/18]
57
Historic England (2018): ‘Neighbourhood Planning and the Historic Environment’, [online] available to download via:
<https://historicengland.org.uk/images-books/publications/neighbourhood-planning-and-the-historic-environment/> last
accessed [11/12/18]
Environmental Report to accompany the
submission version of the Neighbourhood Plan
Prepared for: Rogate and Rake Neighbourhood Plan Steering Group
AECOM
66
Summary of current baseline
Historic Evolution of Rogate and Rake
The Neighbourhood Plan contains an overview of the history of Rogate Parish, outlined below:
“The civil parish of Rogate combines Rogate (including part of the old parish of Terwick) with most of
the village of Rake and several hamlets. The parish is a roughly triangular shape stretching northwards
from the Western Rother across a range of soils. Near the River Rother the sandy soils are fertile and
the land then rises to the north into less fertile east-west sandstone escarpments containing deposits
of carstone (iron stone concretions).
“At the southern base of the escarpments there is a line of springs which account for the growth of the
original settlements. There is evidence of iron-age activity nearby, and a Roman Road crosses the
northern tip of the parish at Langley. It was the Saxons who first cut clearings in the primeval mixed oak
forest—the weald (Wald, German), to make small farmsteads (wicks). Then the Normans founded
Durford Abbey (Scheduled Monument) and built churches at Rogate and Terwick.
“In the sixteenth century, the production of iron from the carstone brought industry to the area,
probably supplying iron to Henry VIII’s navy in Portsmouth. There were iron furnaces in the Combe and
at Habin. The area was then dirty, smoky and noisy, but prosperity saw the building of the first
substantial houses including: The White Horse, some farmhouses, and the old cottages at Fyning. The
Sussex iron industry became out-dated with the Industrial Revolution, and the population had to
support themselves with brick-making, quarrying, forestry, woodland crafts and agriculture. The track
of the old London to Portsmouth road (A3) along the top of Rake Hanger was always dangerous
because of robbers and highwaymen so the settlement there was sparse but directed towards
catering for the travellers.
“There were four extensive estates in the nineteenth century, Rogate Lodge, Dangstein, Fair Oak and
Fyning House with numerous tenanted farms. Then the development of the railway through Petersfield
brought better, safer connections to London and the branch line along the Rother valley from
Petersfield to Midhurst had a station at Nyewood. Policing had improved so wealthy Victorians built
grand houses along the London Road along the edge of Rake Hanger at Hillbrow with views into
Harting Combe. All these households needed domestic and outdoor staff and so smaller cottages
were built in Rake and neighbouring Liss which had a station on the London line. There was once a
village centre known as Rogate Square at the crossroads, and the Church, White Horse pub and village
shop still form the centre of Rogate village.
“The 1950s brought metalled roads, sanitation, piped water, slum clearance, and new agricultural
methods. The population grew. New private housing was built along the London Road, Rake, and
Fyning Lane, Rogate. In the 1960s and 1970s Rogate village leaders decided not to have a gas supply
connected and could not decide on a route for a by-pass. Now the A272, the most important main
road running east-west through West Sussex north of the Downs, carries significant volumes of traffic
through the narrow centre and Conservation Area of Rogate.”
Designated Heritage Assets
Historic England is the statutory consultee for certain categories of listed building consent and all
applications for scheduled monument consent. The historic environment is protected through the
planning system, via conditions imposed on developers and other mechanisms. The Neighbourhood
Plan area contains one Grade I, three Grade II* and 54 Grade II listed buildings which are protected
through the Listed Buildings and Conservation Areas Act 1990. The Grade I and II* listed buildings are
as follows:
• The Parish Church of St Bartholomew (Grade I);
• Fyning House Old Fyning House the Bothy (Grade II*);
• Church of St Peter (Grade II*); and
Environmental Report to accompany the
submission version of the Neighbourhood Plan
Prepared for: Rogate and Rake Neighbourhood Plan Steering Group
AECOM
67
• Barn at Wenham Manor Farm to the North West of the Farmhouse (Grade II*).
Scheduled monuments are sites of national importance and protected by the Ancient Monuments and
Archaeological Areas Act 1979. According to the National Heritage List for England
58
, there are three
scheduled monuments within the Neighbourhood Plan area, namely:
• Durford Bridge;
• Habin Bridge; and
• Durford Abbey.
Conservation areas are designated because of their special architectural and historic interest.
Conservation area appraisals are a tool to demonstrate the area’s special interest, explaining the
reasons for designation and providing a greater understanding and articulation of its character -
mentioned within the ‘Conservation Area Designation, Appraisal and Management’ advice note by
Historic England
59
. Ideally, appraisals should be regularly reviewed as part of the management of the
conservation area and can be developed into a management plan.
Designated in November 1984 and covering the central section of the settlement, the purpose of the
Rogate Conservation Area is noted in the Neighbourhood Plan as follows: “to conserve the
recognisable character of the village centre and its environs, protecting the church and churchyard,
the White Horse Pub and the eighteenth and nineteenth century houses and cottages’. As of May
2019, an appraisal or management plan has not been completed for the Rogate Conservation Area
and it is therefore difficult to identify its special architectural and historic interest. However, the SDNPA
confirms that there is a rolling programme to review and update conservation area appraisals within
the National Park
60
.
Since 2008, Historic England has released an annual Heritage at Risk Register. The Heritage at Risk
Register highlights the Grade I and Grade II* listed buildings, scheduled monuments, historic parks and
gardens, registered battlefields, wreck sites and conservation areas deemed to be ‘at risk’. According
to the 2018 Heritage at Risk Register for the South East, there are no designated heritage assets in the
Neighbourhood Plan area at risk
61
.
However, it is important to recognise that the Heritage at Risk Registers for areas outside of London do
not contain information about the status of Grade II listed buildings. As such, it is currently not possible
to determine whether the 54 Grade II listed buildings within the Neighbourhood Plan are at risk.
The figure above shows the location of the scheduled monuments, listed buildings and conservation
area within the Neighbourhood Plan area.
Locally Important Heritage Features
It should be noted that not all the area’s historic environment features are subject to statutory
designations, and non-designated features comprise a large part of what people have contact with as
part of daily life – whether at home, work or leisure. Although not designated, many buildings and areas
are of historic interest and are important by local communities. For example, open spaces and key
distinctive buildings in the area are likely to be of value for local people.
