Policy DM19: Chichester Harbour Area of Outstanding Natural Beauty (AONB)

s85 of the National Parks and Access to the Countryside Act 1949 as amended provides a duty to have regard to conserving or enhancing the natural beauty.

The requirement in criterion 1 is onerous as there will be cases where it is impossible to demonstrate 'enhancement', particularly for more minor development.

Views of the cathedral from the harbour, any part of the AONB and Salterns Way cycle path should be protected

The second sentence in the introduction is weak
Note that the Third Review of the Chichester Harbour Management Plan 2019-2024 is about to be published and will ;likely supersede its current Management Plan before the Chichester Local Plan Review comes to Examination.

Resident of West Wittering
The A286 Southern Link will have a major impact on the AONB and views from it toward the Cathedral.

It is incomprehensible how anyone who lives in this area would contemplate permission for the number of homes that are being forced upon the local communities when this part of the country is so special. One would have to be blind not to look at a map of the South East of England and realise its slow death from concrete and congestion and here - especially west of Chichester is the last remaining foothold of sanity along the coast.
Chichester, a beautiful County Capital, is a Roman walled city with a Georgian centre - its roads reflect this wonderful heritage - THEY WERE NOT MADE FOR MODERN TRAFFIC LEVELS. This has a knock-on effect upon nearby villages including FISHBOURNE. The position of the Chichester Plains including FISHBOURNE is that it is caught between the SDNP and the sea. But that is no reason to concrete it over. All this is in YOUR CARE.Y

FISHBOURNE - The Present State
Fishbourne cannot be accused of Nimbyism - it has built more than the required number of houses requested on sensitive, sustainable sites and therefore there is no moral justification whatsoever to inflict the community with 250 more. There has been no explanation as to why this number and why Fishbourne from the CDC. Apparently the CDC has decided to classify Fishbourne as a 'service village'. Has anyone actually been to Fishbourne to verify this classification?
The truth is:
Fishbourne Parish Council has already submitted and enacted upon the Neighbourhood Plan with the full involvement and support from the local community.
Fishbourne has already reached its boundaries. It is crucial to the well being of communities and in the spirit of the Government's policies to prevent 'coalescence' of villages.
Fishbourne is a Conservation Area and the FISHBOURNE MEADOWS are a crucial part of it.
The Primary School is already filled with children from the catchment area. The Fishbourne Centre is so popular it is functioning at full capacity. The local church and its hall is likewise functioning at full capacity. The Fishbourne Playing Field facilities provide not only tennis courts, bowls, croquet, cricket, etc. and a fully equipped children's outdoor secure play area. All these are used on a regular basis. There is no doubt that Fishbourne is a thriving and active community and therefore there is NO CASE for further growth.

