We have been passed an early consultation on improvements to the A259 South Coast Corridor. We are concerned these may increase traffic on the A259 impacting the coastal towns along its route and the Cuckmere Valley in particular. See what we have said here.
These are the comments of the Friends of the South Downs (South Downs Society). Founded in 1923, we have 1500 members and campaign to protect the natural beauty and public enjoyment of England’s newest national park. We have seen your email of 6th October 2021 regarding consultation on the A259 South Coast Corridor Study. We find that the on-line questionnaire seems mainly suited to individual road users rather than organisations such as ours, so we felt it more helpful to provide a written response.
We have a strong interest in the study because the A259 has a major impact on the South Downs National Park. The stretch of this road between Eastbourne and Seaford passes through some of the finest landscapes of the South Downs National Park, and also forms the northern border of the defined Sussex Heritage Coast. Between Brighton and Seaford the A259 passes through and adjoins several parts of the Park where its boundaries extend to the coast.
We welcome your comments about encouraging sustainable transport and protecting the environment. However, we are very concerned at your remarks about “improvements” to the A259, supporting growth and providing for greater use of private vehicles. This implies that you are seeking to substantially increase the capacity of the A259 through widening and other measures, and to accommodate growing traffic volumes. We strongly believe that, due to the A259’s route through the National Park, this capacity increase is wholly inappropriate.
We are also concerned at the current proposal to rebuild the bridge over the Cuckmere River at Exceat. We have objected to the planning application and append our objection letter of 24th June 2021 for your information.
We consider that the A259 study, and its presumption that traffic capacity needs to be increased, conflicts with all the relevant plans, strategies and policies that apply at local, regional and national levels.
The A259 is a number allocated in 1922 to a series of roads that then connected south coast towns between Folkstone and Emsworth. While the A259 remains part of the primary road network from Folkstone to Pevensey, west of Pevensey the strategy has for many decades been for the A27 to serve as the principal route along the south coast, and it has been very significantly improved to perform this function. The A259 from Pevensey to Emsworth, Hampshire, now serves only local journeys.
Your email states that the A259 study will directly complement Transport for the South East’s Transport Strategy 2020 and specifically their outer orbital corridor study. We question this as the Strategy recognises that the south coast corridor presents challenges but states that a consensus should be built on a multi-modal approach. Your study instead looks at road capacity in isolation.
East Sussex County Council’s current Local Transport Plan contains a hierarchy of ‘primary routes’ and ‘main roads’, but only categorises the A259 under ‘other roads’. The study’s proposal to increase capacity of the A259 conflicts with this plan.
ESCC was one of the authors of the document Roads in the South Downs: Enhancing the safety and quality of roads and places in the National Park (2015). This contains a core principle of “Maintaining a clear distinction between single-purpose, high-speed strategic routes, and the ‘public realm’ associated with the mixed-use, slower-speed network.” The document lists roads that fall into the first category, such as the A26 and A27; the A259 is in the latter category which “serve a multitude of functions in addition to transport”. “Improving” and increasing traffic volumes on the A259 would conflict with the aims of this document.
Roads in the South Downs – Enhancing the safety and quality of roads and places in the National Park – South Downs National Park Authority, 2015
This guide in its introduction states that:
‘The guide recognizes and highlights the key role played by roads and highways in forming the immediate foreground for most visitors to the Park, and the important influence played by legislation, duties and policies for road design in determining expectations, driver behaviour and values. The guide sits under the Protocol for the Management of Highways in the South Downs National Park agreed with the four Local Highway Authorities (LHAs), Highways England and the SDNPA. This local officer protocol sets out a vision for ‘a highway network that is managed and maintained in such a way that it conserves and enhances the South Downs outstanding landscape quality and local distinctiveness whilst delivering a safe and convenient network for all users and modes of transport.
The guide aims to help avoid the tendency for highways to suburbanize and standardise the landscape. To this end, an approach based on careful analysis of appropriate design speeds for traffic combines with an emphasis on distinctive place-making, village entrances and an integration of roads and streetscapes with their surrounding buildings, features and landscape elements. Building on a growing number of case studies, the guide is intended to inform and inspire officers, councillors, agencies and residents alike to share a broad vision for the long-term care and conservation of a unique and valuable national asset.’
The emphasis is on conserving the South Downs and a multi modal approach.
