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Clever Local Herds

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

Photo: Graham Stockley

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

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

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

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

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

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

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

Malinka van der Gaauw

Walks Leader

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Easebourne/Langham Circular Walk

This Easebourne/Langham circular walk is an easy walk starting either in Easebourne or at Langham Brewery and takes you through open fields with views of the South Downs and patches of woodland with a small amount of road walking on the end by the brewery.

Easebourne/Langham Circular Walk

You can start the Easebourne/Langham circular walk by parking at Langham’s Brewery carpark and walk clockwise or anticlockwise around the whole route (5.7miles) or make it into a figure-of-eight. If this is too far for you, just do the first half of the figure-of-eight (2.5 miles). If you do the whole route and would like to make the walk a little longer, the delightful Easebourne Street is lovely to wander down beside the little culvert which is the River Ez. You will be treated to a very unspoiled selection of the old houses and gardens of Easebourne village.  

Alternatively, if you start from Easebourne Street, where there is parking on-street (left hand side of the map), you can use the brewery as a half-way rest point. Warning! After a beer and Langham’s delicious pizza, the second half of the route seems longer!

Primroses in the River Ez

Langham Brewery offers a delicious range of fresh keg beer, cask conditioned real ale, bottles and cans – lovingly brewed at their award-winning microbrewery in West Sussex, in the South Downs National Park, near Petworth. The brewery is the perfect destination experience; walkers, cyclists, hikers and day-trippers are all warmly welcomed.

The Brewery’s Taproom and Shop are open 6 days a week, and this month the Taproom turns a year old. Please save the date for the celebrations: Saturday 16th April, from 5pm – 9.30pm. Expect live music, a hog roast (delicious veggie options also available) and a well-stocked, award-winning bar. This is a free-to-enjoy event, but please bring loose changes (and notes!) as there will be a collection for the https://davidnottfoundation.com

As well as an extensive range of beers, the team also serve soft drinks, delicious cakes, local, authentic Italian pizzas, and more. Try 4 Langham brews in a single purchase via their ‘flights’ – the brewery’s flight attendant (formerly BA!) is happy to guide you through your tasting experience. The Taproom is also available for private hire.

For loved ones who enjoy craft ale, a gift voucher makes an ideal gift – available for Brewery Tours, beer and merchandise, as well as the new ‘Be A Brewer For The Day’ voucher.

Easebourne/Langham Circular Walk leads to Langham’s taproom!
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We Need Volunteers

Singleton Forest

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

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

The location details are:

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

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

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

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Ban Plastic Tree Guards 

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

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

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

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

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

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

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

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

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

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

Full statement: 

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

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

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

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

Signed:

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

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The English Christmas Mummer’s Play

Normally, across Great Britain, from mid-November until Twelfth Night, you might be lucky enough to witness the performance of The English Christmas Mummer’s Play. “What is a Mummer?” you ask. Glynn Jones is going to give us “one man’s view”!

What I am about to share with you is “one man’s view” on the tradition of The English Christmas Mummer’s Play. This is my opinion, not a thoroughly researched thesis. I am not an academic or a scholar but I have been performing in Mummers’ plays for over twenty years and am currently the Captain of Sompting Tipteers. “What I do – I do plainly before your face and if you can’t believe that – it’s a very hard case”.

The following is a mixture of recorded history and plausible conjecture. I am going to give you some of the background to Mumming as I understand it and introduce you to the play that Sompting Tipteers perform.

What is a “Mummer”?     

Dating from the Mediaeval period, a Mummer is one who delivers a masked or disguised performance also known as Guisers or Rhymers, Pace-Eggers, Soulers, Galoshins and in Kent and Sussex-Tipteerers. The name, perhaps, came from the Greek word “Mommo”, meaning a mask, the wearing of which became popular at royal functions in the fourteenth century, the practice of such being termed as “Momerie”. A group of Mummers or Tipteerers is now known as a “Side” or “Team” and it is usually led and (loosely) organised by its Captain.
 