The Disastrous Consequences of Mass Unnecessary and Unwanted Development
If this is 'forced' upon the community it will break every democratically arrived at Policy of the Parish Council and anger the vast majority of residents for, by permitting a few houses on Bethwines Farm will open up the floodgates to 1000. This will destroy valuable green field agricultural land. It will exacerbate flooding. Will cause untold traffic congestion for with every household there will be two cars as a minimum creating gridlock on local roads. Will heighten the already dangerous levels of air pollution. The local sewerage plant in Apuldram is already at breaking point. All this on top of the already permitted 1600 homes at Whitehouse Farm north of Fishbourne. The chaos and damage to the roads, the noise, the mud, the dust, potential danger to locals due to confined sites etc during construction which could take years not months. The agricultural land in this area is of special importance to the national production of horticulture. It provides employment to 9,000 and creates £1 billion in sales - substantial statistics.
CHICHESTER HARBOUR
Is an AONB, an SSSI, a Ramsar, an SAC, an SPA, an SINC/SNCI, a Conservation Area, a Local Wildlife Site, and a Local Nature Reserve. This is the JEWEL IN THE CROWN. It is the duty of every citizen, especially those in Authority, to safeguard this valuable, irreplaceable asset, unharmed for the nation and future generations. NOTHING should be permitted that would endanger it in any way. So why is the Chichester District Council not fighting the Government to protect it? To protect it from:
Mass Developments that are not NEEDED that will damage the waters through flooding - including Apuldram sewerage outflow, will create pollution from additional traffic, will disturb the wildlife and tranquillity from growing disturbances, will create light pollution, and with the growth in population create damaging levels of litter, and many more.
A259 -Main Road
This is the only access for all the developments being planned and being built in Bosham, Chidham, Nutbourne and Southbourne (hundreds and in some instances thousands) that will accumulate at Fishbourne roundabout in order to access the A27 and the City. This route is the only one that all delivery trucks and all agricultural machinery can use. The traffic will continue to grow along this road as the bus schedules are being cut and the SW train service seems to be in permanent decline. This road is also the boundary to the Chichester Harbour Trust. How then will the CDC enforce the protections of the Trust? AIR POLLUTION
AIR POLLUTION
The UN in June 2017 is quoted as saying: 'Air pollution is Europe's leading environment killer'.
NAEI have a map of the Chichester Plains where the average levels are 0.1 - 0.3 but Fishbourne and Donnington roundabouts already reach 25!
Friends of the Earth are quoted as saying 'Costs to the UK of air pollution runs to £20 billion.
Living Streets say '80% of toxic nitrogen oxide concentrations are found at roadsides from motor traffic'.
'40,000 deaths annually are attributed to air pollution'
'38 out of 43 UK zones exceeded legal levels of nitrogen oxide emission in 2013.'
The UK is breaking the law with its current air pollution levels.
We now have children dying with 'air pollution' on their death certificates.
THE LEVELS AT FISHBOURNE ROUNDABOUT ARE ALREADY BREAKING LEGAL LIMITS
So what will these levels reach :
When all these 2250 scheduled developments with two cars per unit take place using the only road available - A259.
When the TRAFFIC DOUBLES OVER THE THREE SUMMER MONTHS creating gridlock down to the Manhood Peninsular
When your proposed Stockbridge link road - whose construction will break all the criteria laid down in the CDC policies by building across major flood plains, by restricting the protected views of the Cathedral, by building on the protected Fishbourne Meadows and into the AONB of Chichester Harbour, and end up TAKING ALL THE TRAFFIC ON TO THE FISHBOURNE ROUNDABOUT.
WILDLIFE CORRIDOR
The last minute offer of a Wildlife Corridor in an attempt to mitigate the horrors being inflicted upon this community you have placed in a narrow strip to the east of the village. This will immediately be irrelevant for it is too narrow, will pass through a built up environment which will lead to disturbances throughout the day, will lead to noise pollution, will lead to light pollution and will therefore NOT PROVIDE a safe haven for any wildlife. The obvious position for such a corridor would be to the WEST of FISHBOURNE where the open agricultural green field sites will enable all forms of wildlife to access both the Harbour Conservancy and the National Park safely.
THE A27
What is the point of this whole exercise when there has been no decision on the route of the A27. Until the CDC issues correct data on present traffic flows, until the CDC issues correct data on 'projected' traffic flows, until the CDC recognises that this is a NATIONAL STRATEGIC road and NOT A LOCAL road, until the CDC re presents the NORTHERN option, then no permissions for further developments should take place.
The Secretary of State for Housing is quoted as saying: 'The message it (NPPF) sends is clear and direct; we want the right number of homes in the right places. CENTRAL TO THIS IS THE VOICE OF THE COMMUNITIES.'
As the community's elected representatives it is your duty to protect the National Assets in this area. It is your duty to provide 'sustainable' developments that do not create or add to the highway safety, air pollution or any other damage to your communities. This area does not NEED new three/four bedroom houses. What it does need is AFFORDABLE housing. Part of the relief could come from allowing Affordable housing in the SDNP which would halt the decline of the communities, fill the empty schools, and provide continuing regeneration. Jake Berry MP in the Ministry of Housing has said that WHERE HOUSING IS NEEDED IS IN THE NORTH where the region is undergoing regeneration and businesses are relocating.
THE FISHBOURNE COMMUNITY
The Fishburne community has acted in good faith throughout this whole exercise. It is now up to the CDC to support it.

Given the area of land that is taken up by AONB's in the UK, it must be capable of taking its share of considered new housing development, especially when in doing so the land within the AONB can be enhanced. It is essential that the requisite statutory bodies work collectively to get the right approach here assuring development is measured within an AONB, this in my view can mean small scale development where the views are protected and with land enhancement assured.

