Tag: planning

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Your Opinion Matters

Friends of the South Downs was established 100 years ago by ordinary people taking action to protect our precious Downland landscape. Over the past 100 years, our charity’s growth and the achievement of National Park status has been down to the continued involvement of people who care. Now, as we make plans for the next 100 years, we are keen to discover your views on our charity and the issues that you feel most deserve our attention going forward. Your opinion matters to us.  We value your contribution to our future planning and look forward to sharing the results with you in future.

The Friends of the South Downs is owned and run by its members and there are many ways in which you can help. We have many volunteering opportunities for people of all ages, abilities, skills and fitness levels. If you are able to give up some of your time to help us, you’ll meet many interesting and sociable people who really care and work hard to help protect the landscape and heritage of the South Downs.

We are almost totally reliant on our volunteers in helping us achieve our aims and objectives so anyone offering to become a volunteer is always made very welcome.

Here is an example of some of the typical activities you can help us with:

Walks & Strolls Leaders

If you have local knowledge of the South Downs and are good at organising events you can help research our annual programme and lead one or a few of our over 200 walks and strolls.

Trustees / Council Members

If you want to be part of setting the strategic direction of the Society and making sure that its aims are achieved then you would be welcome as a Council member. Your opinion matters. Council meets four times a year but in addition, most members are active in other areas of the Society’s work.

District Officers

Help us keep an eye on and comment on planning applications in your own locality.

Get in touch today!

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Conversions of Barns and Other Rural Buildings

We are deeply concerned to learn of the Government’s plans to rip up the planning protections that keep our national parks beautiful by allowing permitted development rights for conversions of barns and other rural buildings. The Campaign for National Parks has now sent a letter, signed by FSD as well as other NP Societies, to Michael Gove expressing this concern. Read that letter here:

conversions of barns and other rural buildings

SIR – We are deeply concerned to learn of the Government’s plans to rip up the planning protections that keep our national parks beautiful by allowing permitted development rights for conversions of barns and other rural buildings.

National parks and areas of outstanding natural beauty are our finest landscapes, and even small changes can have a disproportionate impact in these places. If these proposals go ahead, they will lead to a free-for-all on the development of isolated residential units in unsustainable locations without the supporting infrastructure, and could add significant pressures in terms of water pollution and traffic.

Where once there was a field barn standing isolated in a hay meadow, there will be a pocket of suburbia, and this will be repeated throughout the landscape, creating sprawl and spoiling everyone’s enjoyment of nature, open space and tranquillity.

We recognise the need to provide more affordable housing across the country, but residential barn conversions in remote places like the Yorkshire Dales National Park would do nothing to help and would instead cause irreparable damage to our fragile countryside.

National parks and areas of outstanding natural beauty are living landscapes that must adapt over time, and the current approach to planning does a difficult job well in balancing progress with protection. The Government should shut the barn door on these disastrous proposals before the horse bolts.

What the Friends of the South Downs Do

We have a Planning and Conservation Committee whose primary objective is to influence the decisions made so that the beauty, amenity and tranquillity of the South Downs is either conserved or sustainably enhanced for public benefit.

To achieve this, our role is to consider planning applications that are made either within or close to the National Park boundary. This is done through a team of Volunteer District Officers, each covering a specific ‘District’ within the Park. Each Officer inspects new planning applications that have been made in their District to assess the likely impact. If considered necessary, a response to an application is submitted to either the National Park Planning Authority or the Local Planning Authority to whom planning decisions have been delegated. A response may set out our concerns including an objection, provide constructive comments and observations or we may present written support for an application on the basis that the Society considers that it will meet National Park purposes.

Would you like to join us as a member to support our work or volunteer with us? Get in touch today!

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Permitted Development Rights (PDR)

We were deeply disappointed to learn of the Government’s plans to extend the Permitted Development Rights (PDR) for any agricultural or rural building to Protected Landscapes (National Parks and Areas of Outstanding Natural Beauty (AONBs)). There is a long-established practice of not applying certain permitted development rights in these areas in line with national planning policy which emphasises the importance of protecting these areas from inappropriate development.

We were deeply disappointed to learn of the Government’s plans to extend the Permitted Development Rights (PDR)

Our Trustees are alarmed and disappointed, as, we are sure will be our members, to see the PDR proposals in relation to our National Parks.  We are strongly opposed to them.