The Plays as we now know them

The plays performed today are mostly Hero Combat Tales – depicting battles between good and evil – light and darkness – life and death; they may have differing story lines and characters but the format is broadly similar. Traditionally, an all-male cast even for female characters. An heroic or villainous figure enters and grandly announces himself – he makes a boast about his prowess – this leads to a fight – one of the protagonists falls wounded or dead – the wounded man is then resurrected promptly by Father Christmas or by a doctor figure who makes much fuss about his skills and his fee. The actors divide into the “Principle” parts and the “Fancy” or smaller parts. A study of scripts gives the impression that Fancy parts were made up and added at will to give opportunities for others to take part and share the spoils. The Hero-Combat tradition with its boasts, battles and rebirth is represented in many cultures throughout the world, for instance, Katha Kali dancers in Kerela, southern India, perform a very similar tale in their travels around the rural villages.

There are three main theories regarding the origins of our plays.

Prehistoric Ritual.
Many say that Mumming, like Morris Dancing is not Folk entertainment but a survival of pre-Christian ritual activity. For these purposes we will define “ritual” as a ceremony carried out by a Shaman and/or his/her acolytes to bring about a desired outcome.

Three witches chanting Hubble Bubble Toil and Trouble around a steaming cauldron is one example, aboriginal people dancing to bring the approval of their gods in a forthcoming hunt or battle is another. Broadly we would describe pre-historic activities like these as pagan and as such unacceptable to the Christian Church.

Mediaeval Period – The Dark Ages
As the name suggests we have very poor records of life in this period. There are tantalising references to mummers from the mediaeval period but no surviving evidence of the nature of the performances other than the idea that they involved disguise and were intended to educate or entertain. It is therefore unsafe to assume that they were performing early versions of today’s hero–combat play or survivals of prehistoric rituals. It is reasonably certain that Mummers had no connection with the Mystery Plays of that period
 
Mid to Late Eighteenth Century
In the late 17th to Early 18th century European Commedia dell’arte spread from mainland Europe to England, it was an important milestone in the development of theatre as we know it and a source of inspiration for several genres including Pantomime and Punch and Judy. Said to be the first entirely professional form of theatre often performed in the open (Street Theatre) and funded by passing the hat. Commedia is a very physical type of theatre that uses dance, music, the slapstick, tumbling, acrobatics and buffoonery. The plays were based on a selection of Stock Characters, easily recognisable “Types” who the public loved to ridicule. One of these was El Dottore who represented a (supposedly) learned man but not necessarily a man of medicine. It would appear that disdain for “Experts” by the less well educated has a long history.

It is generally accepted that this was a major influence on the Mummers’ Play as we know it today. This type of theatre is likely to have been seen or heard about by common working people and the ideas and the style may have been adopted to put on their own entertainments.


Later Developments
Christmas was a lean time for many agricultural workers. There was little employment at that time of the year and not much to celebrate. It is suggested that the poorer members of the parish would put on an entertainment for those with something to spare. The plays would typically be performed at the grand private houses, the pubs and inns around the village, hence Father Christmas’s common opening line – In comes I Old Father Christmas, am I welcome or am I not?The players would be rewarded with a drink, something to eat or a few coins, all of which helped Christmas cheer. These folk would not have access to expensive theatrical make up and the easiest way for them to transform their appearance was to use soot or burnt cork. It is unfortunate that this has more recently been interpreted as “Blacking Up” or “Cultural Appropriation” and is now officially frowned upon when it certainly wasn’t the original intention.

Most rural villages in the South would have had their own play which was part of oral tradition; many of the players would have been illiterate and written scripts would be of little use. This has led to “mission creep” with ideas, lines and characters changing through time and from village to village. Adjoining villages would have very similar plays but the small differences would accumulate with distance and a play on the other side of the county would be recognisable but very different. Characters can change sides from good to evil and their lines become swapped around. The various elements of the play may stem from several sources, though these are hard to pin down.