58
Historic England: National Heritage List for England: <http://list.historicengland.org.uk> last accessed [20/09/2018]
59
Historic England (2016): ‘Conservation Area Designation, Appraisal and Management Advice Note 1’, [online] available to
download from: <https://www.historicengland.org.uk/images-books/publications/conservation-area-designation-appraisal-
management-advice-note-1/> last accessed [20/09/18]
60
South Downs National Park Authority (2019): ‘Conservation Areas’, [online] available to access via:
<https://www.southdowns.gov.uk/planning/historic-environment/conservation-areas/> last accessed [14/05/19]
61
Historic England (2018): ‘Heritage at Risk Register for the South East’ [online] available to download via:
<https://historicengland.org.uk/images-books/publications/har-2018-registers/> last accessed [13/05/19]
Environmental Report to accompany the
submission version of the Neighbourhood Plan
Prepared for: Rogate and Rake Neighbourhood Plan Steering Group
AECOM
68
Following a high-level review of the Historic Environmental Record (HER) for West Sussex (accessed via
the Heritage Gateway)
62
, there are 38 records within Rogate parish, including: Palaeolithic findspots;
Roman findspots; the Chichester to Silchester Roman Road; medieval monasteries, buildings,
earthworks and findspots; post-medieval gardens and parks, limekilns, water wheels and ironstone
workings; the post-medieval to modern Petersfield to Midhurst railway; minepits; and, a Royal Observer
Corps monitoring post.
Summary of future baseline
New development areas in the Neighbourhood Plan area have the potential to impact on the fabric and
setting of heritage assets; for example, through inappropriate design and layout. It should be noted,
however, that existing historic environment designations offer a degree of protection to heritage
assets and their settings.
Alongside, new development need not be harmful to the significance of a heritage asset, and in the
context of the Neighbourhood Plan area there may be opportunity for new development to enhance
the historic setting of the village and better reveal assets’ heritage significance.
A6 – Land, Soil and Water Resources
Context review
The EU’s Soil Thematic Strategy
63
presents a strategy for protecting soil resources in Europe. The
main aim of the strategy is to minimise soil degradation and limit associated detrimental effects linked
to water quality and quantity, human health, climate change, biodiversity, and food safety.
Adopted in October 2000, the purpose of the EU Water Framework Directive (WFD) is to establish a
framework for the protection of inland surface waters, transitional waters, coastal waters and
groundwater, driving a catchment-based approach to water management. In England and Wales there
are 100 water catchments and it is Defra’s intention is to establish a ‘framework for integrated
catchment management’ across England. The Environment Agency is establishing ‘Significant Water
Management Issues’ and recently presented second River Basin Management Plans to ministers. The
plans seek to deliver the objectives of the WFD namely:
• Enhance the status and prevent the further deterioration of aquatic ecosystems and
associated wetlands which depend on aquatic ecosystems;
• Promote the sustainable use of water;
• Reduce the pollution of water, especially by ‘priority’ and ‘priority hazardous’ substances;
• Ensure the progressive reduction of groundwater pollution; and
• Contribute to achieving ‘good’ water quality status for as many waterbodies as possible by
2027.
Completed in December 2015, the updated South East River Basin District Management Plan
64
sets
out the current state of the water environment, the pressures facing the water environment, the
environmental objectives for protecting and improving the waters, a programme of measures and
actions needs to achieve the objectives, and the progress since the 2009 plan.
Key messages from the NPPF include:
62
Heritage Gateway (2019): Historic Environmental Record for West Sussex’, [online] available to access via:
<http://www.heritagegateway.org.uk/gateway/> last accessed [13/04/19]
63
European Commission (2006) Soil Thematic Policy [online] available at: <http://ec.europa.eu/environment/soil/index_en.htm>
last accessed [29/06/18]
64
DEFRA & Environment Agency (2015): ‘South East River Basin Management Plan (Part 1)’, [online] available to access via:
<https://www.gov.uk/government/publications/south-east-river-basin-district-river-basin-management-plan> last accessed
[14/04/19]
Environmental Report to accompany the
submission version of the Neighbourhood Plan
Prepared for: Rogate and Rake Neighbourhood Plan Steering Group
AECOM
69
• ‘Planning policies and decisions should contribute to and enhance the natural and local
environment by:
i. protecting and enhancing valued landscapes, sites of biodiversity or geological value
and soils; and
ii. recognising the intrinsic character and beauty of the countryside, and the wider benefits
from natural capital and ecosystem services – including the economic and other
benefits of the best and most versatile agricultural land, and of trees and woodland.’
• Prevent new or existing development from being ‘adversely affected’ by the presence of
‘unacceptable levels’ of soil pollution or land instability and be willing to remediate and mitigate
‘despoiled, degraded, derelict, contaminated and unstable land, where appropriate’.
• ‘Planning policies and decisions should promote an effective use of land in meeting the need
for homes and other uses, while safeguarding and improving the environment and ensuring
safe and healthy living conditions. Strategic policies should set out a clear strategy for
accommodating objectively assessed needs, in a way that makes as much use as possible of
previously-developed or ‘brownfield’ land.’
• ‘Encourage multiple benefits from both urban and rural land, including through mixed use
schemes and taking opportunities to achieve net environmental gains.’
• Planning policies and decisions should ‘give substantial weight to the value of using suitable
brownfield land within settlements for homes and other identified needs’, and ‘promote and
support the development of under-utilised land and buildings.’
• Taking a proactive approach to mitigating and adapting to climate change, taking into account
the long-term implications for water supply.
• Prevent new and existing development from contributing to, being put at unacceptable risk
from, or being adversely affected by unacceptable levels of water pollution.
• The government has produced a separate plan that specifically deals with planning policy in
relation to waste management; this should be read in conjunction with the NPPF.
Along with the policies contained within Chapter 1 ‘Using and managing land sustainably’ and Chapter
4 ‘Increasing resource efficiency, and reducing pollution and waste’, Goal 2 ‘Clean and plentiful water’,
Goal 5 ‘Using resources from nature more sustainably and efficiently’ and Goal 8 ‘Minimising waste’ of
the Government’s ‘A Green Future: Our 25 Year Plan to Improve the Environment’ directly relates to the
land, soil and water resources SEA theme.
