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The Lupin Field

Against the distant background of the South Downs, a small church stands alone among fields and woodland. It is a modest building from the late 11th or early 12th century with extensive 19th-century alterations including the addition of a porch. This is St Peter’s Church in the West Sussex village of Terwick and here you’ll find The Lupin Field.

There has never been a village of Terwick as the soil near the church is poor. In 1646 there were only five houses in the parish but they may have been substantial households. Today, it is a lovely place to visit in late May or early June, depending on the weather, to see the lupin field at its best.

This field full of lupins separates St Peter’s from the A272 and is now in National Trust ownership.  Until after World War II the field formed part of the rector’s glebe. The Reverend George Laycock planted the lupins which self-seeded and bloomed year after year. He was Rector of Terwick for over 40 years until his death in 1933 (he is buried in the churchyard). He lived nearby in the large rectory and as he was not burdened with many parish duties, he spent much of his time using the field behind the church as a market garden.

The lupin field was later owned by Mr and Mrs Hodge of nearby Fyning House. She adored the view of the lupin flowers in the field framed by the South Downs. The surrounding land is arable and Mrs Hodge wanted to ensure that the view was protected and the lupins would always be there. On the Hodges’ death in 1939, the field was gifted to the National Trust with the condition that they would continue to grow lupins in part of the field. Through the decades the National Trust has worked with the Rogate community and the local farmer to try and ensure new seed is planted and the number of lupins  maintained.

Today, the lupin field still holds hundreds of lupin plants, but within this is a mix of wild grasses and flowers such as ox-eye daisies, poppies, vetch and meadow cranesbill, which have self-seeded and become part of the meadow. Harvest mice also live here and the space is now a ‘naturalised’ meadow which gives space and opportunities for wildlife to flourish amongst a more formal and farmed landscape. The NT manage the field in a similar way to a hay meadow. A cut is taken late in the year once the lupins have seeded and the grass is baled and removed. Russell mix lupin seeds are sown into the bare ground in spring. The lupins are commemorated in an altar frontal given to St Peter’s to celebrate the millennium.

A272 ROGATE to MIDHURST ROAD National Grid Reference: SU 81784 23512. Signpost to St Peter’s Terwick and parking behind the church.

Walks from here turning east back along the road from the church and then crossing the A272 can take you north to Borden where you connect to the Serpent Trail.

Caroline Douglas

Trustee

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Tree Guard Cleanup Day

On Saturday 21 May 2022, our Trustee Chris Steibelt was out in Singleton Forest with volunteers and Forestry England representatives for our first tree guard cleanup day, collecting redundant tree guards to be sent off for recycling.

Tree planting forms a key part of our goal to reach net zero carbon emissions in the next three decades. We all love trees! Most planted saplings need some form of protection from rodents and deer in order to survive until they are well established. The common solution is to use a tree guard. These need to be durable and translucent for at least five years and the most cost-effective solution to date is those made of plastic. The good news is, technology has advanced and not all that plastic is fossil fuel based. Today, many products made with UV stabilised polypropylene which is generally recyclable. Regardless, redundant tree guards remain a problem. National Park campaigners, like the Friends of the Yorkshire Dales, have called for a ban on plastic tree guards. And whether the tree guards are recyclable or not, the fact is they are forgotten for decades, choking the trees they are meant to protect or littering the forest floor.

“I’m pleased to report that our recent tree guard cleanup day, collecting ageing plastic tree guards in Singleton Forest, was a success thanks to help of our team of 10 volunteers supported by Forestry England,” Chris said. “Over 750 were gathered up, some 20 years or more after their original placement. It was sad to see that in a number of cases, the plastic tree guards had actually strangled the tree resulting in its premature death. After removing the non-recyclable plastic zip ties, they were stowed into jumbo bags ready for collection and recycling.

“It is reassuring to hear from Forestry England that of the seven million trees they plant each year only 2% are protected with this type of tree guard and what’s more they are now doing trials of biocompostable guards. In addition, they have taken steps to improve their record keeping of exactly where and when plastic tree guards have been used.”

That sounds relatively encouraging for the future but what about all the mess created in the past? Should it be it left for volunteer groups to tidy up or should we press for more accountability on the part of our forestry managers? What do you think?

A spokesperson for Forestry England said:

“We continuously seek out environmentally friendly alternatives, but due to the lack of a credible, biodegradable alternative, we’ve used tree guards made from UV stabilised Polypropylene to protect the young tees from browsing by deer and rabbits and ensure the best chance of reaching maturity.

“Forestry England’s policy is for all tree shelters to be collected and removed from sites at the end of their useful life – about 10 -15 years after planting. We’re now able to keep track of areas where tree guards have been used, so that once they’ve served their purpose, we can send them to be recycled.

“Forestry England plants seven million trees each year across the nation’s forests and of these only around 2% need to have tree guards to protect them from damage. This amounts to approximately 150,000 tree guards per year. We are continuing with trials of sustainable alternatives to plastic tree guards and as soon as products become commercially available which are high enough quality and durable, we will be ready to switch over and use them for all new tree planting.

“We are already making positive changes and nearby at Queen Elizabeth Country Park and Forest we have used biodegradable alternatives for our tree planting this year and hope to scale this up nationally in autumn and winter of 2022/23.”

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Clever Local Herds

Out on a walk with my dog Ruby recently around the Mardens, at the west end of the South Downs, we stumbled across a shoot. Whilst their target was pheasant, the sound of gunshot ringing around the densely wooded hillside clearly had an unnerving effect on the other inhabitants of this otherwise tranquil area. As we skirted the large, open field, giving the shoot a wide berth, Ruby couldn’t believe her luck when at least 10 deer, one of the clever local herds, leapt out of the hedge in front of us.

Photo: Graham Stockley

Given that Ruby was on the lead, 12 years old and covered in lumps and bumps, I wasn’t initially concerned but in the heat of the moment she somehow managed to slip her collar. An intervention or more accurately, a bellow, was clearly required! To my great satisfaction and pride, she stopped dead in her tracks and returned to my side, with just the slightest look of regret in her eye!

An encounter with deer these days, whether out on a walk or less fortunately, on the road, is fast becoming a normal occurrence.  The UK’s deer population is believed to be at its highest level for 1,000 years, with some two million deer in our countryside and semi-urban areas.

