Natural England supports the aim of this policy in mitigating the impact of recreational disturbance on Pagham and Chichester Harbours SPAs. However, we suggest the following amendments:
- The policy is extremely long, and much of it is explanatory background, which could be moved into the supporting text.
- For the Pagham section, reference to the LNR Management Plan should be removed in clause 1. The joint scheme of mitigation is separate from the Management Plan, the latter is focussed on managing the current visitor experience, not mitigating additional visitor pressure. Therefore, whilst the joint scheme of mitigation should not hinder the LNR Management Plan, it does not need to be in accordance with it.
- It would be helpful to expand the parts of the policy on loss of functionally linked land, and make them distinct from the consideration of recreational disturbance impacts. It should also be made clear that the recreational disturbance part of the policy applies only to residential or tourist accommodation, whereas any type of development could impact functionally linked land.