Our Response to this Consultation

1.  The Friends of the South Downs (FSD) have over 1,500 members and their focus is the conservation and enhancement of the landscape of the South Downs National Park and its quiet enjoyment by everyone. To this end we support and uphold the statutory purposes and special qualities of the National Park. We support the work of the South Downs National Park Authority: we warmly applaud the Authority’s successful and effective Local Plan and the Authority’s work to enhance the natural infrastructure that the Park represents, to increase nature recovery and measures in relation to climate change. We have a close and beneficial relationship with the Authority.

2.  Our Trustees are alarmed and disappointed, as, we are sure will be our members, to see the PDR proposals in relation to our National Parks.  We are strongly opposed to them.

3.   We should not need to remind you that the statutory purposes of the South Downs National Park and indeed all our national parks – section 61(1) Environment Act 1995 – do not include scope for watering-down or compromise. They form the key statutory imperative that should guide all decisions where our national parks are concerned.

4.  We are very supportive of the work of Julian Glover and the important findings in his report, Landscapes Review. On page 64, he wrote:

 ‘The current Permitted Development Rights (PDR) system should also be reviewed and, if necessary, further PDRs should be added to the list of those currently withdrawn within national landscapes to ensure that the full application process applies before determining planning approval.

For example, forestry and agricultural changes allowed under permitted development can have significant impacts on landscape quality, and the South East and East Protected Landscapes forum has made a convincing case that these should be reviewed.’

5.   The Government’s response to Glover acknowledged in relation to Planning Reform that: ‘A strong and effective system must sustainably balance protections with supporting local communities and economies. The balancing exercise must be carried out differently in protected landscapes, to ensure their statutory purposes and special qualities are meaningfully protected. This involves giving greater weight to their special qualities in planning policies, procedures, and decisions.’

On the following page, under the heading ‘Permitted development’, the response went on:

‘The review also highlighted that certain Permitted Development Rights (PDR) may impact landscape quality, and proposal 6 suggested a review of existing rights.

We recognise that permitted development rights can play an important role in delivering new homes, particularly in rural areas. This benefits householders and businesses. We will continue to monitor the use of permitted development rights in protected landscapes and identify future opportunities to review their use.’

6.  Now comes this consultation. Still nothing has happened about implementing Glover beyond a response admitting that ‘this balancing exercise must be carried out differently in protected landscapes’. These proposals though offer no meaningful protection. In fact, they represent the very opposite; one of the biggest threats to the national parks in a generation. We are concerned that the proposals do not include detailed justification for the changes proposed, nor is there any environmental impact appraisal. Our view is that the existing regime works well and it complies properly with the statutory responsibility. 

7.  We are concerned about the conversion of barns. However, there is a planning process in place. It does work. We have seen barn conversions granted, but they have all had to go through a rigorous process to ensure there was no damage to the landscape and environment. What we are more concerned about here in the South Downs is the proposal relating to equestrian use. Over the years the SDNPA has dealt with numerous applications for stables. Of late, there has been a trickle of applications to convert those stables. For the most part those have been for tourism rather than as separate residences because of planning policies. However, If these proposals were enacted, it has to be anticipated there would be a wave of conversions. We would end up with unsuitable buildings in unsuitable locations, with domestic paraphernalia and little pockets of suburbia across the Downs, with increased vehicle movements. There would be little benefit in terms of housing numbers and to communities in the Park. The main beneficiaries in the South Downs would be horse owners, not farmers. The fragile landscape and tranquillity of the South Downs National Park are far too precious to risk being compromised in this manner. Even seemingly small or very small developments can compromise out of all proportion.     

8.  The FSD includes an expert planning committee, who review every planning application and decision within or near the Park. The committee sees no need to adjust the current exemptions and emphasise that any bona fide case for conversion or increase is easily put forward in a planning application which will be expertly assessed by the Authority’s professional staff. Any farmer or property owner will not be deterred from a worthwhile conversion scheme by the need to make a planning application; indeed, the pre-app process often brings forward helpful advice and suggestions. In short, the application process is not burdensome or unhelpful or contrary to the public interest.    

9.  The crux of this is that a bona fide scheme for conversion or enlargement within the South Down National Park can easily be assessed by planning application and no deserving farmer or owner will be deterred: a sound outcome is achieved and the provisions of the Environment Act are upheld.

10.  We have noted below the consultation question numbers that concern this response.

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Be a Friend

Celebrating our Centenary this year, we have some exciting events planned as well as funding some projects that will make a real difference on the Downs. We’d like to take this opportunity to thank all our members for their continued support and invite all our new friends to join us today. Be a Friend of the South Downs.

Be a Friend of the South Downs

As a member, you have access to over 200 walks and strolls a year. Your membership helps support our team of District Officers who monitor planning applications throughout the South Downs National Park. Your membership also helps support our extensive educational programmes with schools.