In conversation recently with Steve Walker, Manager of Kingley Vale Nature Reserve, north of Chichester, I learnt that he’d spent the previous night up on the Downs thermal imaging the fallow deer population with the tech wizards from Digital Fauna. The clever local herds have apparently gotten so clever at avoiding detection that night-time is the best time for getting concrete evidence. The images below clearly show how large some of the herds have become. While the Downs are not part of the reserve, these herds roam vast areas of the Hampshire/West Sussex borderlands, of which the Mardens and Kingley Vale are part.

Unfortunately, at Kingley Vale the future of the famous Yews is under threat from the deer. Yew is famous for its longevity and regeneration properties, but even it needs to produce new shoots for the long-term survival of the forest. With the young, juicy stems being eaten by the deer, the age diversity of the grove is being put at risk. Similarly, most of the woodland understorey has been browsed off. This is already leading to the decline of wildflowers, insects and woodland birds such as the Nightingale, Nightjar, Bullfinch and Marsh Tit, which all rely on this layer for feeding or breeding.  

The nature reserve is also home to an active dew pond restoration programme. Traditionally, their saucer-like design provided sheep with a safe means of accessing water, but their fragile ecology cannot cope with vast herds of deer descending for a drink. Barriers have had to be erected to stop them from eating all the marginal plants, which other wetland species require. Another problem associated with deer, that walkers will surely have come across in recent years, are the ticks that they carry.

Although deer are a beautiful part of our woodland ecology, in the absence of a natural predator like the Lynx, their population needs to be managed. This can only realistically be done by man in an ‘enlightened nature-mimicking way’. This will not only stop damage being done to protected areas, farmland and forestry by these clever local herds, but also ensure the herds themselves remain healthy. However, the ‘Bambi-effect’ is a significant hurdle to a humane cull. Furthermore, even if it was considered publicly acceptable, Covid and Brexit have seen the bottom drop out of the venison market.

If we are to solve all these problems, conventional wisdom suggests that we need to start eating more venison. This will help drive up demand for deer carcasses and make it economically viable for stalkers to carry out a selective cull. As a food source, venison ticks many of the key boxes: it is low in fat and carbon, high in protein and welfare, and full of iron, zinc and B vitamins. If you are yet to give venison a go, perhaps you might be tempted to try it the next time you are out for a meal. If anyone questions your gluttony as you tuck into a venison steak or burger, your rebuttal is clear, you are doing your bit to protect the South Downs…just as Ruby had clearly been hoping to do on our walk!

Malinka van der Gaauw

Walks Leader

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We Need Volunteers

Singleton Forest

Our campaign to create more awareness on plastic tree guards takes a hands-on approach in March 2022.  In partnership with Forestry England we are organising a clean-up of old tree guards which are littering an area of Singleton Forest. Our trustee, Chris Steibelt, explains why we’re doing this here. Read the press release regarding plastic tree guards here. We need volunteers. Best estimates are that these were originally installed 20 years ago and should of course have been removed and recycled as soon as the trees no longer required their protection. As happens all too frequently, they were overlooked and now present a hazard to our environment.

We need volunteers to come along and support us on Saturday 26 March from 9:00 am – 12:00 pm to clear this area.

The location details are:

The site is accessed from the A286 via a tarmac road that leads to the IGAS oil well. It’s 0.8 mile from the top of Cocking Hill on the A286 heading South or 1.5mi from the bus stop in Singleton on the A286 heading North. There’s no signpost and the traffic flows quick quickly down that section.  There is room for parking opposite the IGAS site entrance at the top of the tarmac road on Forestry England land. The area where we will be working is grid ref SU884153/ What3Words: fewest.reduction.detect

Equipment: Forestry England will supply high viz jackets so all you will need is a pair of gloves. There’s some bramble covering the ground, so do make sure you have suitable footwear too.

If you would like to help play a part, please message us or contact us using the above contact button.

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Ban Plastic Tree Guards 

National Park campaigners call for a ban on plastic tree guards as Government considers banning other types of single-use plastic 

Friends of the Dales Chair Bruce McLeod clearing plastic tree guards from the Yorkshire Dales National Park

Campaign for National Parks, Friends of the Dales, Friends of the South Downs and nine other National Park Societies have joined forces to call for a ban on plastic tree guards. Chris Steibelt, Trustee of Friends of the South Downs, is leading this project for us and tells us here why we have decided to launch this campaign.

The campaign coincides with a Defra call for evidence over problematic single-use plastics – which the National Parks campaigners have responded to, highlighting the ongoing issue of plastic tree guards. 

“We want to see a complete end to the use of single-use plastics in the supply of tree guards (much of which will inevitably become highly polluting micro-plastics),” says the joint response, “as well as the introduction of more effective controls and auditing in order to require a greater focus on recovering old tree guards and preventing further pollution.” 

Eleven National Park Societies in England and Wales have joined Campaign for National Parks, the only independent charity campaigning to protect and improve all National Parks in England & Wales, in signing a joint statement (see full text below) urging National Park Authorities to restrict the use of new plastic tubes for tree and hedge planting in National Parks by the end of 2022.  

It follows a commitment from The Woodland Trust to stop using plastic tree guards on their estate by the end of 2021, and efforts by the National Trust to explore, and trial, alternative options – moves supported by National Park Societies and Campaign for National Parks. Yorkshire Dales Millennium Trust is also embarked on a plastic-free woodlands project to remove redundant plastic tree guards and champion alternatives. 

Friends of the Dales Chair Bruce McLeod says: “Society and governments are increasingly calling for a reduction in plastics in the environment. Due to the Climate Crisis and declarations of a climate emergency, they are also calling for an acceleration of tree planting in order to sequester carbon and off-set carbon emissions. We believe that an increase in tree planting should not equal an increase of plastic in the environment.  

“Plastic tree guards are a product of the fossil fuel industry, thereby a contributor to global heating. We support the collection and recycling of redundant tree guards. However, the size of that task only serves to underline that we should not add to this waste. There must be more accountability for the removal of plastic tree guards once they have served their purpose. Alternative (compostable) guards and methods of woodland creation are increasingly being used; they replace the polypropylene tubes that have a life span of centuries either in dumps, other plastic products or as micro plastics in the ocean and soil.” 