Many of the people who the play had been handed down to had been killed in WW1, but a renewed interest in folk customs occurred and R.J. Sharp headed the revival in Sussex, forming the Boxgrove Tipteerers in 1927. Mr. Sharp first saw the play, revived by a Mr. Foard, when he was living in East Preston. Mr. Foard learned the play when he was a boy.  
Our Play

The play, currently, performed by Sompting Tipteers is not the Sompting Play. The Sompting play is said to have been recorded by a Mrs Pullenberry of Sompting in the late 1800s. The script survives but, for reasons unknown to us, we in fact perform the, very similar, Steyning Play. This is yet another mumming mystery.

Glynn Jones,

Trustee

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Strolling with the Romans

Would you like to go strolling with the Romans, along the road from Noviomagnus to Londinium? Stane Street, the Roman road that ran from Chichester (Noviomagnus) to London, was originally up to ten metres wide. Much of it is buried under modern roads following the same route.  The exact date of construction is uncertain; however, on the basis of archaeological finds, it was in use by 70 AD.

Stane Street photo by Judy Robinson

Stane Street shows that Roman roads were not always as straight as we used to believe.  A straight line alignment from London Bridge to Chichester would have required steep crossings of the North Downs, Greensand Ridge and South Downs and so after the first section, the road was designed to exploit a natural gap in the North Downs cut by the River Mole and to pass to the east of the high ground of Leith Hill, before following flatter land in the River Arun valley to Pulborough. Although at no point does the road lie more than 6 miles from the direct line.

The Stroll

There is something special about walking along a route that was constructed by Roman soldiers so long ago.  Along the way you get a great view of the Channel on the horizon, which seems to be remarkably close and at one point the Roman road cuts through an earlier, prehistoric linear earthwork .  The path descends into woodland and at the lowest point can be quite muddy until you start uphill again through the trees.  Its a moderate stroll but if you would like to extend it, the route connects to both the Monarch’s Way and the South Downs Way.

Bignor is also the location of a Roman Villa of domestic proportions where you can really get the feel of how people lived.  There are some good mosaics, a bath house and an example of a hypocaust (underfloor heating system). The site was discovered by George Tupper in 1811 when he uncovered the Summer dining room water basin after striking it with his plough.  

Today the Villa is still managed by the Tupper family under the control of Trustees.  It is open in the spring/summer months and has a tea room.  (check website for 2021 opening times). It well worth a visit and needs support, as it is an ongoing battle to preserve the site from the elements and damp etc.  You can see why the wealthy family who built it, chose the location, as it stands in a beautiful valley. Nowadays there is a vineyard right next door and as it is thought that the Romans introduced wine making into Britain, that seems very fitting.

What did the Romans ever do for us? Take a trip to this area and see for yourself.

Caroline Douglas, Trustee

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Proposed Exceat Bridge Replacement

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

Application no. SDNP/21/02342/FUL

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

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

Summary of objections

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

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

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

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

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

Quality of the application documents 

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

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

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

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

National Park Development / Major Development 

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

The purposes of the National Park are reflected in South Downs Local Plan Policy SD1: Sustainable Development’ which states that “Planning permission will be refused where development proposals fail to conserve the landscape, natural beauty, wildlife and cultural heritage of the National Park unless, exceptionally: a) The benefits of the proposal demonstrably outweigh the great weight to be attached to those interests.”  

We maintain that this proposal has not demonstrated this case.  

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

Road provision in National Parks 

English National Parks and the Broads: UK Government Vision and Circular 2010 contains the most important national policy regarding roads in national parks:

“There is a strong presumption against any significant road widening or building of new roads through a Park, unless it can be shown there are compelling reasons for new or enhanced capacity and with any benefits outweighing the costs very significantly.”