Other key documents at the national level include Safeguarding our Soils: A Strategy for England
65
,
which sets out a vision for soil use in England, and the Water White Paper
66
, which sets out the
Government’s vision for a more resilient water sector. It states the measures that will be taken to tackle
issues such as poorly performing ecosystems, and the combined impacts of climate change and
population growth on stressed water resources. In terms of waste management, the Government
Review of Waste Policy in England
67
recognises that environmental benefits and economic growth can
be the result of a more sustainable approach to the use of materials.
65
Defra (2009) Safeguarding our Soils: A strategy for England [online] available to download from:
<https://www.gov.uk/government/publications/safeguarding-our-soils-a-strategy-for-england> last accessed [20/09/18]
66
Defra (2011) Water for life (The Water White Paper) [online] available at <http://www.official-
documents.gov.uk/document/cm82/8230/8230.pdf> last accessed [20/09/18]
67
Defra (2011) Government Review of Waste Policy in England [online] available at:
<http://www.defra.gov.uk/publications/files/pb13540-waste-policy-review110614.pdf> last accessed [20/09/18]
Environmental Report to accompany the
submission version of the Neighbourhood Plan
Prepared for: Rogate and Rake Neighbourhood Plan Steering Group
AECOM
70
In terms of waste management, the Government Review of Waste Policy in England
68
recognises that
environmental benefits and economic growth can be the result of a more sustainable approach to the
use of materials.
The National Waste Management Plan
69
provides an analysis of the current waste management
situation in England and evaluates how it will support the implementation of the objectives and
provisions of the revised Waste Framework Directive
70
. This includes an assessment of the need for
new collection schemes, additional waste infrastructure and investment channels, as well as providing
general or strategic waste management policies.
At the local level, the South Downs PMP sets out 11 ‘Outcomes’ through which the Management Plan
is to be delivered. The key Outcomes relevant to the land, soil and water resources theme are as
follows:
• Outcome 1: The landscape character of the National Park, its special qualities and local
distinctiveness have been conserved and enhanced by effectively managing land and the
negative impacts of development and cumulative change.
• Outcome 2: There is increased capacity within the landscape for its natural resources, habitats
and species to adapt to the impacts of climate change and other pressures
The following policies within the emerging South Downs Local Plan directly relate to the land, soil and
water resources SEA theme:
• Strategic Policy SD17: Protection of the Water Environment;
• Development Management Policy SD39: Agriculture and Forestry;
• Development Management Policy SD40: Farm and Forestry Diversification; and
• Development Management Policy SD55: Contaminated Land.
71
Summary of current baseline
Soil resources
The Agricultural Land Classification (ALC) classifies land into six grades (plus ‘non-agricultural land’ and
‘urban’), where Grades 1 to 3a are recognised as being the ‘best and most versatile’ land and Grades
3b to 5 of poorer quality. In this context, there is a need to avoid loss of higher quality ‘best and most
versatile’ agricultural land.
In terms of the location of the best and most versatile agricultural land, a detailed classification has not
been undertaken for most of the Neighbourhood Plan area. The Provisional Agricultural Land Quality
dataset
72
shows that the Neighbourhood Plan area is covered by various agricultural land grades:
• The land to the south of Rogate, as well as immediately to the north of the A272 is classified
as Grade 3 land (Good to Moderate).
• The wooded areas extending north from Hill Brow to Rake and Langley are classified as ‘Non-
Agricultural Land – Other land primarily in non-agricultural use’.
68
DEFRA (2011) Government Review of Waste Policy in England [online] available at:
https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/69401/pb13540-waste-
policy-review110614.pdf [accessed 01/03/19]
69
DEFRA (2013) Waste Management Plan for England [online] available at:
https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/265810/pb14100-waste-
management-plan-20131213.pdf [accessed 01/03/19]
70
Directive 2008/98/EC
71
72
Natural England (2018) Agricultural Land Classification map London and the South East (ALC007) [online] available at <
http://publications.naturalengland.org.uk/publication/141047?category=5954148537204736> last accessed [13/05/19]
Environmental Report to accompany the
submission version of the Neighbourhood Plan
Prepared for: Rogate and Rake Neighbourhood Plan Steering Group
AECOM
71
• There are small areas of agricultural land classified as Grade 2 (Very Good): these are located
just north of the A272 east of Sheet (north of Westmark Farm), north of the A272 at Rogate
(the land between Slade Farm and Vicarage Farm), and land to the west of the B3006 Hill Brow
Road (south-east of Liss).
• The northernmost extent of the Neighbourhood Plan area at Langley is classified as Grade 5
(Very Poor).
However, for land classified as Grade 3 land, without the subset grading (3a or 3b) it is not possible to
tell at this stage whether all the agricultural land is ‘best and most versatile’. It is also important to note
that the national dataset is of very low resolution and may not necessarily provide an accurate
reflection of the agricultural land quality within the Neighbourhood Plan area.
Water resources
The Neighbourhood Plan area is located within the South East River Basin District, within the Arun and
Western Streams Management Catchment. The River Rother is the main watercourse within the
Neighbourhood Plan area, passing through its southern section.
The Nitrates Directive (91/676/EEC) requires Member States to identify areas where groundwater have
nitrate concentrations of more than 50 mg/l nitrate or are thought to be at risk of nitrate contamination.
Areas associated with such groundwater are designated as Nitrate Vulnerable Zones (NVZs) within
which, Member States are required to establish Action Programmes to reduce and prevent further
nitrate contamination. In this regard, the southern half of the Neighbourhood Plan area is within the
‘Petersfield’ Groundwater NVZ. However, it is useful to note that as the Neighbourhood Plan is likely to
allocates land for residential development and potential employment areas, such uses are not
considered to increase the risk of pollution to the NVZ.
Groundwater Source Protection Zones (SPZs) have been defined by the Environment Agency in
England and Wales to protect groundwater sources such as wells, boreholes and springs that are used
for public drinking water supply. Within the western section of the Neighbourhood Plan area there is a
Zone I ‘Inner Protection Zone’, Zone II ‘Outer Protection Zone’ and Zone III ‘Total Catchment’ SPZ.