Campaign for National Parks Policy and Research Manager Ruth Bradshaw added: “Our National Parks and the Climate Emergency report released last year explored how National Parks were adapting to and mitigating climate change. There are huge efforts underway to do both and it’s clear that tree planting has a role to play in this, but the benefits – carbon capture, habitat creation etc. – are undermined when each sapling is surrounded by a new, single-use plastic tree guard. Plastic waste is a huge issue in National Parks – from the carbon footprint of making such disposable items to the long-term impact on the landscape of non-biodegradable items. Plastic tree guards are part of the problem, not part of the solution and we must treat them as such.” 

Full statement: 

Society and governments are increasingly calling for a reduction in plastics in the environment. Due to the Climate Crisis and declarations of a climate emergency, they are also calling for an acceleration of tree planting in order to sequester carbon and off-set carbon emissions. However, we believe that an increase in tree planting should not equal an increase of plastic in the environment.  

We believe that the current practice of using plastic tree guards in woodland creation is unsustainable. Plastic tree guards are a product of the fossil fuel industry, thereby a contributor to global heating. We support the collection and recycling of redundant tree guards. However, the size of that task only serves to underline that we should not add to this waste. There must be more accountability for the removal of plastic tree guards once they have served their purpose. Alternative (compostable) guards and methods of woodland creation are increasingly being used; they replace the polypropylene tubes that have a life span of centuries either in dumps, other plastic products or as micro plastics in the ocean and soil.  

Major tree planting organisations such as the Woodland Trust have decided to cease using plastic when planting by the end of 2021. We support this sea change in our relationship to single use plastics, woodland creation and the natural world. We support the campaign to reduce single use plastic in our National Parks and the landscape.  

In an unprecedented show of unity, and supported by the Campaign for National Parks, National Park Societies throughout England and Wales call upon the national park authorities to radically reduce the blight of plastic tree guards in our precious and protected landscapes. Further, we challenge National Park Authorities in England and Wales to make a similar pledge to that made by the Woodland Trust in 2021: to restrict the use of new plastic tubes for tree and hedge planting within the National Parks by the end of 2022.  

Signed:

Friends of the Dales, Friends of the South Downs, Snowdonia Society, North York Moors Association, Exmoor Society, Brecon Beacons Park Society, Friends of the Pembrokeshire Coast National Park, Friends of the New Forest, The Broads Society, Friends of the Peak District, Dartmoor Preservation Association and Campaign for National Parks 

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The Environment Act

Photo credit: Malinka van der Gaauw

The Environment Act is the current version of the Environment Bill. This Bill should make provision about targets, plans and policies for improving the natural environment; for statements and reports about environmental protection; for the Office for Environmental Protection; about waste and resource efficiency; about air quality; for the recall of products that fail to meet environmental standards; about water; about nature and biodiversity; for conservation covenants; about the regulation of chemicals; and for connected purposes. This is a statement from our president, Maggie Jones, regarding the Environment Act.

Over the last few months, I have been busy with the government’s Environment Bill in the House of Lords.

Maggie Jones, President

It was undoubtedly a landmark Bill, with ambitions across many aspects of our environment. However, opportunities like this do not come along very often so the Lords, across the parties, worked very hard to improve it to make it a piece of legislation about which we could all be proud.

It was debated during preparations for COP26 and we were keen to emphasise that globally we face a biodiversity emergency as well as a climate emergency. In fact, recent reports have shown that the UK is now one of the most nature-depleted countries in the world, with 41% of our species declining and 1 in 10 threatened with extinction.

So, one of our first achievements in the Bill was to introduce challenging measures to halt the decline in biodiversity by 2030.

This will be supplemented by the introduction of ‘biodiversity net gain’ as a condition for awarding planning permission locally. This would mean that new buildings would have to be offset by investment in alternative environmental projects. This is an exciting concept but still needs much more work – particularly on how it would relate to the government’s planning reforms.

Another issue which was hotly debated was the need to protect our ancient woodlands. These have been disappearing from our landscapes at an alarming rate. While the government’s promise to plant 30,000 hectares of new woodland each year is welcome, progress so far is slow; these new trees do not provide a comparable rate of carbon capture to that of existing established woodlands, so it was pleasing to get extra commitments to protect our ancient trees.

The Bill also included new commitments on waste recycling, creating more resource efficiency and cutting back on plastics. We were pleased to introduce new measures to charge manufacturers the full environmental impact costs of single-use items such as cups, plates and cutlery which create huge amounts of litter and marine pollution.

Air quality and tackling air pollution turned out to be a hugely controversial issue. We know that there are some 40,000 early deaths a year from the health effects of breathing in polluted air. We tried, unsuccessfully, to write into the Bill the introduction of World Health Organisation air quality standards by 2030. We will continue to campaign on this issue.

The challenge to prevent water companies discharging raw sewage into our rivers and seas was a major debate and it was fantastic to see the public campaign and support for the action we were proposing.

As a result, we made significant progress on controlling unauthorised discharges for the future, as well as requiring water companies to invest more resources into the outdated infrastructure.

These are just some of the many issues which we pursued over the months of debate.

However, we remain concerned that so much of the Bill has deadlines and targets in the distant future and we failed to win amendments to introduce interim targets which would have provided measurable data on progress at an earlier date.

Finally, a huge amount depends on the success of the Office of Environmental Protection which is a new organisation set up to replace the oversight of our environmental laws previously carried out by the EU.

We remain concerned that this new body is not sufficiently independent of government, nor does it have the same powers of redress.

So, overall, we were pleased with the progress we made in improving the Bill which has now become law, but only time will tell if the ambition of the Environment Act really will live up to its promise.

Maggie Jones

President, Friends of the South Downs, and Member of the House of Lords

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Poor Old Ivy

Ivy has a bad name. Many folk believe that it is a damaging parasite that should be removed from our trees. Unfortunately, this is mostly incorrect. Poor Old Ivy is not a parasite. It has its own root system penetrating the soil, from which it gains all its water and nutrients. To help it climb, it also has adventitious roots equipped with small suckers that it uses to cling to its host tree but they do not penetrate the bark. Ivy is just using the tree as a ladder to climb up from the forest floor towards the light and it does not strangle the tree in the process.

