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.
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 area. The 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.
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.
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.
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.
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.
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.
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.