73
These zones show the risk of contamination from any activities that might cause pollution in the area.
Water quality
The Neighbourhood Plan area is located within the South East River Basin District, falling under the
Arun and Western Streams Management Catchment and the Rother Western Operational
Catchment
74
. The section of the Rother which falls under the Neighbourhood Plan area is the ‘Western
Rother Durford’.
Based on the most recently completed water quality assessments undertaken in 2016, the
Environment Agency’s Catchment Data Explorer
75
classifies the Western Rother Durford as having a
Good chemical status and a Moderate ecological status. The reasons for not achieving good status
(RNAGs) are primarily attributed to the following activities: poor soil management; poor nutrient
management; point source continuous sewage discharge; and, invasive non-native species
(Pacifastacus leniusculus, the North American signal crayfish).
Mineral resources
Mineral resources are defined as natural concentrations of minerals or, in the case of aggregates,
bodies of rock that are, or may become, of potential economic interest due to their inherent properties.
They make an essential contribution to the country’s prosperity and quality of life. Since minerals are a
non-renewable resource, minerals safeguarding is the process of ensuring that non-minerals
73
Natural England (2019) ‘Magic Map Application’, [online] available to access via: <http://magic.gov.uk/>[accessed 13/05/19]
74
Environment Agency (no date) ‘Rother Western Operational Catchment’, [online] available to access via: <
https://environment.data.gov.uk/catchment-planning/OperationalCatchment/3533> last accessed [13/05/19]
75
Environment Agency (2019): ‘Catchment Data Explorer’, [online] available to access via:
<https://environment.data.gov.uk/catchment-planning/> [accessed 13/05/19]
Environmental Report to accompany the
submission version of the Neighbourhood Plan
Prepared for: Rogate and Rake Neighbourhood Plan Steering Group
AECOM
72
development does not needlessly prevent the future extraction of mineral resources, of local and
national importance
76
.
Adopted in July 2018, the Joint Minerals Local Plan
77
for West Sussex covers the period to 2033 and
provides the basis for making consistent decisions about planning applications for mineral activities
throughout the county. Appendix E confirms the location of the five mineral safeguarding areas (MSAs)
throughout West Sussex, which includes: Sharp Sand and Gravel, Soft Sand (including potential Silica
Sand), Brick Clay Resource, Chalk, and Building Stone. The Neighbourhood Plan area overlaps with the
Soft Sand and Building Stone MSAs.
Summary of future baseline
Future development has the potential to affect water quality through diffuse pollution, waste water
discharges, water run-off, and modification. However, water companies are likely to maintain adequate
water supply and wastewater management over the plan period, and the requirements of the Water
Framework Directive are likely to lead to continued improvements to water quality within the
Neighbourhood Plan area and wider area.
In the absence of a detailed Agricultural Land Classification assessment for most of Rogate and Rake,
it remains uncertain whether new development in the Neighbourhood Plan area will lead to losses of
higher quality (best and most versatile) agricultural land.
A7 – Population and Community
Context review
Key messages from the NPPF include:
• One of the three overarching objectives of the NPPF is a social objective to; ‘support strong,
vibrant and healthy communities, by ensuring that a sufficient number and range of homes can
be provided to meet the needs of present and future generations; and by fostering a well-
designed and safe built environment, with accessible services and open spaces that reflect
current and future needs and support communities’ health, social and cultural wellbeing.’
• To support the Government’s objective of significantly boosting the supply of housing,
strategic policies ‘should be informed by a local housing need assessment, conducted using
the standard method in national planning guidance. In addition to the local housing need
figure, any needs that cannot be met within neighbouring areas should also be taken into
account in establishing the amount of housing to be planned for.’
• The size, type and tenure of housing needed for different groups in the community should be
assessed and reflected in planning policies. Where a need for affordable housing is identified,
planning policies should specify the type of affordable housing required, and expect it to be
met on-site where possible.
• Recognise the important contribution of small and medium sized development sites in
meeting housing needs. Local Plans should identify land to accommodate at least 10% of their
housing requirement on sites no larger than one hectare, and neighbourhood planning groups
should also consider the opportunities for allocating small and medium-sized sites.
• In rural areas, planning policies and decisions should be responsive to local circumstances
and plan housing development to reflect local needs, particularly for affordable housing,
including through rural exception sites where appropriate. Authorities should consider whether
76
GOV.UK (2014): ‘Minerals Guidance’, [online] available to access via: <https://www.gov.uk/guidance/minerals> last accessed
[11/03/19]
77
West Sussex County Council (2018): ‘Joint Minerals Local Plan’, [online] available to access via:
<https://www.westsussex.gov.uk/about-the-council/policies-and-reports/environment-planning-and-waste-policy-and-
reports/minerals-and-waste-policy/joint-minerals-local-plan/> last accessed [13/05/19]
Environmental Report to accompany the
submission version of the Neighbourhood Plan
Prepared for: Rogate and Rake Neighbourhood Plan Steering Group
AECOM
73
allowing some market housing would facilitate the provision of affordable housing to meet
local needs.
• Promote the retention and development of local services and community facilities such as
local shops, meeting places, sports venues, open space, cultural buildings, public houses and
places of worship.
• Ensure that developments create safe and accessible environments where crime and
disorder, and the fear of crime, do not undermine quality of life or community cohesion. Places
should contain clear and legible pedestrian routes, and high-quality public spaces, which
encourage the active and continual use of public areas.
• Ensuring that there is a ‘sufficient choice of school places’ and taking a ‘proactive, positive and
collaborative approach’ to bringing forward ‘development that will widen choice in education’.
The ‘Ready for Ageing?’ report, published by the Select Committee on Public Service and
Demographic Change
78
warns that society is underprepared for an ageing population. The report
states that ‘longer lives can be a great benefit, but there has been a collective failure to address the
implications and without urgent action this great boon could turn into a series of miserable crises’. The
report recognises that the supply of specialist housing for the older generation is insufficient for the
demand. There is a need for central and local Government, housing associations, and house builders
to ensure that these housing needs are better addressed, giving as much priority to promoting an
adequate market of social housing for the older generation as is given to the younger generation.