For the tree there are some downsides: the extra weight of the ivy on the branches of the tree and the windage of its foliage, which can act like a sail. A healthy tree can normally accommodate these extra loads but in exceptionally fierce weather, or in the case of a diseased tree, damage may occur. In addition, vigorous ivy growth around the tree trunk can produce a localised damp microclimate in which fungal growth can thrive. Tree Inspections become difficult with possible hazards being hidden from sight.
 
Buildings
Ivy can grow extremely rapidly, especially on buildings where there is no competing foliage. In a three-year project carried out by English Heritage in conjunction with Oxford University, to determine the true effects of ivy on buildings, the findings were positive. The study showed that ivy covered walls kept the inside of the building 15% warmer in the winter compared to other parts of the structure. In summer, the reverse was the case. The walls were recorded to be 36% cooler!
 
Ivy also helps to protect and preserve walls from frost, salt and pollution. The only time ivy is not beneficial and should be removed is on buildings that have existing structural damage or crumbling lime mortar because the ivy will creep into cracks and crevices, expanding with growth and increasing the damage and instability.
 
Value to wildlife
The plant also provides nest sites and shelter for insects, birds, bats and other small mammals. It is an important food plant for some butterfly and moth larvae such as holly blue, small dusty wave, angle shades and swallow-tailed moth.

Due to its autumn flowering, the ivy provides one of the latest sources of pollen, nectar and berries for insects and birds when little else is available.  Many insects including, but not limited to, honey bees, wasps, hornets, hoverflies, bumblebees, small tortoiseshells, peacock butterflies and red admirals rely on ivy’s nectar source to survive the late Autumn season. The nectar is an essential part of the ecosystem, providing the reserves needed by the adult red admiral butterfly to hibernate over-winter whilst the high fat content of the berries provides a nutritious food resource for redwings, fieldfares and our resident thrushes as well as blackcaps, blackbirds and wood pigeons. In total the plant can support at least 50 different species of wildlife throughout the year.

Human Health and Welfare
Ivy is known for its many health benefits, as it reduces mould and improves air quality.  This is a well-recognised topic at the moment due to a rise in people having respiratory problems. According to NASA, ivy is one of the top air purifying plants, removing toxins like
•        Benzene
•        Formaldehyde
•        Xylene
•        Toulene
 
Mythology and Symbolism
Ivy is commonly associated with Christmas, along with its counterpart Holly. As evergreen species, both plants were used to ‘ward off evil spirits’, with sprigs being picked and brought inside to keep house goblins at bay. It has also been a tradition to place a sprig of ivy within a bride’s bouquet, as it is thought that ivy symbolises fidelity, loyalty and support within a marriage.

Wearing a wreath of ivy leaves around the head was once said to prevent one from getting drunk. The Roman god Bacchus, the god of intoxication, was often depicted wearing a wreath of ivy and grapevines. Ivy was also a symbol of intellectual achievement in ancient Rome and wreaths were used to crown winners of poetry contests. Wreaths were also given to winning athletes in ancient Greece.
 
Think very, very carefully about the benefits of ivy before you decide whether to remove it.
 
Glynn Jones,
Trustee

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Eton New Town

In recent years, the Government has changed national planning policies and how it calculates the numbers of homes each area should aim to provide. Lewes District Council is currently looking at the required revisions to its local plan which has now expired. Accordingly, it has issued a consultation document entitled in short “Issues and Options”. Recently, on one of the Society strolls, members took the opportunity to walk round the North Barns Farm area, sight of the proposed Eton New Town. If it went ahead it would have a profound impact on not only the views out from and into the South Downs.

As ever, one of the key components are the plans to meet the requirement for more housing. The initial findings were that, to meet the Government targets, 602 houses would need to be built per annum, compared to 385 houses per annum in the current plan. In the last year, 242 new houses were built. Consultations run until the end of 2023 and the plan should be finally agreed by 2025, for delivery from 2026, covering the period to 2040.

There are some severe restraints. The District is constricted by the sea to the south, the National Park and the proximity to the Ashdown Forest. Along the coast, infrastructure is poor, e.g., the congested A259, but also within the Low Weald. Yet these are the only areas where new housing development can be accommodated, unless it is tacked onto to the eastern parts of Burgess Hill and Haywards Heath, both of which are already subject to massive expansion, with the Northern Arc scheme of circa 3000 houses.

The coastal strip covers Seaford, Newhaven, Peacehaven and Telscombe. The Low Weald encompasses the villages of Barcombe, Broyle, the Chaileys, Cooksbridge, East Chiltington, Newick, Plumpton, Ringmer and Wivelsfield.

Another approach, as in other Districts, is the suggestion of an entirely new settlement. Hence, North Barnes Farm and the surrounding area near East Chiltington and Plumpton Green, which is owned by Eton College, has come forward as one of the options for the Eton New Town. This totals some 465 acres. Welbeck Land have worked up detailed proposals for a new live/work community to be created over 25 years with a phased “place making approach”. It is suggested the focus would be on agricultural and horticultural activities with the creation of 2750-3500 jobs and 25,000 to 30,000 sq. m. of “workspaces”.  If you drive around that area you will see this scheme is not popular with almost every house bearing a “No Eton New Town” poster.

All of this however has now been kicked into touch, as the new Secretary of State has called for a pause on the new Housing Bill. Included in these the proposals, as part of the drive for more housing, was a new formula, known as the standard method, to determine the required housing provision, based on population projections and local affordability data. That method gives the higher hosing targets above but may now be revised.

Pictured is a map showing the area under consideration at North Barnes. Here is a link to the map, illustrating just how big this development is. Recently on one of the Society strolls, members took the opportunity to walk round the area, which might be involved. If it went ahead, it would have a profound impact on views out from and into the Downs, which would be one of our concerns. The Bevern stream runs though land, which is an important spawning area for sea trout. As ever there are no zero cost options.

Patrick Haworth,
Trustee

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Proposed Exceat Bridge Replacement

The Friends of the South Downs is concerned about the proposed replacement bridge at Exceat in the Cuckmere Valley. This letter to the South Downs National Park Authority explains those concerns.