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

National Planning Policy Framework (NPPF).  Section 15, Para172 of the NPPF 2019 ‘Conserving and enhancing the natural environment’ states that “Great weight should be given to conserving and enhancing landscape and scenic beauty in National Parks … which have the highest status of protection in relation to these issues….The scale and extent of development within these designated areas should be limited.  Planning permission should be refused for major development other than in exceptional circumstances…”. 

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

Transport Infrastructure 

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

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

Requirements for infrastructure 

South Downs Local Plan Policy SD42: Infrastructure’ states that “Development proposals for new, improved or supporting infrastructure will only be permitted where: a) It represents the least environmentally harmful option reasonably available … and b) the design minimises the impact on the natural beauty, wildlife and cultural heritage of the National Park and the general amenity of local communities.”  

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

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

The landscape impact 

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

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

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

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

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

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

Increased lighting /dark skies

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

Impact on the natural environment.  

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

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

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

Provision for cyclists and pedestrians

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

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

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

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

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

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

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

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

Footpath closures during construction

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

The A259 is not a strategic route. 

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

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

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

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

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

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

The document Roads in the South Downs (Enhancing the safety and quality of roads and places in the National Park) (2015) contains a core principle of “Maintaining a clear distinction between single-purpose, high-speed strategic routes, and the ‘public realm’ associated with the mixed-use, slower-speed network.”  The A259 falls into the latter category and so should not be regarded as having any strategic function.

Traffic 

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

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

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

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

Heritage Coast 

In recognition of its outstanding importance, this was the first heritage coast to be defined in Britain.  The A259 forms the northern boundary of the defined area.  Sussex Heritage Coast: a strategy and action plan 2016-20 The Strategy states (in section 3) that “There will be a need to consider key access routes such as the A259.  There is also a need to assess any road scheme proposals against enhancement of landscape (e.g. pressure for … A259 road improvements) Measures to support and enable sustainable transport options need to be seriously considered.”  ESCC’s ‘Planning Statement’ fails to mention or address the Heritage Coast Strategy or to adequately provide for sustainable travel especially in regards to cyclists. 

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

Sustainable Tourism 

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

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

Tranquillity Impacts

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

Noise 

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

Opening the area for development 

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

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

The Suggested Alternative 

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

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

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

The alternative outlined above:

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

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

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

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

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The A259 South Coast Corridor

We have been passed an early consultation on improvements to the A259 South Coast Corridor. We are concerned these may increase traffic on the A259 impacting the coastal towns along its route and the Cuckmere Valley in particular. See what we have said here.

These are the comments of the Friends of the South Downs (South Downs Society).  Founded in 1923, we have 1500 members and campaign to protect the natural beauty and public enjoyment of England’s newest national park. We have seen your email of 6th October 2021 regarding consultation on the A259 South Coast Corridor Study.  We find that the on-line questionnaire seems mainly suited to individual road users rather than organisations such as ours, so we felt it more helpful to provide a written response.

We have a strong interest in the study because the A259 has a major impact on the South Downs National Park.  The stretch of this road between Eastbourne and Seaford passes through some of the finest landscapes of the South Downs National Park, and also forms the northern border of the defined Sussex Heritage Coast.  Between Brighton and Seaford the A259 passes through and adjoins several parts of the Park where its boundaries extend to the coast.

We welcome your comments about encouraging sustainable transport and protecting the environment.  However, we are very concerned at your remarks about “improvements” to the A259, supporting growth and providing for greater use of private vehicles.  This implies that you are seeking to substantially increase the capacity of the A259 through widening and other measures, and to accommodate growing traffic volumes.  We strongly believe that, due to the A259’s route through the National Park, this capacity increase is wholly inappropriate.

We are also concerned at the current proposal to rebuild the bridge over the Cuckmere River at Exceat.  We have objected to the planning application and append our objection letter of 24th June 2021 for your information.

We consider that the A259 study, and its presumption that traffic capacity needs to be increased, conflicts with all the relevant plans, strategies and policies that apply at local, regional and national levels.