At the local level, the South Downs PMP sets out 11 ‘Outcomes’ through which the Management Plan
is to be delivered. The key Outcomes relevant to the population and community theme are as follows:
• Outcome 5: Outstanding visitor experiences are underpinned by a high quality access and
sustainable transport network providing benefits such as improved health and wellbeing. „
• Outcome 6: There is widespread understanding of the special qualities of the National Park
and the benefits it provides.
• Outcome 7: The range and diversity of traditional culture and skills has been protected and
there is an increase in contemporary arts and crafts that are inspired by the special qualities
of the National Park.
• Outcome 8: More responsibility and action is taken by visitors, residents and businesses to
conserve and enhance the special qualities and use resources more wisely. Towards a
sustainable future
• Outcome 9: Communities and businesses in the National Park are more sustainable with an
appropriate provision of housing to meet local needs and improved access to essential
services and facilities.
• Outcome 10: A diverse and sustainable economy has developed which provides a range of
business and employment opportunities, many of which are positively linked with the special
qualities of the National Park.
• Outcome 11: Local people have access to skilled employment and training opportunities.
The following policies within the emerging South Downs Local Plan directly relate to the population and
community SEA theme:
• Core Policy SD1: Sustainable Development;
• Core Policy SD3: Major Development;
• Strategic Policy SD19: Transport and Accessibility;
78
Select Committee on Public Service and Demographic Change (2013) Ready for Ageing? [online] available at:
<http://www.parliament.uk/business/committees/committees-a-z/lords-select/public-services-committee/report-ready-for-
ageing/> last accessed [21/09/18]
Environmental Report to accompany the
submission version of the Neighbourhood Plan
Prepared for: Rogate and Rake Neighbourhood Plan Steering Group
AECOM
74
• Strategic Policy SD23: Sustainable Tourism;
• Strategic Policy SD25: Development Strategy;
• Strategic Policy SD28: Affordable Homes;
• Strategic Policy SD33: Gypsies and Travellers and Travelling Showpeople;
• Strategic Policy SD34: Sustaining the Local Economy;
• Development Management Policy SD37: Development in Town and Village Centres;
• Development Management Policy SD43: New and Existing Community Facilities;
• Development Management Policy SD46: Provision and Protection of Open Space, Sport and
Recreational Facilities and Burial Grounds / Cemeteries; and
• Development Management Policy SD47: Local Green Spaces.
Summary of current baseline
Population and Age Structure
The population of Rogate and Rake increased at a lower rate (2.8%) between 2001 and 2011 in
comparison to observed increases for Chichester (6.9%), the South East (7.9%) and England (7.9%).
Approximately 1.37% of the population of Chichester District live within the boundaries of the
Neighbourhood Plan area
79
.
The percentage of residents within the 60+ age category (33.7%) in the Neighbourhood Plan area is
slightly higher than in Chichester District (32.0%), and notably higher than in the South East (23.4%)
and England (22.3%). Conversely, the proportion of Plan area residents aged 0-24 (25.0%) is slightly
lower than at district level (26.4%), and notably lower than at regional (30.2%) and national (30.8%)
levels
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.
Regarding the working age categories (25-44 and 45-59) the total for the Neighbourhood Plan area
(41.4%) is in line with the total for Chichester (41.6%), but markedly lower than the total for the South
East (49.9%) and England (46.9%).
Household deprivation
Census statistics measure deprivation across four ‘dimensions’ of deprivation, summarised below:
▪ Employment: Any person in the household (not a full-time student) that is either
unemployed or long-term sick.
▪ Education: No person in the household has at least a level 2 qualification and no person
aged 16-18 is a full-time student.
▪ Health and disability: Any person in the household that has generally ‘bad’ or ‘very bad’
health or has a long-term health problem.
▪ Housing: The household accommodation is either overcrowded (with an occupancy rating
of -1 or less), in a shared dwelling or has no central heating.
Based on Census data, 46.0% of households in the Neighbourhood Plan area are deprived in some
form. This is lower than rates for Chichester (51.4%), the South East (52.3%) and England (57.4%). Most
households in the Neighbourhood Plan area are deprived in either 1 or 2 dimensions, similar to the
regional and national trends
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.
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ONS (no date): Census 2011: Population Density 2011; Population Density 2001
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ONS (no date): Census 2011: Age Structure 2011
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ONS (no date): Census 2011: ‘Households by Deprivation Dimensions 2011 (Table QS119EW)
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Index of multiple deprivation
The Index of Multiple Deprivation 2015 (IMD) is an overall relative measure of deprivation constructed
by combining seven domains of deprivation according to their respective weights, as described below.
The seven deprivation domains are as follows:
• Income: The proportion of the population experiencing deprivation relating to low income,
including those individuals that are out-of-work and those that are in work but who have low
earnings (satisfying the respective means tests).
• Employment: The proportion of the working-age population in an area involuntarily excluded
from the labour market, including those individuals who would like to work but are unable to do
so due to unemployment, sickness or disability, or caring responsibilities.
• Education, Skills and Training: The lack of attainment and skills in the local population.
• Health Deprivation and Disability: The risk of premature death and the impairment of quality of
life through poor physical or mental health. Morbidity, disability and premature mortality are
also considered, excluding the aspects of behaviour or environment that may be predictive of
future health deprivation.
• Crime: The risk of personal and material victimisation at local level.
• Barriers to Housing and Services: The physical and financial accessibility of housing and local
services, with indicators categorised in two sub-domains.
a. ‘Geographical Barriers’: relating to the physical proximity of local services.
b. ‘Wider Barriers’: relating to access to housing, such as affordability.
• Living Environment: The quality of the local environment, with indicators falling categorised in
two sub-domains.
c. ‘Indoors Living Environment’ measures the quality of housing.
d. ‘Outdoors Living Environment’ measures air quality and road traffic accidents
Two supplementary indices (subsets of the Income deprivation domains), are also included:
1. Income Deprivation Affecting Children Index: The proportion of all children aged 0 to 15
living in income deprived families.
2. Income Deprivation Affecting Older People Index: The proportion of all those aged 60 or
over who experience income deprivation.
Lower Super Output Areas (LSOAs)
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are a geographic hierarchy designed to improve the reporting of
small area statistics in England and Wales. They are standardised geographies designed to be as
consistent in population as possible, with each LSOA containing approximately 1,000 to 1,500 people.