Application no. SDNP/21/02342/FUL

These comments on the planning application are made by the Friends of the South Downs (The South Downs Society). Founded in 1923, the Society campaigns for the protection, quiet enjoyment, and enhancement of the landscape of the South Downs National Park. 

This application has generated significant interest and concern from our members.

Summary of objections

The Society is concerned that this proposal is not in line with the National Park’s purposes, is highly insensitive to the chalkland landscape of the Cuckmere valley and has significant impact on the Heritage Coast, on the Seaford to Beachy Head Site of Special Scientific Interest and Seaford Head Local Nature Reserve and on the listed buildings at Exceat. 

The larger road bridge and increased traffic will change the area from a rural route in a charming landscape to a noisier through corridor. The increased speed and noise of traffic will have a significant impact on the whole valley. It is concerning that it is accepted that these road improvements would allow the opening up of the area for further development of housing. 

The proposed bridge is longer, wider, higher and more dominant. The bridge’s design gives an alien sense of enclosure in a wide, open landscape. The bridge is presented as something of a tourist destination whereas the need is for a minimal approach. The impact on the wider landscape is given significantly less thought in the scheme than the pub’s car park. More consideration needs to be given to the wider landscape impact in this sensitive and charming valley. 

Cyclists would be forced to use the two way main carriageway unless a further future transport scheme caters for them.  Given the popularity of the valley for visitors it is concerning that little priority has been given to these users.  

One of the most significant issues is that there is a flawed assumption that creating a two lane faster road will not serve to increase traffic.  Studies within the application that rely on this flawed assumption will not portray the reality of the impact of the scheme.  This invalidates the findings of many of the surveys. How can you consider the impacts of noise, for example, when you don’t assess the whole impact?

Quality of the application documents 

The applicant (ESCC) seems to underestimate the tests that a road must pass to be acceptable in a National Park.  The justification is insufficient and refers to documents that no longer form the development plan against which the application should be judged. 

It is particularly concerning that the wrong Local Plan documents (Lewes and Wealden) are cited in the supporting information.  These plans were replaced by the South Downs Local Plan back in 2019. When the applicant provides no justification for meeting some of the policies it is difficult to assess whether the scheme meets them. The applicant should be required to justify the development against current policy (national and local) before the application is determined. 

It is surprising that there seems to be no detailed assessment of the landscape impact. One would expect artist’s impressions of the altered views from points around the valley and consideration of the impacts on views of the valley.  There is a map which shows points where you can see the bridge (which is apparently ascertained from Google and photos from a site visit). However, there is no consideration of the new bridge (higher, wider ,further North and on a new alignment) and where this will be visible and the significance of this. In parts the application seems to pay lip service to issues rather than providing detailed analysis. 

The application gives insufficient detail in some areas which makes detailed understanding of the scheme and its impacts difficult. Likewise there are some internal inconsistencies within the documents. Footpath closures are an example of this. It is just not clear how long closures will be and thus it is hard to assess this loss to users. 

National Park Development / Major Development 

The proposal does not conserve or enhance the natural beauty, wildlife and cultural heritage of the area. Indeed the new bridge and associated works are detrimental to the landscape, to the Heritage Coast, to the Seaford to Beachy Head Site of Special Scientific Interest and to Seaford Head Local Nature Reserve and to the listed buildings at Exceat. The bridge brings in more and faster traffic to a valley changing it significantly. The development is not in line with the purposes of the National Park. The scheme is detrimental to the enjoyment of the local areaThe lack of provision of cycling facilities and adequate crossings for pedestrians is not consistent with the need to provide for the enjoyment of the area. 

The purposes of the National Park are reflected in South Downs Local Plan Policy SD1: Sustainable Development’ which 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.”  

We maintain that this proposal has not demonstrated this case.  

SD3: Major Development.  The Society considers that the proposed bridge should be defined as major development.  The policy states that permission for major development should be refused unless certain considerations are met. We believe the application fails to meet these considerations.  One of the considerations quoted in the policy is that developing outside the designated area should be considered.  This is relevant as the A27 provides a preferred alternative traffic route. The A27 is currently being improved, and further improvements are under investigation with a consultation due out in the next few weeks.  The policy also states that proposals should be measured against factors that include zero carbon and sustainable transport; a scheme that increases road capacity conflicts with these factors. 

Road provision in National Parks 

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.”

It is surprising and concerning that this policy is not referred to or addressed anywhere in the ESCC’s application, and it appears to have been overlooked.  Because it has ignored the policy, ESCC have produced no evidence of “compelling reasons” to justify the scheme.  This is a major failing of the application. When a scheme will change the look and feel of a valley to a significant degree it must be justified. A slightly shorter commute time (removing a pinch point) does not justify development in this sensitive location. The increased capacity and speed of the road that will result is likely to increase traffic volume. The scheme’s justification assumes no increase in traffic which renders much of it inaccurate, worthless and misleading. A quick search on google for a route between Lewes and Eastbourne shows 3 routes all at 41 minutes. One is the route through Ringmer and Golden Cross, one is the A27 via Polegate and one is the A27/A26/A259 coastal option through Exceat. If the Exceat journey time is reduced by say 3 minutes then satnavs will show this as the best option. It is hard to imagine this will not be the case and traffic would not use this route. 

National Planning Policy Framework (NPPF).  Section 15, Para172 of the NPPF 2019 ‘Conserving and enhancing the natural environment’ 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 scale and extent of development within these designated areas should be limited.  Planning permission should be refused for major development other than in exceptional circumstances…”. 

The Society considers that the proposed bridge most certainly should be regarded as major development and considered accordingly. 

Transport Infrastructure 

South Downs Local Plan Policy SD19: Transport and Accessibility’ states that improvements to transport infrastructure will be supported in certain limited cases.  

The proposed bridge does not fall into any of the cases it cites. 

Requirements for infrastructure 

South Downs Local Plan 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.”  

We do not consider that a scheme which increases road capacity and is likely to increase traffic volumes meets these criteria. The bridge is large and intrusive. This scheme is detrimental to the area’s natural beauty, wildlife and listed buildings. 

