The 2015 Chichester Local Plan Inspectorate Report stated "Early proposals to locate strategic development to the south west and west of Chichester and at Fishbourne were discounted due to their environmental impact on the Chichester and Langstone Harbour Special Protection Area (SPA). Subsequently a mitigated strategy for recreational disturbance was developed and a solution to address the issue of waste water treatment emerged. This led to the strategic location for development West of Chichester being re-introduced. However, the SA report makes it clear that no such justification exists to re-introduce South West of Chichester or Fishbourne as locations for strategic development."

I and many others cannot find any evidence which has changed from this position since 2015 for CDC to include AL6 in the Local Plan Review 2035.

AL6 is one of several Policies to not have had a development location assessment in the Appendix of the Sustainability Appraisal which is in breach of Section 19 of the Planning and Compulsory Purchase Act 2004 requires a local planning authority to carry out a sustainability appraisal of each of the proposals in a Local Plan during its preparation.

Section 85 of the CRoW Act of 2000 requires relevant authorities to have regard to the purpose of the AONB 'in exercising or performing any functions in relation to, or so as to affect, land" in these areas. The AONB do not support this Policy and were not consulted on prior to its publication.

The NPPF states that great weight should be given to conserving and enhancing landscape and scenic beauty of AONBs (para 172).

Landscape Appendix: Chichester District Council Landscape Capacity Study states "Landscapes of great wildlife importance", "...the rural foreground in views to the Cathedral from Chichester Harbour", "... the landscape pattern that dates from the late post-medieval planned private enclosure associated with Apuldram Hamlet"

Against CPRE Policy of protecting and enhancing Landscape, Dark Skies, Hedgerows and Tranquillity.

AL6 - states the following:

Apuldram and Donnington Parishes 6.47 The impacts of development (including landscape, flooding and transport) in this location, along with the commercial attractiveness of the site, will need to be tested further as this local Plan Review is prepared. However based on initial assessment of the area so far, it is considered that there is potential to deliver significant development in this area which addresses the constraints of the site and its wider environment."

The development proposed would be on a Fluvial and Coastal Flood Plain 2 & 3 with significant risk of flooding. This is not mentioned in AL6. In AL4 (positioned on a Floodplain 1) 10. "Adoption of a comprehensive approach to flood risk management on the site, including consideration of surface water drainage as part of the masterplanning process;" why is this statement not also included in AL6? Is it because no actual thorough assessments set out in Policy S27 have been carried out? Strategic Flood Risk Assessment Level 1 and NPPF 2018 section on Planning and Flood Risk: Sequential test, Exception test and Environment Agency requirements. AL6 Policy is at complete odds with the Flood Risk and Water Management 5.54 "As a consequence of the rise in sea levels and storm surges, parts of the plan area will be at increasesd risk from coastal erosion, groundwater, fluvial and/or tidal flooding...villages are protected by sustainable means that make space for water in suitable areas."

Chichester Harbour Trust 's response to AL6 have voiced concerns against further deterioration in water quality leading to the downgrading of Chichester Harbour's SSSI status.

AL 6 in addition is adjacent to the Chichester Harbour (AONB, RAMSAR, SPA and SSSI sites) boundary which is not highlighted in AL6 Map and The Fishbourne Meadows Conservation Area, with the complete loss of the buffer zone outside the AONB . Breaching the SSI impact risk zone and negatively impacting the SAC, SPA and Ramsar designated areas. Contravening Policy DM28

Wildlife Habitats/Hedgerows- Destruction of habitat for protected species dependent on woodland edge, scrubland and rough grassland habitat.

Destruction of natural wildlife corridors and subsequent effect on biodiversity see Wildlife Corridor attachment. DM29 Biodiversity is at odds with AL6 as there is no adequate survey nor data to support the impact of the Wildlife with this development.

Negative impact on River Lavant Marsh SNCI site and associated vegetation including floodplain grazing (see attachment AL6 River Lavant SNCI)

Wildlife stepping stones- this piece of land is an existing wildlife stepping stone between Pagham and Medmerry Harbours, the historic Chichester Ship Canal and Chichester Harbour.

Urbanisation of the countryside contrary to policy S24 Countryside and destroys the separation of Stockbridge, Apuldram and Fishbourne which contravenes 3.7 Spatial Vision and Strategic Objectives-The East-West Corridor "maintaining and enhancing the countryside between settlements".

Landscape- destruction of the outstanding, historic and unique views of the Cathedral framed by the SDNP from Chichester Harbour (the only view of a Cathedral from the sea in England) and Salterns Way cycle path (see attached images) Contravening Landcape Policy 22, Policy DM28.