In relation to the IMD 2015, LSOAs are ranked out of the 32,844 LSOAs in England and Wales, with 1
being the most deprived. Ranks are normalised into deciles, with a value of 1 reflecting the top 10%
most deprived LSOAs in England and Wales.
The Neighbourhood Plan area falls within two LSOAs: ‘Chichester 003B’ (which comprises most of the
Parish) and ‘Chichester 003C’ (the northernmost portion of the Neighbourhood Plan area, comprising
Rake). These two LSOAs are among the 50% and 30% least deprived neighbourhoods in the country,
respectively.
While both LSOAs are among the 10% and 20% least deprived neighbourhoods in terms of income,
employment, health and disability, ‘Chichester 003B’ is noticeably more deprived than ‘Chichester
003C’ in the ‘Education, skills and training’ domain. Additionally, both LSOAs are among the 20% most
82
DCLG (2015): Indices of Deprivation Explorer’, [online] available at: http://dclgapps.communities.gov.uk/imd/idmap.html
[accessed 07/05/19]
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deprived neighbourhoods in the country within the ‘Living Environment’ and ‘Barriers to Housing and
Services’ domains.
Housing
There is a high rate of home ownership in the Neighbourhood Plan area, with 71% of residents owning
their own homes (outright or with a mortgage)
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. This is a higher proportion of home ownership than at
district (67.2%), regional (67.6%) and national levels (63.3%). 10.2% of people live in private rented
accommodation, compared to 16.0% of people living in social rented accommodation. There are fewer
residents living in privately rented accommodation in the Neighbourhood Plan area in comparison to
regional and national totals. In contrast, there are a larger number of residents living rent-free within the
Neighbourhood Plan area (2.6%) in comparison to England (1.3%). In addition, a slightly larger number
of residents live in social rented accommodation in the Neighbourhood Plan area (16.0%) in
comparison to Chichester (14.9%) and the South East (13.7%), but fewer than the percentage total for
England (17.7%).
Education
Based on the 2011 census data
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, 19.2% of residents in the Neighbourhood Plan area have no
qualifications, which is similar to the district (19.5%) and regional (19.1%) levels, but lower than the total
for England (20.7%). However, a higher proportion of residents in the Neighbourhood Plan area have
qualifications Level 4 and above (37.1%) in comparison to the district (32.4%), regional (30.0%) and
national (27.4%) trends. Therefore, the Neighbourhood Plan area has a highly qualified working
population.
Employment
Regarding employment within the Neighbourhood Plan area, the following three occupation categories
support the most residents
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:
• Professional occupations (22.0%);
• Managers, directors and senior officials (20.3%); and
• Associate professional and technical occupations (14.5%).
Overall, 56.8% of residents within the Neighbourhood Plan area are employed in one of the above
three occupation categories, higher than the totals for Chichester (46.0%), the South East (44.8%) and
England (41.1%).
27.7% of residents in the Neighbourhood Plan area are currently economically inactive, broadly in line
with the figures for Chichester (27.7%) and the South East (27.9%), but slightly lower than the total
percentage for England (30.1%).
Community assets and infrastructure
Rogate has a range of local community facilities which serve the needs of the local community and
play a vital role in supporting the parish’s sense of identity, including the village hall, the White Horse
Inn/Pub, village shop and post office. The Neighbourhood Plan also confirms that there are eleven local
green spaces (LGS), namely:
• LGS1: Rogate Recreation Ground;
• LGS2: Terwick Woodland;
• LGS3: Garbetts Wood;
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ONS (no date): Census 2011: Tenure-Households 2011
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ONS (no date): Census 2011: Highest Level of Qualification 2011
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ONS (no date): Census 2011: ‘Occupation 2011’ (Table KS608EW)
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• LGS4: Hugo Platt play area and public open space;
• LGS5: Oliver’s Piece;
• LGS6: Lupin Field, Terwick;
• LGS7: Chapel Common SSSI and SNCI;
• LGS8: Durford Heath;
• LGS9: Rake Hanger SSSI;
• LGS10: Fyning Moor SSSI; and
• LGS11: Weavers Down.
Summary of future baseline
As the population of the Neighbourhood Plan area continues to increase and age, this could potentially
negatively impact upon the future vitality of the local community and economy of certain parts of the
Neighbourhood Plan area, whilst also placing additional pressures to existing services and facilities.
The suitability (e.g. size and design) and affordability of housing for local requirements depends on the
implementation of appropriate housing policies through the Local Plan and Neighbourhood Plan.
Unplanned development may have wider implications in terms of transport and access to
infrastructure, or the natural environment.
A8 – Health and Wellbeing
Context review
Key messages from the NPPF include:
• One of the three overarching objectives of the NPPF is a social objective to; ‘support strong,
vibrant and healthy communities, by ensuring that a sufficient number and range of homes can
be provided to meet the needs of present and future generations; and by fostering a well-
designed and safe built environment, with accessible services and open spaces that reflect
current and future needs and support communities’ health, social and cultural wellbeing.‘
• ‘Planning policies and decisions should aim to achieve healthy, inclusive and safe places which
enable and support healthy lifestyles, especially where this would address identified local
health and wellbeing needs – for example through the provision of safe and accessible green
infrastructure, sports facilities, local shops, access to healthier food, allotments and layouts
that encourage walking and cycling.’
• Policies and decisions should take into account and support the delivery of local strategies to
improve health, social and cultural well-being for all sections of the community.
• Access to a network of high-quality open spaces and opportunities for sport and physical
activity is important for the health and wellbeing of communities. Development should avoid
building on existing open space, sports and recreational buildings and land, including playing
fields.
• Promote the retention and development of local services and community facilities such as
local shops, meeting places, sports venues, cultural buildings, public houses and places of
worship.
In relation to other key national messages in relation to health, Fair Society, Healthy Lives
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(‘The
Marmot Review’) investigated health inequalities in England and the actions needed in order to tackle
86
The Marmot Review (2011) The Marmot Review: Implications for Spatial Planning [online] available to download from: <
https://www.nice.org.uk/media/default/About/what-we-do/NICE-guidance/NICE-guidelines/Public-health-guidelines/Additional-
publications/Spatial-planning/the-marmot-review-implications-for-spatial-planning.pdf > last accessed [24/09/18]
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them. Subsequently, a supplementary report was prepared providing additional evidence relating to
spatial planning and health on the basis that that there is: “overwhelming evidence that health and
environmental inequalities are inexorably linked and that poor environments contribute significantly to
poor health and health inequalities”.