The SDNPA and all relevant authorities are required to have regard to the purposes of the South Downs National Park (SDNP) as set out in Section 62 of the Evironment Act 1995. The purposes are 'to conserve and enhance the natural beauty, wildlife and cultural heritage of the area' and 'to promote opportunities for the understanding and enjoyment of the special qualities of the national park by the public.' The Authority would appreciate reference to Section 62 being added to
paragraph 1.31 of the draft Plan.

Duty to Cooperate

As set out in our previous response, the SDNPA has a set of six strategic cross-boundary priorities.
I would like to take the opportunity to again highlight these which provide a framework for ongoing Duty to Cooperate discussions:
* Conserving and enhancing the natural beauty of the area.
* Conserving and enhancing the region's biodiversity (including green infrastructure issues).
* The delivery of new homes, including affordable homes and pitches for Gypsies, Travellers and Travelling Showpeople.
* The promotion of sustainable tourism.
* Development of the local economy.
* Improving the efficiency of transport networks by enhancing the proportion of travel by sustainable modes and promoting policies which reduce the need to travel.

Conserving and enhancing the natural beauty

We welcome the requirement in policies S26 (Natural Environment) and DM28 (Natural Environment) to ensure that development proposals have no adverse impact on the openness of views and setting of the SDNP. It is noted that a substantial amount of new homes are proposed on the A259 corridor between Emsworth and Chichester. This is a sensitive stretch of land in the coastal
plain between the coast, the south coast railway and the A27. This corridor provides the connection, including intervisibility, between the protected landscapes of the South Downs National Park and Chichester Harbour AONB, for example views of the channels within the Harbour from the Trundle and Stoke Clump.
We note the intention of identifying settlement gaps and look forward to seeing the evidence base and the proposed gaps in the Regulation 19 iteration of Chichester Local Plan Review 2035, particularly as to how they will contribute to safeguarding the relationship between the SDNP and Chichester Harbour AONB. We would welcome the opportunity to work with CDC on this matter.

Locations identified for development

Development in the CDC Local Plan Review 2035, particularly along the A259 (policies AL7 Highgrove Farm Bosham, AL9 Fishbourne Parish, AL10 Chidham and Hambrook Parish, AL13 Southbourne Parish) corridor, have the potential to deliver a significant cumulative adverse impact on the setting of the National Park and its important relationship with the Chichester Harbour AONB.
We consider that the policy wording for the A259 corridor Strategic Site Allocations could be more robust and proactive with regard to conserving and enhancing the National Park. In particular, it could provide more active direction to applicants in order to ensure adverse impacts are minimised locally, and in relation to the National Park. For example, with regard to green infrastructure, each of the
A259 Strategic Site Allocation policies (AL7, AL9, AL10 and AL13) include a criteria requiring the provision of green infrastructure, and we would suggest this could be re-worded as follows: 'Identify opportunities are taken for and secure the expansion and provision of multifunctional green infrastructure into the wider countryside and protected landscapes of the South Downs National Park, and Chichester Harbour AONB, including between settlements and facilities.'

Reference to considering and minimising impact on the SDNP in each of the A259 Strategic Site Allocation policies (AL7, AL9, AL10 and AL13) is welcomed, for example criterion 5 of policy AL9:
Fishbourne Parish. However, this could be usefully re-worded to ensure that developers do not create a scheme and only consider the impact afterwards. Wording to direct people to 'respect and respond to the National Park landscape, its setting and purposes prior to development design' avoids the risk of relying upon ill-informed and inappropriate mitigation measures This matter could also be usefully
addressed in relevant Strategic and Development Management policies elsewhere in the Local Plan concerning design, landscape, and the South Downs National Park. We would be happy to work with CDC on this matter.

We note Strategic Policy S32, which requires proposals for housing allocations and major development sites to be accompanied by a site-wide design strategy. We would strongly encourage masterplans and development briefs for each allocation (or settlement where the sites are to be allocated through a Neighbourhood Plan) to come ahead of applications and demonstrate positive design interventions which respond directly to landscape/SDNP sensitivities. We would be happy to be involved in shaping these as consultees in order to achieve the best quality scheme. These interventions could be written in to the policy wording.