The Friends of the South Downs has agreed a major programme of spending totalling over £100,000 in our Centenary year, to benefit the Downs in the short term and the long term. The Friends can spend this money because they are fortunate to have recently received two substantial legacies. You can help us make these legacies go even farther by supporting us. Be a friend.

Bigger Items of Spending in the Plan

  • £60,000 to the National Park Authority for the refurbishment of the iconic 18th century pump barn building at the Seven Sisters country park, which will be used to showcase the Downs for visitors and provide space for activities.
  • £20,000 for projects to encourage children to learn about and appreciate the South Downs.  We’re running the projects with bodies like the National Park Authority and Youth Hostels Association.  We’re aiming at children for groups who are less likely to visit the Downs.  The plan is to teach them about the landscape and history, and most of all encourage them to appreciate and value the Downs.

Be a Friend and Support our Projects

  • providing attractive wooden benches, converting stiles to gates to improve access and placing information boards at significant locations.
  • helping make a path more accessible for people with limited mobility, planned location Devils Dyke. 
  • Contributing to the cost of staging a play based on Hilaire Belloc’s famous book The Four Men about a walk across the Downs.
  • Financing prizes at Brighton University for academic work relevant to the South Downs.

Upcoming Centenary Events

Be a friend and join today!

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Our Centenary Year

Our Centenary year in 2023 provides a great opportunity to celebrate the South Downs and the role of the Friends of the South Downs, and to publicise what we do. To mark our Centenary year we are planning significant events and activities to celebrate the beginnings of the Society.

Seven Sisters from Cuckmere Haven Friends of the South Downs

It’s difficult to imagine a world in which people could build without restriction on a landscape of outstanding beauty, yet that is the threat that our predecessors faced almost 100 years ago.

After witnessing the construction of Peacehaven on the chalk cliffs to the west of the Ouse, our founder members feared what would happen to the rest of the eastern Downs in that time without effective planning controls.  To counter that threat they joined together in 1923 to form ‘a society for the preservation of the Downs’, which soon became the Society of Sussex Downsmen.  We later changed the name to the South Downs Society and are now known as the Friends of the South Downs.

Peacehaven our centenary year friends of the south downs

‘One spring day in 1923 on the chalk cliffs overlooking the Channel, two men, brothers-in-law, walking east from Brighton, were dismayed to come upon the new settlement of Peacehaven, developed on what was once downland. There was only rudimentary town planning in the 1920s and Peacehaven had been sold in plots, with no control over the dwellings to be built on them. It was no more than a shanty town.

‘Their day doubtless spoilt, Robert Thurston Hopkins and Captain Irvine Bately returned to their homes in Brighton resolved to try to prevent any further loss of the precious landscape of the Sussex Downs. Thurston Hopkins made contact with Gordon Volk. A committee was formed comprising Robert Thurston Hopkins, his wife Sybil, Captain Irvine Bately, his wife Lilian, and Gordon Volk. Volk then approached Arthur Beckett, a prominent newspaper owner. Beckett agreed to become President of the new society. Late in 1923, a crowded public meeting in the Royal Pavilion enthusiastically resolved to form a society for the preservation of the Downs.‘ Excerpt from Richard Reed’s A Centenary History of the Friends of the South Downs.

The threats to the Downs may have changed over the last 100 years but we still remain vigilant to protect the natural beauty of the area. To mark our Centenary year we are planning these significant events and activities.

South Downs for All:  a two-year lottery-funded project to encourage children to know and love the Downs. We’re working with two secondary and six primary schools to take children on field trips on the Downs.  The schools chosen have higher than average less well-off and ethnic minority children: groups which are less likely to visit the great outdoors.

A fascinating new book on the history of the Friends. Written by Richard Reed, who has been a member for a remarkable 75 years, the book traces our history from the struggles of the 1920s when there were few planning controls to the challenges of today.  The book is available to all members and available to purchase on our website.

Stimulating talks by prominent personalities. We have arranged tremendous online talks in 2023 by

  • Hilary Benn, the Labour Member of Parliament for Leeds Central who, in 2009, signed the order confirming the designation of the South Downs National Park. Register here!
  • Alistair Appleton, television broadcaster (Escape to the Country), psychotherapist and meditation teacher at Mindsprings in East Sussex
  • Isabella Tree, award-winning author of Wilding who, with her husband Charlie Burrell, run the rewilding project at Knepp Estate in West Sussex

Recreation of Hilaire Belloc’s Four Men walk We will walk in the summer of 2023 perhaps one of the first long-distance trails, Hilaire Belloc’s route from Robertsbridge to South Harting. We’re also thinking as well of ways to make the walk better known.