Transport strategies

The A259 is a number allocated in 1922 to a series of roads that then connected south coast towns between Folkstone and Emsworth.  While the A259 remains part of the primary road network from Folkstone to Pevensey, west of Pevensey the strategy has for many decades been for the A27 to serve as the principal route along the south coast, and it has been very significantly improved to perform this function.  The A259 from Pevensey to Emsworth, Hampshire, now serves only local journeys. 

Your email states that the A259 study will directly complement Transport for the South East’s Transport Strategy 2020 and specifically their outer orbital corridor study.  We question this as the Strategy recognises that the south coast corridor presents challenges but states that a consensus should be built on a multi-modal approach.  Your study instead looks at road capacity in isolation.

East Sussex County Council’s current Local Transport Plan contains a hierarchy of ‘primary routes’ and ‘main roads’, but only categorises the A259 under ‘other roads’.   The study’s proposal to increase capacity of the A259 conflicts with this plan.

ESCC was one of the authors of the document Roads in the South Downs: Enhancing the safety and quality of roads and places in the National Park (2015).  This contains a core principle of “Maintaining a clear distinction between single-purpose, high-speed strategic routes, and the ‘public realm’ associated with the mixed-use, slower-speed network.”  The document lists roads that fall into the first category, such as the A26 and A27; the A259 is in the latter category which “serve a multitude of functions in addition to transport”.  “Improving” and increasing traffic volumes on the A259 would conflict with the aims of this document.

Roads in the South Downs – Enhancing the safety and quality of roads and places in the National Park – South Downs National Park Authority, 2015

This guide in its introduction states that:

‘The guide recognizes and highlights the key role played by roads and highways in forming the immediate foreground for most visitors to the Park, and the important influence played by legislation, duties and policies for road design in determining expectations, driver behaviour and values. The guide sits under the Protocol for the Management of Highways in the South Downs National Park agreed with the four Local Highway Authorities (LHAs), Highways England and the SDNPA. This local officer protocol sets out a vision for ‘a highway network that is managed and maintained in such a way that it conserves and enhances the South Downs outstanding landscape quality and local distinctiveness whilst delivering a safe and convenient network for all users and modes of transport.

The guide aims to help avoid the tendency for highways to suburbanize and standardise the landscape. To this end, an approach based on careful analysis of appropriate design speeds for traffic combines with an emphasis on distinctive place-making, village entrances and an integration of roads and streetscapes with their surrounding buildings, features and landscape elements. Building on a growing number of case studies, the guide is intended to inform and inspire officers, councillors, agencies and residents alike to share a broad vision for the long-term care and conservation of a unique and valuable national asset.’

The emphasis is on conserving the South Downs and a multi modal approach.

Perhaps though what is most interesting is that the A259 is not listed as a major route;

‘The major highway network is dominated by north-south routes, connecting the south coast ports and settlements to London and the Midlands. These include the M3, the A3,the A24, the A29, the A283 / A285 and the A23. There are fewer east-west routes; the A272 runs through the centre of the western portion of the National Park, with the A27 linking the conurbations to the south and connecting Brighton to Lewes and Eastbourne.’

National policies

English National Parks and the Broads: UK Government Vision and Circular 2010 contains the most important national policy regarding roads in national parks:

“There is a strong presumption against any significant road widening or building of new roads through a Park, unless it can be shown there are compelling reasons for new or enhanced capacity and with any benefits outweighing the costs very significantly.”

National Policy Statement on National Networks, 2014

The National Policy Statement on National Network, 2014 includes a more recent reiteration of the presumption against significant road widening or the building of new roads in National Parks.

Paragraph 5.152 states that:

‘there is a strong presumption against any significant road widening or the building of new roads and strategic rail freight interchanges in a National Park, …. unless it can be shown there are compelling reasons for the new or enhanced capacity and with any benefits outweighing the costs very significantly. Planning of the Strategic Road Network should encourage routes that avoid National Parks….’