Perhaps though what is most interesting is that the A259 is not listed as a major route;
‘The major highway network is dominated by north-south routes, connecting the south coast ports and settlements to London and the Midlands. These include the M3, the A3,the A24, the A29, the A283 / A285 and the A23. There are fewer east-west routes; the A272 runs through the centre of the western portion of the National Park, with the A27 linking the conurbations to the south and connecting Brighton to Lewes and Eastbourne.’
English National Parks and the Broads: UK Government Vision and Circular 2010 contains the most important national policy regarding roads in national parks:
“There is a strong presumption against any significant road widening or building of new roads through a Park, unless it can be shown there are compelling reasons for new or enhanced capacity and with any benefits outweighing the costs very significantly.”
National Policy Statement on National Networks, 2014
The National Policy Statement on National Network, 2014 includes a more recent reiteration of the presumption against significant road widening or the building of new roads in National Parks.
Paragraph 5.152 states that:
‘there is a strong presumption against any significant road widening or the building of new roads and strategic rail freight interchanges in a National Park, …. unless it can be shown there are compelling reasons for the new or enhanced capacity and with any benefits outweighing the costs very significantly. Planning of the Strategic Road Network should encourage routes that avoid National Parks….’
The NPS also reiterates the more general assumption against major development set out in the National Planning Policy Framework.
The National Planning Policy Framework
The National Planning Policy Framework is unsupportive of this development. By way of example;
Para 171 states that:
‘Plans should reduce risk from coastal change by avoiding inappropriate development in vulnerable areas and not exacerbating the impacts of physical changes to the coast.’
Given the proximity of the A259 to the coast and the erosion of the chalk cliffs spending vast sums on a road that may require future coastal defences or rerouting seems to lack sense.
While the study runs between Rottingdean and Pevensey it is worth noting that congestion and risk of cliff fall is perhaps greatest on the Rottingdean to Brighton section and it would thus seem advisable to consider this part of the route in the study. NPPF Para 174 (e) also mentions land instability – which the chalk coast is (If stable the cliffs would not be white!).
Likewise, is developing a route running through the Cuckmere Valley which is expected to be inundated with water in coming years sensible? Are we looking at a raised route across the Cuckmere Valley? The raising of Exceat Bridge recently proposed seems to suggest this may be the case.
Para 174 states that :
‘Planning policies and decisions should contribute to and enhance the natural and local environment by:
a) protecting and enhancing valued landscapes, sites of biodiversity or geological value and soils (in a manner commensurate with their statutory status or identified quality in the development plan);
b) recognising the intrinsic character and beauty of the countryside, and the wider benefits from natural capital and ecosystem services – including the economic and other benefits of the best and most versatile agricultural land, and of trees and woodland;
c) maintaining the character of the undeveloped coast, while improving public access to it where appropriate;
d) minimising impacts on and providing net gains for biodiversity, including by establishing coherent ecological networks that are more resilient to current and future pressures;
e) preventing new and existing development from contributing to, being put at unacceptable risk from, or being adversely affected by, unacceptable levels of soil, air, water or noise pollution or land instability. Development should, wherever possible, help to improve local environmental conditions such as air and water quality, taking into account relevant information such as river basin management plans….’
Para 176 states that;
‘Great weight should be given to conserving and enhancing landscape and scenic beauty in National Parks, …. which have the highest status of protection in relation to these issues. The conservation and enhancement of wildlife and cultural heritage are also important
considerations in these areas, and should be given great weight in National Parks … The scale and extent of development within all these designated areas should be limited, while development within their setting should be sensitively located and designed to avoid or minimise adverse impacts on the designated areas.’
It should be noted that even the setting of the National Park is to be safeguarded – a change brought in in the latest version of the NPPF and thus reflecting current government priorities.
Paragraph 177 states that;
‘When considering applications for development within National Parks, the Broads and Areas of Outstanding Natural Beauty, permission should be refused for major development other than in exceptional circumstances, and where it can be demonstrated that the development is in the public interest. Consideration of such applications should include an assessment of:
a) the need for the development, including in terms of any national considerations, and the impact of permitting it, or refusing it, upon the local economy;
b) the cost of, and scope for, developing outside the designated area, or meeting the need for it in some other way; and
c) any detrimental effect on the environment, the landscape and recreational opportunities, and the extent to which that could be moderated.’
Para 177b refers to the scope for locating development away from the National Park. This need to be considered given the A27 being a parallel and easily substitutable and somewhat less impactful road.
