Conservationists have urged a Government inspector to refuse plans to develop the derelict Upper Beeding cement works.
Developer Callstone plans to spend £10 million transforming the disused Blue Circle Cement works.
The company hopes to build a business park, hotel and restaurant and 84 houses. The proposal also includes landscaping an area by the quarry cliffs.
As a public inquiry into the scheme draws to a close, opponents of the scheme have been presenting their final arguments.
Martin Small of the Sussex Downs Conservation Board asked inspector Geoff Salter to refuse Callstone's application and dismiss their appeal.
He said the scheme would do "demonstrable harm to a nationally important landscape".
He accused Callstone of using Health and Safety Executive constraints, centering on the issue of rare peregrine falcons and breeding ravens who nest on the site, to justify carrying out minimal restoration works.
He said: "The landscape is of national importance, not its nature conservation value. The presence of the birds should not override other natural beauty considerations if there is a conflict.
"The landscape and ecological benefits of the proposal are not sufficient to justify the development as proposed."
Traffic, noise, light and activity generated by occupants of the proposed houses would be detrimental to the area, he said.
Patrick Ellis, chief solicitor for West Sussex County Council, asked Mr Salter to refuse the application as he said the cement works was a "unique opportunity" for a waste energy site.
He said there was an urgent need for more waste management in the county, as 11.6 million tonnes of waste would be generated between 2001 and 2016, yet the county had nowhere to manage it.
The works, he said, was one of only three possible sites in West Sussex.
He said: "If you accept there is an urgent need for more waste management capacity then the only safe course would be to refuse permission."
Trevor Ward, representing Adur District Council, said the proposals contained too much housing and as a result were not in accordance with part of the council's development plan.
He said: "The council strongly supports the employment development on areas B and C and considers the scheme on area D on balance is acceptable."
However, he said the housing on area A was "unsustainable and can only be justified if it is necessary as an enabling development".
The council was not satisfied the housing carried out these requirements.
The inquiry at The Barn, part of Horsham District Council's offices, was due to finish on Thursday but has been extended.
Horsham District Council and Callstone will sum up tomorrow, the final day of the inquiry.
Tuesday May 6 2003
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