The increasing role that local level authorities are expected to play in providing health outcomes is
demonstrated by recent government legislation. The Health and Social Care Act 2012 transferred
responsibility for public health from the NHS to local government, giving local authorities a duty to
improve the health of the people who live in their areas. This will require a more holistic approach to
health across all local government functions.
At the local level, the South Downs PMP sets out 11 ‘Outcomes’ through which the Management Plan
is to be delivered. The key Outcomes relevant to the health and wellbeing theme are as follows:
• Outcome 5: Outstanding visitor experiences are underpinned by a high-quality access and
sustainable transport network providing benefits such as improved health and wellbeing. „
• Outcome 6: There is widespread understanding of the special qualities of the National Park
and the benefits it provides.
The revised South Downs PMP, which is currently being developed, is also likely to have a more
specific Outcome relating to health. This will be included in the new version of the PMP, which will be
adopted later in 2019.
The following policies within the emerging South Downs Local Plan directly relate to the health and
wellbeing SEA theme:
• Strategic Policy SD6: Safeguarding Views;
• Strategic Policy SD7: Relative Tranquillity;
• Strategic Policy SD9: Biodiversity and Geodiversity;
• Strategic Policy SD19: Transport and Accessibility;
• Development Management Policy SD46: Provision and Protection of Open Space, Sport and
Recreational Facilities and Burial Grounds / Cemeteries; and
• Development Management Policy SD47: Local Green Spaces.
Summary of current baseline
Joint Strategic Needs Assessment
At the regional level, the 2018 Joint Strategic Needs Assessment (JSNA) summary for West Sussex
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provides a variety of statistics relating to the following themes: environment, population, assets and
health/wellbeing, and provides a section on each broad life-stage of the population: childhood (starting
well), working age (living well) and older age (ageing well). Summary of the key challenges as follows:
• Year-on-year changes in the 65 and over population, averaging +2,500 per year between 2002
and 2017, with a projected average of +4,800 per year between 2017 and 2032;
• In 2016/2017, 19.3% of adults were estimated to be physically inactive;
• 60% of adults and 29% of 10/11-year olds are overweight (including obese);
• Violent crime (as measured by the rate of recorded violent crime including sexual offences per
1,000 population) has been increasing in West Sussex, and nationally, in recent years. In
2016/17 there were a total of 13,567 recorded offences compared with 9,740 in 2014/15;
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West Sussex Health and Wellbeing Board (2018): ‘JSNA Summary’, [online] available to access via:
<https://jsna.westsussex.gov.uk/updates/west-sussex-jsna-summary-2018/> last accessed [15/04/19]
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• The rate of people killed or seriously injured on the roads remains high in West Sussex. The
rate for 2014-16 of 56.8 per 100,000 is significantly higher than England (39.7) and the 4th
highest amongst comparable authorities; and
• It is estimated that 117,400 adults (aged 16+) in West Sussex are likely to have a common
mental health problem, namely: generalised anxiety disorder, depression, phobias, obsessive
compulsive disorder or a panic disorder.
Public Health Profile for West Sussex
Published in July 2018 by Public Health England, the public health profile for Chichester district
outlines the following key trends
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:
• Life expectancy for both men and women is higher than the England average;
• Life expectancy is 3.9 years lower for men and 3.8 years lower for women in the most deprived
areas of Chichester than in the least deprived areas;
• Estimated levels of adult physical activity are better than the England average; and
• The rate of people killed or seriously injured on roads is worse than average.
Health indicators and deprivation
Deprivation is a significant contributor to poor health and can have adverse effects on wellbeing, with
elements related to poor housing quality, living environment, income and employment, as previously
discussed in detail in Chapter 8. Based on 2011 Census data
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, 84.8% of residents in the
Neighbourhood Plan area consider themselves as having ‘very good health’ or ‘good health’, slightly
higher than totals for Chichester (82.6%), the South East of England (83.7%) and England (81.4%).
Similarly, the percentage of residents in the Neighbourhood Plan area considering themselves to have
‘bad health’ or ‘very bad health’ (3.1%) is lower than the totals for Chichester (4.3%), South East (4.4%)
and England (5.4%).
the total number of residents within the Neighbourhood Plan area who report that their activities are
limited ‘a lot’ is lower than the regional and national trends, while the total number of residents who
report their activities are limited ‘a little’ is slightly higher than regional and national trends. Overall,
83.2% of residents report their activities are not limited, which is broadly in line with regional and
national trends
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.
Summary of future baseline
Health and wellbeing levels within the Neighbourhood Plan area are generally good, with a higher
percentage of residents reporting ‘good’ or ‘very good’ health compared to regional and national
trends, and a low percentage of residents reporting that their activities are limited in some way.
The JSNA for West Sussex indicates that between 2017 and 2032 there will be projected increase in
the population aged 65 or over of over 4,800 per year. An ageing population within the Neighbourhood
Plan area might place future pressures on health services in the area. Similarly, ongoing cuts to
community services have the potential to lead to effects on health and wellbeing over the long term.
In addition to the main challenges outlined in the JSNA for West Sussex, obesity is seen as an
increasing issue by health professionals, and one that will contribute to significant health impacts on
individuals, including increasing the risk of a range of diseases, including heart disease, diabetes and
some forms of cancer.
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Public Health England (2018): ‘Public Health Profile for Chichester’, [online] available to access via:
<https://fingertips.phe.org.uk/profile/health-profiles> last accessed [15/04/19]
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ONS (no date): Census 2011: ‘General Health 2011’
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ONS (no date): Census 2011: ‘Long-term Health Problem or Disability 2011’ (Table QS303EW)
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A9 – Transportation
Context review
European and UK transport policies and plans place emphasis on the modernisation and sustainability
of the transport network. Specific objectives include reducing pollution and road congestion through
improvements to public transport, walking and cycling networks and reducing the need to travel.
National policy also focuses on the need for the transport network to support sustainable economic
growth.