There is an opportunity for allocation policies to seek to deliver the joining up of existing, and/or improvements to, the network of RoW (Equestrians, Cyclists and Pedestrians) to enable and encourage access into the National Park in accordance with the National Park's Second Purpose.
Further comments on specific allocations:
* Policy AL1 (Land West of Chichester) - We welcome the consideration of the Centurion Way in criteria 10. However, we would ask for stronger policy wording to explicitly state that development must not adversely affect, and preferably enhance usability of, Centurion Way connecting Chichester with the SDNP.
* We note that Policy AL4 (Land at Westhampnett/NE Chichester) still refers to Lavant Valley greenspace but we query if this is likely to be secured now based on planning applications submitted. We would suggest that criteria 12, last sentence, could also refer to securing offsite improvements/upgrades for cycleway links
* Policy AL6 (Land South-West of Chichester (Apuldram and Donnington Parishes)) should address the important opportunity to secure a safe off-road connection between the Centurion Way and Salterns Way as the two flagship and largely safe off-road multi-user trails linking Chichester with (respectively) SDNP and Chichester Harbour AONB. We would welcome the opportunity for further dialogue and joint working on this matter with CDC.
* We welcome criterion 5 of policy AL14 (Land West of Tangmere). It is a sensitive site due to the impact on clear views of the site from important locations in the SDNP such as the Trundle and Halnaker Hill. We therefore ask that criterion 5 is expanded to emphasise and address the sensitivity of the site
Specific wording comments on other policies/paragraphs:

We have the following comments on the following specific paragraphs:
* Para 2.29 (challenges and opportunities facing the Plan Area): We suggest that the 7th bullet point should say 'Protect and enhance the character of the area including the Chichester Harbour AONB and the setting of the SDNP'.
* Policy S20 (Design): As mentioned above regarding the A259 Strategic Site Allocation policies, we consider that the wording of this policy could be more proactive by including wording to direct people to 'respect and respond to the National Park landscape, its setting and purposes prior to development design'.
* Policy S25 (The Coast): Paragraph 5.44: We suggest adding 'serves to provide important scenic views from the water across to the SDNP which should be conserved'.
* Policy S26 (Natural Environment): We suggest deleting reference to 'openness' and to include reference to views from and to the National Park.
* Policy S32 (Design Strategies for Strategic and Major Development Sites): We suggest that the policy requires such design strategies to be informed by landscape character and the sites landscape context. We also suggest that criteria h. includes a requirement to state maximum building heights.
* Policy DM17 (Stand-alone Renewable Energy): The policy requirement for demonstrating no significant adverse impact upon landscape or townscape character is welcomed. We request reference is also made specifically of views of the SDNP.
* Policy DM19 (Chichester Harbour AONB): We request criterion three also identifies the relationship by way of intervisibility between the AONB and SDNP.
* Policy DM22 (Development in the Countryside): Further to comments on the A259 Strategic Site Allocation policies and S20 (Design), we consider that the wording of this policy could be more proactive by including wording to direct people to 'respect and respond to the National Park landscape, its setting and purposes prior to development design'.
* Policy DM23 (Lighting): The reference to the South Downs International Dark Skies Reserve is welcomed. However, proposals that aren't immediately adjacent to the Reserve may have significant adverse impact, for example due to the site's particular visibility within the landscape or sky glow; we suggest that wording is amended to reflect this.
* Policy DM32 (Green Infrastructure): We suggest that this policy could benefit from specifically citing that green infrastructure should be 'multifunctional'. We also recommend reference to opportunities to make better green infrastructure connections in line with Lawton Principles of 'bigger, better, more joined up', to ensure these spaces can function and therefore deliver benefits.

Conserving and enhancing the region's biodiversity (including green infrastructure).

The SDNPA welcomes the approach taken by CDC to identify green infrastructure and habitats networks as cross boundary issues in paragraph 1.26 of the Plan. The SDNPA looks forward to continuing to work with CDC on green infrastructure matters particularly as your Plan is progressed to pre-submission.

We note that an open space study has been prepared and this could be linked up with other work into a wider green infrastructure approach incorporating the identified strategic wildlife corridors, areas for natural flood management, PROW and connections between the settlements, protected landscapes and the stations, landscape views/settlement gaps and some land management guidelines
for these really important areas. This would be particularly useful to inform development proposals in the A259 corridor.

Policy SD30 - Strategic wildlife corridors

The SDNPA very much welcomes and supports the inclusion into policy of wildlife corridors which traverse the district connecting the two protected landscapes of the Chichester Harbour AONB and the SDNPA.