The least harmful option would be no change. A simple alternative with a distinct benefit at little cost is the maintenance of the bridge and the addition of lights to control traffic.  The application is contrary to South Downs Local Plan Policy SD42. 

The landscape impact 

The present bridge is unobtrusive in character, as it rightly should be given its sensitive location. It is short in length (being set at right angles to the bank on either side), narrow and low in profile. Given the lie of the land on either side and the surrounding trees and scrub, it is all but invisible to travellers coming down the hills from Friston to the east and Seaford to the west, their view being of the River Cuckmere following its meandering way north and south, with the Downs opposite and the sea in the distance. This view of the Cuckmere is nationally famous, and rightly so. It features in much artwork and provides a pleasant open feel immediately after leaving the coastal town of Seaford. 

The proposed new bridge will be far from unobtrusive or visually insignificant, being longer (it crosses the river at an angle), at least double the width of the existing bridge, and higher (to take account of predicted flood levels), both at road level and above. Further, its re-alignment to the north is likely to make it visible from a distance, thus detracting substantially from the view described above. 

We recognise that ESCC have made efforts to reduce the visual impact of the proposed bridge, by minimising the size of the structure and the use of appropriate materials.  Nevertheless, the proposed bridge would be significantly more visually intrusive than the existing. 

What is more, the proposed barriers between the road and the north and south footpaths on the bridge will mean that car drivers and passengers won’t be able to see the view to either side when crossing the bridge. They also mean that walkers on the southern footpath will have difficulty in looking to the north and those on the northern footpath to the south as the girders between the carriageway and footways will be up to 1.7 metres high. This serves to prevent the long open views that give the valley its distinctive open feel. Instead, there is an alien sense of enclosure – an urban feel. 

This is contrary to the South Downs Local Plan, which promotes a landscape-led approach to design.  Policy SD4 ‘Landscape Character’ states that development proposals will only be permitted where they “conserve and enhance the landscape character.”  The increased size and visual impact of the bridge structure cannot be considered to achieve this.  This is especially of concern in this location, as the Cuckmere valley is a landscape of the most exceptional quality within the National Park. 

It would be good if the application contained more artist’s impressions of the bridge in longer views and cross sections of the re-landscaped areas. It would be useful to see how the scheme would appear in its context and to see more visual assessment of the landscape impacts. It seems a glaring omission that there is inadequate assessment of the landscape impact of the scheme. 

Increased lighting /dark skies

The proposed design includes three high-level street lamps (in place of the present two), plus eleven low-level light fittings to illuminate the footways.  We feel this is excessive when assessed against policy SD8 ‘Dark Night Skies’ which requires proposals to demonstrate that “all opportunities to reduce light pollution have been taken.”  Since the footways will be bounded by metal railings, we are concerned that the lights will be visible for a considerable distance up and down the river. Is the South Downs National Park Authority content that sufficient detail has been given to lighting and its strength?  The assessment refers to the 2018 Technical Advice note but once again the requirements of the Local Plan of 2019 have been ignored. 

Impact on the natural environment.  

It is hard to see how a larger, faster and more used road could have a positive impact on the flora and fauna of this valley. 

The scheme includes a proposal to enhance the ecological value of a field to the north of the bridge in order to meet requirements for biodiversity net gain.  However the proposals lack sufficient detail for their effectiveness to be assessed. There is a lack of recognition of the importance of grazing in this downland landscape which is concerning. There is an assumption that an ‘area for biodiversity’ is a gain over the existing biodiverse grazed land. The biodiversity area proposed seems like a token mitigation effort – an add on to appease rather than an appropriately thought out scheme. 

There is much reshaping of the ditches, contours and immediate surrounds. Yet little detail is given of the habitat creation area or its impact on the landscape. Again the focus seems to be on the area close to the bridge with scant regard to the setting and wider impacts. 

Provision for cyclists and pedestrians

The Department for Transport’s Manual for Streets (2.4.2) states “In the past, road design hierarchies have been based almost exclusively on the importance attributed to vehicular movement. This has led to the marginalisation of pedestrians and cyclists in the upper tiers where vehicular capacity requirements predominate. The principle that a road was primarily for motor traffic has tended to filter down into the design of streets in the bottom tiers of the hierarchy.”  

The Government’s guidance on planning for cycling and walking such as: Gear Change, A bold vision for cycling and walking, Department for Transport, July 2020 and also Cycle Infrastructure Design (LTN 1/20) “Guidance for local authorities on designing high-quality, safe cycle infrastructure” July 2020 are ignored in the application. 

While the scheme includes a southern footway over the bridge and some limited traffic calming, by encouraging greater traffic volumes on the A259, the bridge widening will be of overall detriment to walkers, cyclists and the amenities of the National Park.

It is noted that the southern footway is wide enough to allow its future use as a shared surface by both pedestrians and cyclists but it is also recognised that cyclists won’t actually be able to use it unless a further scheme is taken forward.  Why install a wide, dominant bridge if it can’t be used by cyclists? 

It is very disappointing that no proposals are included for a cycle lane across the causeway and continuing to Seaford.  This road forms part of National Cycle Route 2 and also the Avenue Verte between Paris and London via Newhaven.  Other sections of this cycle route have been improved, such as the dedicated cycle path to Berwick Station and the connecting cycle lanes proposed along the A27.  The section along the A259 remains one that is hostile to cycling. The double height kerbs on the bridge will make the road particularly unattractive to cyclists. Many cyclists could be encouraged to use this attractive route if it were less dangerous. 