Since the study envisages increasing capacity on the A259 this is likely to involve widening and other works that would be contrary to these national policies.
It is hard to see how road improvements are compatible with the Heritage Coast designation offered protection by Para 178:
‘Within areas defined as Heritage Coast (and that do not already fall within one of the designated areas mentioned in paragraph 176), planning policies and decisions should be consistent with the special character of the area and the importance of its conservation. Major development within a Heritage Coast is unlikely to be appropriate, unless it is compatible with its special character.’
The National Parks and Access to the Countryside Act 1949 sets out the purposes of national parks: to conserve and enhance their natural beauty, wildlife and cultural heritage, and; to promote
opportunities for the understanding and enjoyment by the public. It applies the “Sandford principle”, giving priority to the first purpose. The Act (s11A(2)) also imposes a duty on relevant authorities, including county councils, to have regard to these purposes and the Sandford principle when exercising or performing any functions that affect a national park. This duty applies to activities outside a national park that may have an effect on it. In view of the fact that the whole study area is within or close to the South Downs, we are surprised that your email and questionnaire make no reference to the national park.
Your email refers to the need to support projected economic and housing growth in the area, but you do not explain where this growth is expected to take place or how the A259 relates to them. In fact, one of the main areas of housing and population growth identified in councils’ local plans are in the south of Wealden District and neighbouring parts within Eastbourne Borough. These development allocations are around the settlements of Polegate, Willingdon, Stone Cross and Westham. All these areas are close the A27, and are not served by the A259. Similarly, projected growth at Newhaven will be served by the A26, which directly links it to the A27. The relevant local plans do not identify the A259 as a hindrance to development or advocate increasing its capacity. We therefore strongly disagree your assumption that “improvements” to the A259 are needed to support growth.
The study needs to be assessed against the policies of the South Downs Local Plan. The Local Plan has been prepared in the context of the statutory purposes of the national park and adopts a landscape-led approach. Improvements to the A259 involving widening are likely to require planning permission and would need to be considered according to its policies.
- Policy SD1 ‘Sustainable Development’ states that “Planning permission will be refused where development proposals fail to conserve the landscape, natural beauty, wildlife and cultural heritage of the National Park unless, exceptionally: a) The benefits of the proposal demonstrably outweigh the great weight to be attached to those interests.”
- Widening and similar proposals are also likely to fall within the definition of major development and so would need to be considered against policy SD3, which states that permission for major development should be refused unless certain considerations are met; we consider that works to increase road capacity would fail to meet these considerations.
- Policy SD19 ‘Transport and Accessibility’ states that improvements to transport infrastructure will be supported in certain limited cases, but these would not include significant capacity increases.
- Policy SD42 ‘Infrastructure’ states that “Development proposals for new, improved or supporting infrastructure will only be permitted where: a) It represents the least environmentally harmful option reasonably available … and b) the design minimises the impact on the natural beauty, wildlife and cultural heritage of the National Park and the general amenity of local communities. ‘ Road capacity increases would not meet these criteria.
Noise, air quality and the impact of lighting on dark skies are also issues that may need consideration against local plan policies.
The South Downs Partnership Management Plan 2020-2025 contains the following statements relevant to the A259 study:
- “We must change the way we travel and live. There is an urgent need to decarbonise transport … in ways that are appropriate in these special landscapes.” (p 12)
- “National infrastructure schemes must take far better account of protected landscapes. There are an increasing number of proposals for new national infrastructure, including road and rail schemes … that could cut through the National Park. Solutions must be found to avoid or reduce the impact of such schemes and to achieve net gain for the environment.” (p 15)
Sussex Heritage Coast : a strategy and action plan 2016-20
Between Seaford and Eastbourne the A259 forms the northern boundary of the Sussex Heritage Coast. In recognition of its outstanding quality this was the first heritage coast in England to be defined. The south-east has the lowest proportion of heritage coast in England, so this stretch is especially valuable. Sussex Heritage Coast: a strategy and action plan 2016-20 states (in section 3) that;
‘There will be a need to consider key access routes such as the A259. There is also a need to assess any road scheme proposals against enhancement of landscape (e.g. pressure for … A259 road improvements). Measures to support and enable sustainable transport options need to be seriously considered.’
Increased capacity and traffic volumes would not be appropriate for a road within a heritage coast.