The destruction of this historic landscape will have a negative impact on Tourism and Wellbeing and contravenes the Vision and Objectives in the Plan along with Visit Chichester's Destination Management Plan statements:

Vision
"Follow a socially responsible and more environmentally friendly way of life, in the knowledge that the natural environment and biodiversity of the area is being conserved, managed and enhanced;"

"Enjoy...areas of attractive, accessible and unspoilt harbours, coast and countryside;"

Objectives
"...aims of the Chichester Vision" -
Economy- "Enable viability of the rural economy"

Visit Chichester's Destination Management Plan states that a key strength of Chichester's tourism economy is "Protected landscapes (Chichester Harbour and the South Downs) and the opportunities are "Coastal Tourism (Chichester Harbour and Selsey Coastal Trust)."

Agricultural Land- fields within AL6 are grade 1 agricultural land, some of which are covenanted to the National Trust. This rushed policy is at odds with Policy 26 Natural Environment "Considering the quality of the agricultural land, with development of poorer quality agricultural land being preferred to the best and most versatile land." Have the National Trust been consulted on this plan?

Soil Pollution affecting the AONB, River Lavant SNCI and The Fishbourne Meadows Conservation Area.

Air quality - loss of this part of the City's open space and one of its remaining green lungs, will have a negative effect on residents' health and wellbeing. The creation of a further AQMA is very likely at Fishbourne within the vicinity of the AONB with these junction changes and raised road.

HEDNA has identified a need for 23.2 hectares of additional employment sites; AL1, AL2, AL15 totals 12.4 hectares which leaves 10.8 hectares remaining. AL6 is proposed to have 33 hectares for employment development space. That is 3 times the requirement! See my response to Policy S8

Noise pollution from the industrial business units, and the minimum of 100 homes - disturbing and affecting the AONB Chichester Harbour natural inhabitants, not mentioned in the Local Plan

The proposed Link road slipped into the plan in September 2018 to facilitate the development on this site and is brushed over in this Policy as "a new link road". Not stating that it will need to be elevated to cross over the River Lavant and floodplain. Correspondence with the Environment Agency has confirmed this. "Where a road is crossing a watercourse we would seek a clear span design. This has the benefit of not only maintaining the continuity of flow routes but also are beneficial for biodiversity. We would look for any new road to be designed in such a way to manage any impacts to the environment from their drainage systems and therefore have no additional impact on the Harbour. We would not support surface water drainage from the development being connected to the Wastewater Treatment Works at Apuldram".

An elevated link road will negatively impact on the dark skies area of the AONB across this flat harbour area. The increase in noise pollution from the industrial park and raised road will destroy the value of the AONB, RAMSAR, SPA and SSSI sites. Any mitigation will obliterate the historic Landscape views of the Cathedral from the harbour.

The raised link road and Fishbourne roundabout alterations encroach 7,000m2 into The Fisbourne Meadow Conservation area. Any noise mitigation will further obliterate the historic Landscape views of the Cathedral from the harbour.

Local residents have already been consulted on the junction improvements in 2016 repeated in this plan the combination of Opt 2 & 3- the results 3% supported junction changes and 47% objected to the junction changes and link road, they understood the negative impacts stated in my comments on AL6. 56% voted to consult on a northern alignment. This begs the question, are those against a northern alignment for personal reasons within CDC putting in a southern alignment by stealth without consultation of another option?

Remove the employment development site and place the HENDA advised 10.8 hectares remaining in AL4.
Remove the housing development of minimum of 100 homes and country park and return them to the 41 per year SDNP allocation. The residents in the SDNP are crying out for affordable housing to meet the needs of undersubscribed local schools and shops are closing. At a Boxgrove Meeting in Autumn 2018 residents of the SDNP raised their frustration at their undersubscribed and in some cases closing primary schools alongside shops due to the lack of affordable homes in the SDNP to their MP Gillian Keegan.

Remove Stockbridge Link Road as there is no real need to waste funds building it and the subsequent environmental impact when employment and housing development can be placed elsewhere.

Is this raised link road being slipped in to allow for a business development and housing estate with a minimum of 100 homes and a country park? Or is the development an excuse to get the raised link road put in?

Development Plan & Infrastructure Panel (DPIP) is there to advise the Cabinet on Planning Matters including the Local Plan. It is appointed by the Cabinet and is Chaired by the Cabinet Member for Planning and also includes the Leader of the Council and Deputy Leader (who represents an SDNP Ward) both of whom are Cabinet Members also; the constitution allows for the Cabinet Member for Planning as Chairman and the Leader not for any other Cabinet Members. No agendas or Minutes of this panel's proceedings are published. Not withstanding the fact that it is within CDC's constitution this appears highly undemocratic and open to a lack of transparency or objectivity in plan making. This calls for a change in CDC's constitution.

I wish to take these points up with the examiner.