Making a length of footpath more accessible We plan to improve a selected footpath to make it accessible for wheelchair users. We’re still working out the details of the best site to choose and will keep you updated.

A cycling festival Cycling, particularly with electric bikes, can help people access suitable routes on the Downs. We are working with selected bike shops this summer to run events near the South Downs Way to demonstrate and try the latest regular and electric bikes.

Centenary appeal Would you like to help these exciting events and projects happen?  Please get in touch. We’d love to hear from you!

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Eton New Town

Update October 31, 2023: The proposed Eton New Town project, aiming to introduce up to 3,250 new homes in East Sussex, has been rejected by local planners. Lewes District Council has opted not to include this development, slated for land owned by Eton College near East Chiltington, in its local plan.

Eton New Town Barry Page Photographer
Photo courtesy of Don’t Urbanise The Downs by Barry Page Photographer

The council cited the site’s unsuitability and emphasized the need for smaller, more affordable housing options. The North Barnes Farm Partnership expressed deep disappointment, labeling the decision as misguided.

Council officials conducted a thorough assessment, concluding that the site fell short of meeting the necessary criteria. Zoe Nicholson, leader of the council from the Green Party, underlined the importance of sustainable development alongside the pressing need for additional housing.

Damon Turner of the North Barnes Farm Partnership voiced their disappointment, asserting that their proposal offered a comprehensive solution to housing, environmental, and climate challenges. The exclusion of North Barnes Farm is viewed as a setback for Lewes’ future development, according to the developer, prompting a careful consideration of the next steps.

On Thursday 9 November 2023, councillors will convene to discuss and potentially approve the next phase of public consultation on the local plan.

November 8, 2021: 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 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. 

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.

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‘Dreadful’ design for former Auction Rooms in Garden Street, Lewes with no affordable homes

Our volunteer District Officers (DOs), Liz Thomas and Jennifer Chibnall, spoke at the National Park planning committee meeting earlier in March 2020 against a proposal to build large glass and timber clad tower houses on this site which was allocated in the Lewes Neighbourhood Plan to meet local housing need.  The National Park planning officers had recommended the proposal be accepted even though the development didn’t include any affordable housing. The expensive ‘novel’ design was offered as reason why none of the houses could be affordable.  Liz Thomas drew attention to the precedent set by a High Court case in London which rejected such building on sites that has been designated for affordable housing.

 

 

 

 

 

There was much criticism of the design, in particular from the chair of the Planning Committee, both for its unsuitability in this Lewes Conservation Area and it being so expensive in its construction that the applicant argued this precluded affordable housing.  As a result, the officer recommendation was rejected unanimously by the committee, and the application refused. Click the links below to see our DOs in action and the Chair’s excellent dissection of Conservation Area purposes.  He held that any development in a Conservation Area, must respect and reflect the original reasons for the designation saying –  it was not sufficient to argue a development was “good architecture” in isolation and it must be framed by the reasons originally set out for the area to be conserved.

Click on their namehere  to see Jennifer Chibnall and Liz Thomas in action

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Design Consultation: new development of 226 homes at Old Malling Farm Lewes

Local Lewes councillors and the Friends of the South Downs (South Downs Society) called on the developer to reduce the over provision of parking for each property on the site but called for on street parking restrictions to prevent commuter parking causing problems for the new householders. There is already local concern as nearby is the HQ for both the Police and Fire Services.  The Society also called for

  • Improved cycling and walking links to Lewes town which is only a short distance away.
  • A better design to compensate for the loss of biodiversity and ecosystem services at thid greenfield site.
  • A pedestrian crossing on Old Malling Way –  via a ‘Grampian-style’ condition (meaning it would happen before the wider development begins).
  • Provision of zero carbon houses, – the design brief layout must cover the type of heating to be used. If solar panels are to be used, the layout needs to addressed from the outset

Consultation on the design brief has now closed, but more details of the proposal can be found by searching for the reference SDNP/DBC/SD76 on the South Downs National Park planning portal. Consultation on the wider outline application is still active, however, with more details available by searching for the reference SDNP/18/06103/OUT. For more information go to: https://www.southdowns.gov.uk/old-malling-farm-design-brief/

The Society’s response was prepared by our Lewes Town volunteer District Officers – Liz Thomas and Dr Jennifer Chibnall – click below to read the document:

SDS Response to SDNP Design Brief Consultation March 2020