Key messages from the NPPF include:
• ‘Transport issues should be considered from the earliest stages of plan-making and
development proposals, so that:
i. The potential impacts of development on transport networks can be addressed
ii. Opportunities from existing or proposed transport infrastructure, and changing
transport technology and usage, are realised
iii. Opportunities to promote walking, cycling and public transport use are identified and
pursued
iv. The environmental impacts of traffic and transport infrastructure can be identified,
assessed and taken into account
v. Patterns of movement, streets, parking and other transport considerations are integral
to the design of schemes, and contribute to making high quality places.’
• ‘Significant development should be focused on locations which are or can be made
sustainable, through limiting the need to travel and offering a genuine choice of transport
modes. This can help to reduce congestion and emissions, and improve air quality and public
health. However, opportunities to maximise sustainable transport solutions will vary between
urban and rural areas, and this should be taken into account in both plan-making and decision-
making.’
At the local level, each Local Transport Authority in England and Wales has a statutory duty to produce
and adopt a Local Transport Plan through the Local Transport Act 2000, as amended by the Local
Transport Act 2008. In this regard, the West Sussex LTP3 2011-2026 is a strategic policy tool through
which the council exercises its responsibilities for planning, management and the development of
transport in the county
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. The four strategies within the LTP3 that guide the Council’s approach to
maintaining, managing and investing in transport include: promoting economic growth, tackling climate
change, providing access to services, employment and housing, and improving safety, security and
health.
At the local level, the South Downs PMP sets out 11 ‘Outcomes’ through which the Management Plan
is to be delivered. The key Outcome relevant to the transportation theme is as follows:
• Outcome 5: Outstanding visitor experiences are underpinned by a high-quality access and
sustainable transport network providing benefits such as improved health and wellbeing.
The following policies within the emerging South Downs Local Plan directly relate to the health and
wellbeing SEA theme:
• Strategic Policy SD19: Transport and Accessibility;
• Strategic Policy SD20: Walking, Cycling and Equestrian Routes;
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West Sussex County Council (2011): ‘West Sussex LTP3’, [online] available to access via:
<https://www.westsussex.gov.uk/about-the-council/policies-and-reports/roads-and-travel-policy-and-reports/west-sussex-
transport-plan-2011-26-ltp3/> last accessed [15/04/19]
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• Strategic Policy SD23: Sustainable Tourism;
• Strategic Policy SD45: Green Infrastructure;
• Development Management Policy SD21: Public Realm, Highway Design and Public Art; and
• Development Management Policy SD22: Parking Provision.
Summary of current baseline
Rail Network
There are no railway stations within the Neighbourhood Plan area. The nearest mainline railway station
is Liss, located approximately 5 km north-west of Rogate. Operated by South Western Railway,
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Liss
Station provides regular services to London Waterloo (to the east) and Portsmouth (to the south).
Bus Network
Four Stagecoach-operated bus services serve the plan area: these are routes 54, 91, 92, 93. The bus
routes connect residents in the Neighbourhood Plan area to settlements in the wider area including
Chichester (to the south), Midhurst (to the east), and Petersfield (to the west).
Road Network and Congestion
The Neighbourhood Plan area is well connected to the highways network, including via the A272, A3
and B2070. These routes provide connections to the City of Portsmouth and to London.
The ‘Rogate and Rake Traffic and Travel Background Paper’
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was produced for the pre-submission
documentation for the Neighbourhood Plan. The paper notes that there are “material traffic volume
and speed problems within the villages [of Rogate and Rake]” associated with the main roads.
The paper also notes “a significant level of through traffic: between Petersfield and Midhurst and
beyond on the A272; between Petersfield and Liphook on the B2070; and, to a lesser extent, north-
south with traffic from villages to the south accessing the A3 at Liphook”.
Cycle and Footpath Network
National Cycle Route 22 runs close along the western border of the Plan area. There are also networks
of footpaths across the Plan area, including the ‘Sussex Border Path’: a long-distance trail extending
approximately 240 km across the inland borders of Sussex
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.
Availability of cars and vans
Based on 2011 Census data
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, 90.8% of household in the Neighbourhood Plan area have access to at
least one car or van, a higher percentage than district (84.4%), regional (81.4%) and national (74.2%)
levels. Households in the Neighbourhood Plan area also have a higher rate of ownership of two or more
cars/vans at 59.2% in comparison to the totals for Chichester (42.4%), the South East (39.7%) and
England (32.0%).
Travel to Work
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National Rail (2019) ‘Liss [LIS]’, [online] available at:
http://ojp.nationalrail.co.uk/service/ldbboard/dep/LIS?_ga=2.126508424.483316581.1557240499-1610432557.1556718008
[accessed 07/05/19]
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Rogate and Rake Plan (2016) ‘Traffic and Travel Background Paper’, [online] available at:
http://www.rogateandrakeplan.co.uk/docs/traffic-and-travel-background-paper-version-16-pre-submission.pdf [accessed
07/05/19]
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West Sussex County Council (no date): ‘Sussex Border Path’, [online] available to access via:
<https://www.westsussex.gov.uk/leisure-recreation-and-community/walking-horse-riding-and-cycling/sussex-border-path/>
last accessed [13/05/19]
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ONS (no date): ‘Car or Van Availability 2011’
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The most popular method of travelling to work in the plan area is by car or van (43.2%), higher than the
totals for Chichester (39.7%), the South East (39.7%) and England (37.0%). Fewer economically active
residents choose to walk or cycle to work in comparison to the regional and national trends. A higher
percentage of residents in the Neighbourhood Plan area choose to work mainly at or from home in
comparison to the regional and national trends.
Summary of future baseline
New development has the potential to increase traffic and cause congestion within the
Neighbourhood Plan area, principally at junctions on key routes. This is likely to continue to be more
pronounced at weekends and during peak times of year (i.e. holiday seasons) due to the setting of the
Neighbourhood Plan area within the boundaries of the South Downs National Park. Public transport
use is likely to remain low compared with private car use. This is due to the relative inaccessibility of the
neighbourhood Plan area via public transport, particularly in the absence of a train station. A greater
proportion of residents in the Neighbourhood Plan area choose to work from home compared to
regional and national trends, reflecting a national shift towards more flexible working practices.
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