The NPS also reiterates the more general assumption against major development set out in the National Planning Policy Framework.

The National Planning Policy Framework

The National Planning Policy Framework is unsupportive of this development. By way of example;

Para 171 states that:

‘Plans should reduce risk from coastal change by avoiding inappropriate development in vulnerable areas and not exacerbating the impacts of physical changes to the coast.’

Given the proximity of the A259 to the coast and the erosion of the chalk cliffs spending vast sums on a road that may require future coastal defences or rerouting seems to lack sense.

While the study runs between Rottingdean and Pevensey it is worth noting that congestion and risk of cliff fall is perhaps greatest on the Rottingdean to Brighton section and it would thus seem advisable to consider this part of the route in the study. NPPF Para 174 (e) also mentions land instability – which the chalk coast is (If stable the cliffs would not be white!).

Likewise, is developing a route running through the Cuckmere Valley which is expected to be inundated with water in coming years sensible? Are we looking at a raised route across the Cuckmere Valley? The raising of Exceat Bridge recently proposed seems to suggest this may be the case.

Para 174 states that :

‘Planning policies and decisions should contribute to and enhance the natural and local environment by:

a) protecting and enhancing valued landscapes, sites of biodiversity or geological value and soils (in a manner commensurate with their statutory status or identified quality in the development plan);

b) recognising the intrinsic character and beauty of the countryside, and the wider benefits from natural capital and ecosystem services – including the economic and other benefits of the best and most versatile agricultural land, and of trees and woodland;

c) maintaining the character of the undeveloped coast, while improving public access to it where appropriate;

d) minimising impacts on and providing net gains for biodiversity, including by establishing coherent ecological networks that are more resilient to current and future pressures;

e) preventing new and existing development from contributing to, being put at unacceptable risk from, or being adversely affected by, unacceptable levels of soil, air, water or noise pollution or land instability. Development should, wherever possible, help to improve local environmental conditions such as air and water quality, taking into account relevant information such as river basin management plans….’

Para 176 states that;

‘Great weight should be given to conserving and enhancing landscape and scenic beauty in National Parks, …. which have the highest status of protection in relation to these issues. The conservation and enhancement of wildlife and cultural heritage are also important

considerations in these areas, and should be given great weight in National Parks … The scale and extent of development within all these designated areas should be limited, while development within their setting should be sensitively located and designed to avoid or minimise adverse impacts on the designated areas.’

It should be noted that even the setting of the National Park is to be safeguarded – a change brought in in the latest version of the NPPF and thus reflecting current government priorities.

Paragraph 177 states that;

‘When considering applications for development within National Parks, the Broads and Areas of Outstanding Natural Beauty, permission should be refused for major development other than in exceptional circumstances, and where it can be demonstrated that the development is in the public interest. Consideration of such applications should include an assessment of:

a) the need for the development, including in terms of any national considerations, and the impact of permitting it, or refusing it, upon the local economy;

b) the cost of, and scope for, developing outside the designated area, or meeting the need for it in some other way; and

c) any detrimental effect on the environment, the landscape and recreational opportunities, and the extent to which that could be moderated.’

Para 177b refers to the scope for locating development away from the National Park. This need to be considered given the A27 being a parallel and easily substitutable and somewhat less impactful road.

Since the study envisages increasing capacity on the A259 this is likely to involve widening and other works that would be contrary to these national policies.

It is hard to see how road improvements are compatible with the Heritage Coast designation offered protection by Para 178:

‘Within areas defined as Heritage Coast (and that do not already fall within one of the designated areas mentioned in paragraph 176), planning policies and decisions should be consistent with the special character of the area and the importance of its conservation. Major development within a Heritage Coast is unlikely to be appropriate, unless it is compatible with its special character.’