Whilst it is tentatively accepted that the provision of protected footways along the proposed new bridge should negate the likelihood of accidents involving pedestrians on the bridge itself, the increased vehicle numbers and speeds that the realignment and widening will encourage will undoubtedly lead to an increase in such accidents at either end of the bridge: 

  • at the western end, there is a footpath to the south (the Vanguard Way) which meets the A259 by the public house; there is also a footpath on the north side at much the same point which follows the river up to Alfriston. To follow this path in either direction between Alfriston and Cuckmere Haven, it is necessary to cross the road at this point; 
  • if walking from Alfriston on the western footpath and wishing to cross the bridge, the only way to do it at present is via the existing footway on the north side. However, when the eastern end of the bridge is reached, the footpath continues along the south side of the road, thus requiring the walker to cross the road at this point. The proposed provision of a further footway along the south side of the new bridge will not obviate this crossing; 
  • there is a bus-stop on either side of the road at the western end of the bridge (these essentially serve the needs of walkers and pub visitors). Passengers alighting or boarding at these stops frequently have to cross the road to continue their journey/reach their destination on foot; 
  • at the eastern end of the bridge, the Visitor Centre and café is on the north side of the road while a nearby and popular car park is opposite it on the south side, thus requiring the crossing of the road. Further, anyone walking from the bridge and wishing to get to the Visitor Centre also has to cross the road at this point; and 
  • the bus-stops on the eastern side of the bridge (on either side of the road at the Visitor Centre) lead to frequent crossings of the road, particularly by bus-passengers from the west who alight here at the start of a walk either over the Seven Sisters or along the footpath following the river to Cuckmere Haven.

The proposed bridge will do nothing to render unnecessary any of the road-crossings outlined above. On the contrary, it will make those crossings more dangerous to undertake given the increased speed and non-stop nature of the traffic and the increased width of the road at each end of the bridge. With the large numbers of pedestrians currently using the bridge, many of whom are likely to have to cross the road at some point, the objective ought to be to reduce the risk involved in such action, not to increase it. It is important to note that the road being used by vehicles going in one direction and then the other affords significant gaps in the traffic. Without these gaps and with faster traffic families, children, the elderly, disabled people will find it much harder to cross the road. 

Footpath closures during construction

The documents point to closures of the Cuckmere Valley footpath to the North East as being longer than the two weeks or so of the whole road closure for construction. Different documents suggest different lengths of closure of this route. Can the length of time footpaths will be closed be clarified?  The diversion is lengthy and inconvenient. Is there a better option? 

The A259 is not a strategic route. 

ESCC’s ‘Planning Statement’ accompanying the application includes a section ‘Need for Development’ (3.2) which states: “The A259 at Exceat Bridge is the longest Zone 2 A road in Great Britain.  It carries approximately 11,000 vehicles per day along the coastal route and provides an alternative to the A27 for vehicular traffic and non-vehicular travellers along the coastal route between Eastbourne and Brighton and beyond.”

The South East Local Enterprise Partnership states on its website that the replacement of the bridge will “unlock the full capacity of the network to support employment and housing growth.  Exceat bridge is part of the A259, one of the principal road networks in East Sussex which serves two of the County’s growth areas for housing and employment: Newhaven and Eastbourne/South Wealden.  The A259 is a critical route for economic connectivity from the east of the county, along the East Sussex coast to Brighton and through to West Sussex, including linkage to a key port at Newhaven.”

These statements from ESCC and SELEP give the misleading and erroneous impression that the A259 is a road of strategic importance.  It must be stressed that this is not the case.

Road numbering was first introduced in 1922.  The A259 was a number given to a series of roads that then linked the coastal towns between Folkestone and Emsworth.  Since the 1950s the A27 has been designated at the principal coastal route through most of Sussex, replacing the A259, and it has been very greatly improved to perform this function.  The A259 now remains only as an incoherent sequence of local roads that, for historical reasons from a century ago, have the same number.  It mainly passes through town centres and other highly congested areas, so is entirely unsuitable for through traffic.  The Local Transport Plan (fig. 2) contains a hierarchy of ‘primary routes’ and ‘main roads’, but only categorises the A259 under ‘other roads’.  Indeed, in view of the sensitivity of the landscape through which it passes, the Society believes the stretch of the A259 between Seaford and Eastbourne should be downgraded to B road status.

ESCC’s statement also implies that increasing the capacity of the A259 will attract traffic from the A27.  It is contrary to policies that a local road through the National Park should take traffic away from a trunk road. 

Most of the housing and population growth referred to by SELEP is expected to take place in south Wealden District and neighbouring parts of Eastbourne.  This area is close to the A27 and is not served by the A259.  Newhaven is principally served by the A26 trunk road, connecting to the A27.

The document Roads in the South Downs (Enhancing the safety and quality of roads and places in the National Park) (2015) 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 A259 falls into the latter category and so should not be regarded as having any strategic function.

Traffic 

The bridge forms a link on the A259 with this section of the road running between Brighton, Newhaven and Seaford to the west and Eastbourne to the east. While not the east-west trunk road ( the A27 fulfilling this role) this part of the A259 does carry local commuter traffic and, particularly at weekends, visitor traffic. The Society is of the view that the volume of traffic on the road is largely determined by its capacity and the proposal to re-align and widen the bridge to two lanes will increase that capacity, thus attracting more vehicles to use this route in preference to the A27. Any increase in traffic on this part of the A259 will have a harmful impact not only on the immediate area but also on Seaford town centre to the west (already suffering serious congestion at peak times), East Dean and Friston to the east, and on the roads through villages lying to the north of the A259 (Alfriston, Litlington, Wilmington, Milton Street, and Jevington) and which link up with the A27 (these roads used as shortcuts and being wholly unsuitable for the volume and size of vehicles which already use them). The increase in traffic will also result in greater noise and air pollution. It should be added that this vehicle increase will predominantly comprise local commuters using the route through the Park as a means of getting from A to B. It is unlikely to encourage more Park visitors as capacity in this regard is limited by the availability of parking (three car parks at the eastern end of the bridge, being one opposite the Visitor Centre and two behind it). The pub car park caters for visitors to the pub.   

ESCC’s Traffic Assessment claims that the widening of the bridge will not lead to increases in traffic on the A259, beyond rises projected in road traffic generally.  However, it offers no evidence for this view other than that it was “agreed by all parties”.  We believe that increasing the capacity of the road at this key pinch point is very likely to attract more traffic to use this whole stretch, and so consider it inadvisable of ESCC to put forward this proposal without fully modelling its effects in traffic generation.  This is necessary especially in view of ESCC’s statement that the A259 provides an alternative to the A27, implying that journeys readily transfer between the two routes. Is it appropriate for The South Downs National Park Authority to determine this application ignoring this fundamental omission?