It is important to note that there is no corresponding policy within South Downs Local Plan, currently at examination, to continue protection of the wildlife corridors within the SDNP. We have concerns that it is unlikely to be sufficient for the corridors just to reach the SDNP boundary. We also note that several of the corridors appear to be quite narrow, especially to the east of the City, and we query whether they are substantial enough to perform the intended function.

We note the detailed evidence outlined in the background paper and the SDNPA would like to work with CDC on the continued development of the strategic wildlife corridors, in particular with regard to their connection points with the National Park and how we can work together on robustly delivering this strategic cross boundary objective.

Ebernoe Common, The Mens, and Singleton & Cocking Special Areas of Conservation

The SDNPA has been working together on technical advice to facilitate sustainable development within proximity Ebernoe Common, The Mens, and Singleton & Cocking Special Areas of Conservation, which are designated for their populations of Bechstein and barbastelle bats. The draft Sussex Bat Special Area of Conservation Planning and Landscape Scale Enhancement Protocol was published in 2018 in the Core Document Library as part of the South Downs Local Plan Examination. The Protocol is based on published data which identifies key impact zones, one of 6.5km and one of 12km, around each of the three SACs. It also sets out avoidance, mitigation, compensation and enhancement measures to inform and be addressed by development proposals. Parts of the Chichester District Local Plan area are within these key impact zones. These zones have been incorporated into policy SD10 of the South Downs Local Plan and the policy has not been modified by the Inspector as a result of the examination in public. The SDNPA would welcome the opportunity for further discuss with CDC and Natural England on this work.
Solent Recreation Mitigation Partnership

Both CDC and the SDNPA are members of the Solent Recreation Mitigation Partnership (SRMP) (also known as Bird Aware Solent) which has provided a strategic mitigation solution to address potential harm to the protected habitat at Chichester Harbour and ensuring compliance with the Habitats Regulations. We note that the SRMP mitigation solution is reflected in Policy DM30 and we look forward to continuing to work with CDC and other members of the SRMP on this matter.
With regard to paragraph 7.185 we suggest reference to the Medmerry Realignment be a new bullet point: 'Medmerry realignment, which is intertidal habitat created in 2013 to compensate for historic losses across the Solent to SSSI and Natura 2000 sites'.
We also suggest the following wording amendment to paragraph 7.187: '...This is particularly relevant to Chichester and Langstone Harbour and Pagham Harbour and the impact of recreational pressure on the birds that use these Special Protection Areas. Any negative impacts that the development may have should will be weighed against the benefits of the proposal. This may include looking at whether the assets are surplus to requirements, if the proposal impacts on a small area or corridor or if a wider need exists for the development and there is no alternative location....'

The delivery of new homes, including affordable homes and pitches for Gypsies,
Travellers and Travelling Showpeople

Policy S4: Meeting Housing Needs
The SDNPA welcomes the uplift to the housing target to address unmet need arising in that part of the SDNP within Chichester District (estimated at 44 dpa at the time the last Statement of Common Ground was agreed in April 2018). The provision of 41 dpa broadly meets this need.
We note that the Objectively Assessed Need is calculated only for the area outside the SDNP using the 'capping' method set out in the Government's standard methodology (the currently adopted target of 435 dwellings per annum plus 40% = 609) - this is helpful as it makes a clear distinction between the assessed need for Chichester District Local Plan area and that for the SDNPA, notwithstanding
the Duty to Cooperate.

Policy S5: Parish Housing Requirements 2016-35
We support identification of parish specific housing requirements providing certainty to local communities. This is the same approach as we have taken in the South Downs Local Plan.

Affordable housing
We note that there is a need for 285 affordable homes per annum (source: HEDNA) which underlines the need for a strong policy which seeks to maximise affordable housing delivery. This high level of need is common to the wider sub-region and is an issue relevant to the wider housing market area.
The SDNPA supports CDC's approach of taking opportunities arising from new residential development to contribute to the supply of affordable housing, to meet local needs in terms of type and tenure (paragraph 4.35). In this respect, it is important that the whole plan viability testing currently being undertaken should fully reflect Planning Practice Guidance on viability, such that as high as possible a percentage of affordable housing is sought. We also support the positive approach to Community Land Trusts (CLTs) as a mechanism for delivering affordable housing (paragraph 4.45). Chichester District Council may also wish to note that SDNPA has, subject to main modifications consultation, received the go-ahead from its Local Plan Inspector for unmodified inclusion of Strategic Policy SD28: Affordable Housing in the South Downs Local Plan. This includes a lower threshold than that advised in Government policy, and also seeks on-site affordable housing from small sites below the 11 threshold stipulated in Government policy.