The National Parks and Access to the Countryside Act 1949 sets out the purposes of national parks: to conserve and enhance their natural beauty, wildlife and cultural heritage, and; to promote

opportunities for the understanding and enjoyment by the public.  It applies the “Sandford principle”, giving priority to the first purpose.  The Act (s11A(2)) also imposes a duty on relevant authorities, including county councils, to have regard to these purposes and the Sandford principle when exercising or performing any functions that affect a national park.  This duty applies to activities outside a national park that may have an effect on it.  In view of the fact that the whole study area is within or close to the South Downs, we are surprised that your email and questionnaire make no reference to the national park.

Local policies

Your email refers to the need to support projected economic and housing growth in the area, but you do not explain where this growth is expected to take place or how the A259 relates to them.  In fact, one of the main areas of housing and population growth identified in councils’ local plans are in the south of Wealden District and neighbouring parts within Eastbourne Borough.  These development allocations are around the settlements of Polegate, Willingdon, Stone Cross and Westham.  All these areas are close the A27, and are not served by the A259.  Similarly, projected growth at Newhaven will be served by the A26, which directly links it to the A27.  The relevant local plans do not identify the A259 as a hindrance to development or advocate increasing its capacity.  We therefore strongly disagree your assumption that “improvements” to the A259 are needed to support growth.

The study needs to be assessed against the policies of the South Downs Local Plan.  The Local Plan has been prepared in the context of the statutory purposes of the national park and adopts a landscape-led approach.  Improvements to the A259 involving widening are likely to require planning permission and would need to be considered according to its policies.

  • Policy SD1 ‘Sustainable Development’ states that “Planning permission will be refused where development proposals fail to conserve the landscape, natural beauty, wildlife and cultural heritage of the National Park unless, exceptionally: a) The benefits of the proposal demonstrably outweigh the great weight to be attached to those interests.”
  • Widening and similar proposals are also likely to fall within the definition of major development and so would need to be considered against policy SD3, which states that permission for major development should be refused unless certain considerations are met; we consider that works to increase road capacity would fail to meet these considerations. 
  • Policy SD19 ‘Transport and Accessibility’ states that improvements to transport infrastructure will be supported in certain limited cases, but these would not include significant capacity increases. 
  • Policy SD42 ‘Infrastructure’ states that “Development proposals for new, improved or supporting infrastructure will only be permitted where: a) It represents the least environmentally harmful option reasonably available … and b) the design minimises the impact on the natural beauty, wildlife and cultural heritage of the National Park and the general amenity of local communities. ‘ Road capacity increases would not meet these criteria.

Noise, air quality and the impact of lighting on dark skies are also issues that may need consideration against local plan policies.

The South Downs Partnership Management Plan 2020-2025 contains the following statements relevant to the A259 study:

  • “We must change the way we travel and live.  There is an urgent need to decarbonise transport … in ways that are appropriate in these special landscapes.”  (p 12)
  • “National infrastructure schemes must take far better account of protected landscapes.  There are an increasing number of proposals for new national infrastructure, including road and rail schemes … that could cut through the National Park.  Solutions must be found to avoid or reduce the impact of such schemes and to achieve net gain for the environment.”  (p 15)

Sussex Heritage Coast : a strategy and action plan 2016-20

Between Seaford and Eastbourne the A259 forms the northern boundary of the Sussex Heritage Coast.  In recognition of its outstanding quality this was the first heritage coast in England to be defined.  The south-east has the lowest proportion of heritage coast in England, so this stretch is especially valuable.  Sussex Heritage Coast: a strategy and action plan 2016-20 states (in section 3) that;

‘There will be a need to consider key access routes such as the A259.  There is also a need to assess any road scheme proposals against enhancement of landscape (e.g. pressure for … A259 road improvements).  Measures to support and enable sustainable transport options need to be seriously considered.’

Increased capacity and traffic volumes would not be appropriate for a road within a heritage coast. 

