Representation by South Downs National Park Authority (South Downs National Park Authority)
- Date submitted
- 20 October 2023
- Submitted by
- Local authorities
The application site is outside of the South Downs National Park, however the proposals will have some impact on the National Park, in particular in respect of tranquillity and dark night skies. Despite our offer to work with Gatwick Airport Limited (GAL) both at scoping and during the statutory consultation in 2021, we have not been approached by the applicant. At this stage, our main issues are as follows: 1. The impact on relative tranquillity within the National Park as a result of an increase in overflights, to the National Park as a whole and also over key sites including Petworth Park and Ditchling Beacon. The Landscape and Visual Impact Chapter of the Environmental Statement advises that there would be a minor adverse effect on the perception of tranquillity, based on there being an increase of 2 flights per day over either the central and/or eastern part of the National Park. There is no mechanism to control or limit the number of flights per day and this figure seems very low in relation to the overall increase in flights that would be enabled by the proposed development. 2. Effect on Dark Night Skies. The South Downs National Park is designated as an International Dark Night Skies Reserve. More overflights above the National Park will make it more difficult to view an authentic night sky. Regarding contrails it is also a potential concern – albeit a matter of debate – whether contrails seed small clouds that then make the sky more opaque. 3. It does not appear that the proposal has had regard to the National Park’s Statutory Purposes or the Special Qualities for which the National Park has been designated. The National Parks and Access to Countryside Act 1949, as amended by the Environment Act 1995, sets the following statutory purposes for National Parks: 1. To conserve and enhance the natural beauty, wildlife and cultural heritage of the area; and 2. To promote opportunities for the understanding and enjoyment of the special qualities of the Park by the public. 4. In addition, Section 62 of the Environment Act 1995 also requires all relevant authorities, including statutory undertakers and other public bodies (such as the Planning Inspectorate) to have regard to these purposes. This ensures that relevant authorities take account of these purposes when coming to decisions or carrying out their activities relating to or affecting land within National Parks. 5. In respect of air pollution and climate change we recognise these will be issues to be addressed and considered by the Examining Authority and Secretary of State. As we have noted before we are happy to work with GAL to try and overcome our concerns.