Policy S7: Meeting Gypsies, Travellers, Travelling Showpeoples' Needs
The SDNPA supports the principle of the policy and whilst noting the significant need arising. It is not clear whether the intention is to allocate sites to meet the need in a separate DPD. Paragraph 4.49
refers to 'the forthcoming DPD' and policy S7 to sites being allocated in a Site Allocation DPD 'where there is a shortfall in provision'. Has this work already been triggered by the scale of need? The policy and associated text could be clearer on this matter.
We would like to highlight that there is limited capacity within the National Park to allocate sites for Gypsies and Travellers through DtC, given significant landscape constraints. We suggest that the coastal authorities and SDNPA continue to work closely with regards addressing the need.

Improving the efficiency of transport networks by enhancing the proportion of travel by sustainable modes and promoting policies which reduce the need to travel
The SDNPA supports in principle Policy S23 (Transport and Accessibility). In particular, we support emphasis on encouragement of use of sustainable modes. We suggest explicit support in the text for improving links into the National Park, particularly by sustainable and active transport modes.
Allocation policies should also should seek to deliver the joining up of existing, and/or improvements to, the network of Public Rights of Way.

SDNPA notes reference in the policy to a coordinated package of improvements to the A27 Chichester Bypass, as well as to a new road from the Fishbourne roundabout. The SDNPA would urge that any such schemes be fully assessed, including streetlighting, for potential adverse impacts on landscape where there is a relationship with the National Park and its setting. Any such impact will
need to be mitigated, and opportunities taken to enhance green infrastructure networks and public rights of way networks. CDC may wish to consider whether the Policy S23 should include additional wording to reflect these principles.

Centurion Way
The SDNPA supports the reference to Centurion Way in paragraph 7.185 in relation to Green Infrastructure & resistance to dissection of green movement corridors. There are opportunities to improve these links, for example, suggest explicit reference to protecting and enhancing the Centurion Way. The reference to Salterns Way is also supported. Centurion Way and Salterns Way are two flagship off-road routes for the SDNP and AONB respectively and do not currently benefit
from safe off-road connection. The SDNPA would strongly support policy to secure this connection and would welcome opportunities to discuss this further and work jointly with CDC on this strategic issue.

With regard to Strategic Policy S14 (Chichester City Transport Strategy) we request that the SDNP is included in the penultimate bullet point as a destination for strategic cycle routes.

Transport evidence
We would highlight that the transport assessment carried out to inform the South Downs Local Plan.
This indicated a potential severe impact on the Petersfield Road / Bepton Road / Rumbolds Hill junction in Midhurst of additional development in the town, in the context of junctions already becoming overcapacity due to background traffic growth, for example, . arising from strategic development in neighbouring planning authorities.
A review of the CDC Transport Study of Strategic Development indicates significant traffic growth arising from Scenario 1 (the preferred strategy). It is not clear from the study how this will impact on the A286 towards Midhurst, which in turn could have a critical impact on junction capacity at Midhurst.
SDNPA may seek further assurance that such potential impacts have been looked at, and appropriate mitigation sought.
Other comments
Page 16 - Local Plan area map: Request clarification whether the Local Plan area includes the following two properties, as not clear from the Local Plan Area map: Stedlands Farm, and The Stable/Little Stedlands, Haslemere GU273DJ
We would like to wish you well in the progression of your Local Plan and would welcome further discussion and joint working on the strategic cross boundary matters raised.

We object to the allocation site at Highgrove Farm, Bosham with approximately 13 ha of open countryside allocated to a minimum of 250 houses.

This development in the countryside directly conflicts with policy S24 Countryside and Policy S26 the Natural Environment; which clearly states there should be no adverse impact on the openness of views in and around the coast, designated environmental areas (i.e. the AONB) and the setting of the South Downs National Park. The proposed development at Highgrove Farm directly contradicts these policies.

We strongly believe that this development would cause irretrievable harm to the landscape character, setting and context of Chichester Harbour AONB and the intervisibility with the South Downs National Park. We feel that the measures proposed within the policy would not be able to sufficiently mitigate for the damage this development would cause.

See attachment

See attachment

See attachment

See attachment