The Traffic Assessment also claims that the bridge widening will not attract more heavy vehicles to the road, and that such vehicles will be prevented from using it by road signs and sat nav.  We consider that the current single lane bridge is a significant deterrent to large vehicles, which will be lost if the bridge is widened.  While road signs may redirect some long-distance heavy vehicles, drivers familiar with the area are highly unlikely to be influenced by signage.

The main reason why the road will attract more traffic if the proposed bridge is built is speed. At present, the existing layout – with the bend at the west end of the bridge and its single lane – acts as a traffic-calmer, requiring all vehicles to slow down or stop before driving across the bridge.  The proposal will make the transit of the river non-stop, the application envisaging a speed limit of 30mph at this point. The majority of vehicles using the realigned, wider, bridge are unlikely to observe this proposed limit and it will be difficult to enforce.  The Design and Access Statement (at page 14) refers to the proposed new bridge as having ”a presence that will encourage slower traffic speeds”. It is difficult to comprehend what is meant by this, given that the majority of daily users of the road are local commuters who, if the proposal is adopted, are being encouraged to drive through the National Park in greater numbers and at greater speeds than at present with a view to getting more quickly to their destinations outside the Park. As for visitors in cars, it would seem fanciful to believe that they will slow down on the new bridge to admire the view, “presence or no, given other traffic behind them and the fact that the proposal envisages a barrier 1.7 metres high on either side of the road (so as to protect pedestrians on the footpaths alongside), a height above the eye-line of car-drivers.

Heritage Coast 

In recognition of its outstanding importance, this was the first heritage coast to be defined in Britain.  The A259 forms the northern boundary of the defined area.  Sussex Heritage Coast: a strategy and action plan 2016-20 The Strategy 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.”  ESCC’s ‘Planning Statement’ fails to mention or address the Heritage Coast Strategy or to adequately provide for sustainable travel especially in regards to cyclists. 

NPPF (2019) states that “Major development within a Heritage Coast is unlikely to be appropriate, unless it is compatible with its special character.”  This scheme is not compatible with the designation. Indeed it is detrimental to the Heritage Coast changing the nature of the valley to a road corridor. 

Sustainable Tourism 

The Local Plan (6.56) states that sustainable tourism will be supported, while policy SD23 says that development proposals should minimise the need for travel by private car and encourage travel by sustainable means, including public transport, walking cycling or horse riding.  We consider the widening of the bridge will principally encourage increased car use and so is in conflict with this policy.  

We would also draw attention to the 2001 publication by Transport 2000 “Tourism Without Traffic”, which gives good advice on planning for these issues in national parks. 

Tranquillity Impacts

The new bridge would be more visually intrusive into the landscape and attract more road traffic through the National Park. This is in conflict with policy SD7 ‘Relative tranquillity’, which states that proposals should not have “direct impacts that…are likely to cause changes in the visual and aural environment in the immediate vicinity of the proposals” and “indirect impacts that may be caused within the National Park that are remote from the location of the proposals themselves, such as vehicular movements.”    It also says that “Development proposals in highly tranquil and intermediate tranquillity areas should conserve and enhance, and not cause harm to, relative tranquillity.” The tranquillity of the Cuckmere valley is an important attraction for its users, residents and visitors.  This scheme adversely impacts on tranquillity. 

Noise 

The new bridge’s higher height means that noise will travel further from the road into the valley.  Noise seems only to have been measured at receptors such as houses and there is little assessment of impacts on the footpaths and Cuckmere Valley and surrounding downland more generally.  Again this seems to neglect the need to ensure the National Park is not damaged by noise. The assessment ignores the reality that increased capacity will generate more traffic. 

Opening the area for development 

The South East Local Enterprise Partnership states on its website that the replacement of the bridge will ‘unlock the full capacity of the network to support employment and housing growth. Exceat bridge is part of the A259, one of the principal road networks in East Sussex which serves two of the County’s growth areas for housing and employment: Newhaven and Eastbourne/South Wealden. The A259 is a critical route for economic connectivity from the east of the county, along the East Sussex coast to Brighton and through to West Sussex, including linkage to a key port at Newhaven.’ 

It is highly concerning that this route is being taken to be a through route. The A27 should provide the required linkages. The A259 in this location should provide access but not encourage any use of the National Park for through traffic. Treating this road as a through route makes a mockery of the National Park designation. 

The Suggested Alternative 

Since the end of March 2021, temporary traffic lights, installed by East Sussex Highways, have been in place at either end of the bridge, the stated reason being that it was “hoped the lights will improve the traffic flow on the A259 especially for people travelling from Eastbourne towards Seaford or Brighton” [news item on ESCC website]. 

These lights have worked very well in keeping to a minimum the build-up of traffic to the east of the bridge at peak hours. It is worth noting in this regard that, in recent years, when Eastbourne’s annual airshow “Airbourne” is taking place temporary traffic lights have been installed on the bridge, by East Sussex Highways, solely to cope with the sudden increase in traffic from east to west at the end of each day of the show; they have also worked well. The Society would suggest that if measures are needed to alleviate the current peak-time congestion, “smart” traffic lights (having the ability to control the traffic flow) should be installed on a permanent basis.

In addition, a simple footbridge (without viewing platforms) could be installed to run along the south side of the bridge (this being in addition to the existing footpath on the north side), thereby reducing the need for those on foot to cross the road. It could also be designed to accommodate cyclists. Further, some form of pedestrian crossing could be installed at the west end of the bridge (perhaps operating as a function of the suggested traffic lights), with another pedestrian crossing being installed from the Visitor Centre to the car park opposite. 

The alternative outlined above:

  • would cost a fraction of the money involved in the scheme outlined in the application;
  • would keep any increase in traffic to a minimum;
  • would not lead to any increase in the speed of that traffic, 

but would substantially ease, if not eliminate, the occasional congestion at peak times on the approaches to the bridge;

  • would provide safer crossing points for pedestrians and fewer reasons for crossing, will all but eliminate the risks caused by fast through traffic on a two-lane road;
  • would cause little disturbance;
  • would leave the surrounding area and its ecology wholly undisturbed; and
  • would not cause any visual harm to the existing beauty and charm of the location and the surrounding landscape.

For the reasons set out above we urge the SDNPA to refuse this application. 

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The A259 South Coast Corridor

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.

Transport strategies

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.’

National policies

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.

Local policies

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.