CPRE’s The Impact of Road Projects in England (2017)
There is evidence that road schemes justified on the basis of reduced journey times fail to deliver the promised economic benefit. The 2017 report commissioned by the CPRE concluded that:
‘a major change to national policy is called for, involving a move away from large-scale road building. The evidence of the last 20 years suggests that:
- Any benefits of road schemes in terms of congestion relief are short-lived;
- Road schemes cause permanent environmental damage;
- The evidence that they deliver economic benefits is lacking.’
A link to this document is offered here. https://www.cpre.org.uk/resources/transport/roads/item/4542-the-impact-of-road-projects-in-england
Campaign for Better Transport – Rising to the Challenge, A shared green vision for RIS2
This document provides good practice and also cites the South Downs National Park as a case study. It offers so much useful information that it is hard to single out anything for inclusion. The impacts on landscape, heritage, air quality etc are all considered with valuable input on solutions and even the availability of grants for works.
Conclusions and way forward
We consider that the level of traffic on the A259 to be significantly determined by its capacity. Because the A259 runs parallel to the A27 any increase in its capacity will lead to traffic reallocating from the A27, negating any perceived benefits. This is likely to include long-distance journeys which are wholly inappropriate on this road. It would lead to a cycle of rising congestion causing new bottlenecks to develop, leading to pressure for yet more widening. It would also attract rat-running traffic onto country lanes connecting to the A259, such as those through Rodmell, Alfriston, Litlington and Jevington. It would increase traffic through the coastal towns to their detriment.
The Department for Transport’s Major Road Network was introduced in 2018 with minimal consultation. The identification of roads for inclusion in the MRN was based largely on the volume of traffic they carry, especially HGVs. Selection took very limited account of other important considerations, including the strategic allocation of traffic, duplication with other arteries, or impact on the environment, particularly special landscapes such as national parks and heritage coasts. The MRN also includes local and congested roads, such as those through Eastbourne and Seaford town centres and along Brighton seafront. ESCC should advocate the removal of the A259 from the MRN, at least the section through the national park. Indeed, we consider this stretch should be downgraded to a B road.
The study should be revised to instead examine how the A259 can be altered to make it function in a manner more suitable to its location in the national park and heritage coast. This study should take account of the policy documents referred to above, as well as the DfT’s Manual for Streets 2, Gear Change, a bold vision for cycling and walking and the Campaign for Better Transport’s Tourism Without Traffic: a good practice guide.
The area of the national park and heritage coast through which the A259 is very popular with walkers and horse riders. Numerous public footpaths and bridleways cross and run alongside the road, including the South Downs Way, Vanguard Way and the new England Coast Path. Bordering the road there are very large areas of open access land, where the public have the right to roam. These are in the Seven Sisters Country Park, the National Trust’s extensive land holdings at Crowlink, Gayles Farm and in the Cuckmere valley, the Forestry Commission’s Friston Forest, Eastbourne Council-owned open downland and Brighton Council-owned downland at Rottingdean. Walkers and riders using these paths and areas suffer badly from severance and environmental intrusion caused by the A259. Much of the route is at the national speed limit, which is too high for a road of this kind and causes difficulty and danger to walkers and riders.
The number 12 bus route along the A259 provides a frequent service for those visiting the national park from settlements between Brighton and Eastbourne. However, bus stops are in need of improvement and alighting passengers must contend with crossing the busy road.
National Cycle Route 2 runs along the A259 between Exceat and Seaford, but road conditions are hostile to cyclists. Increasing traffic volumes would further worsen conditions for cycling.
Because the A259 follows an elevated route across hills and along ridges, its traffic causes noise and visual intrusion over a wide surrounding area, to the detriment of the amenities of the national park and heritage coast.
Pollution from heavy traffic on the road is damaging to the environment and wildlife. There are several sites of special scientific interest and nature reserves adjoining and near the road which are adversely affected by fumes and noise.
The Seven Sisters Country Park is estimated to attract around one million visitors per annum. Many of these arrive by bus. While the country park lies mainly south of the A259, the visitor centre is on the north side of the road. This creates a very poor setting for the visitor centre, and difficult and dangerous conditions for the huge numbers of visitors crossing the road.
In conclusion, the Friends of the South Downs consider that any intention to increase capacity on the A259 is entirely inappropriate and the study should instead focus on remedying current problems and providing improvements for cyclists, pedestrians and public transport users.
Upgrading the A259 has the potential to damage the inherent value of the South Downs.