CPRE’s The Impact of Road Projects in England (2017)

There is evidence that road schemes justified on the basis of reduced journey times fail to deliver the promised economic benefit. The 2017 report commissioned by the CPRE concluded that:

‘a major change to national policy is called for, involving a move away from large-scale road building. The evidence of the last 20 years suggests that:

  • Any benefits of road schemes in terms of congestion relief are short-lived;
  • Road schemes cause permanent environmental damage;
  • The evidence that they deliver economic benefits is lacking.’

A link to this document is offered here. https://www.cpre.org.uk/resources/transport/roads/item/4542-the-impact-of-road-projects-in-england

Campaign for Better Transport – Rising to the Challenge, A shared green vision for RIS2

This document provides good practice and also cites the South Downs National Park as a case study.  It offers so much useful information that it is hard to single out anything for inclusion. The impacts on landscape, heritage, air quality etc are all considered with valuable input on solutions and even the availability of grants for works.

Conclusions and way forward

We consider that the level of traffic on the A259 to be significantly determined by its capacity.  Because the A259 runs parallel to the A27 any increase in its capacity will lead to traffic reallocating from the A27, negating any perceived benefits.  This is likely to include long-distance journeys which are wholly inappropriate on this road.  It would lead to a cycle of rising congestion causing new bottlenecks to develop, leading to pressure for yet more widening.  It would also attract rat-running traffic onto country lanes connecting to the A259, such as those through Rodmell, Alfriston, Litlington and Jevington. It would increase traffic through the coastal towns to their detriment.

The Department for Transport’s Major Road Network was introduced in 2018 with minimal consultation. The identification of roads for inclusion in the MRN was based largely on the volume of traffic they carry, especially HGVs.  Selection took very limited account of other important considerations, including the strategic allocation of traffic, duplication with other arteries, or impact on the environment, particularly special landscapes such as national parks and heritage coasts.  The MRN also includes local and congested roads, such as those through Eastbourne and Seaford town centres and along Brighton seafront.  ESCC should advocate the removal of the A259 from the MRN, at least the section through the national park.  Indeed, we consider this stretch should be downgraded to a B road.

The study should be revised to instead examine how the A259 can be altered to make it function in a manner more suitable to its location in the national park and heritage coast.  This study should take account of the policy documents referred to above, as well as the DfT’s Manual for Streets 2, Gear Change, a bold vision for cycling and walking and the Campaign for Better Transport’s Tourism Without Traffic: a good practice guide.

The area of the national park and heritage coast through which the A259 is very popular with walkers and horse riders.  Numerous public footpaths and bridleways cross and run alongside the road, including the South Downs Way, Vanguard Way and the new England Coast Path.  Bordering the road there are very large areas of open access land, where the public have the right to roam.  These are in the Seven Sisters Country Park, the National Trust’s extensive land holdings at Crowlink, Gayles Farm and in the Cuckmere valley, the Forestry Commission’s Friston Forest, Eastbourne Council-owned open downland and Brighton Council-owned downland at Rottingdean.  Walkers and riders using these paths and areas suffer badly from severance and environmental intrusion caused by the A259.  Much of the route is at the national speed limit, which is too high for a road of this kind and causes difficulty and danger to walkers and riders.

The number 12 bus route along the A259 provides a frequent service for those visiting the national park from settlements between Brighton and Eastbourne.  However, bus stops are in need of improvement and alighting passengers must contend with crossing the busy road.

National Cycle Route 2 runs along the A259 between Exceat and Seaford, but road conditions are hostile to cyclists.  Increasing traffic volumes would further worsen conditions for cycling.

Because the A259 follows an elevated route across hills and along ridges, its traffic causes noise and visual intrusion over a wide surrounding area, to the detriment of the amenities of the national park and heritage coast.

Pollution from heavy traffic on the road is damaging to the environment and wildlife.  There are several sites of special scientific interest and nature reserves adjoining and near the road which are adversely affected by fumes and noise.

The Seven Sisters Country Park is estimated to attract around one million visitors per annum.  Many of these arrive by bus.  While the country park lies mainly south of the A259, the visitor centre is on the north side of the road.  This creates a very poor setting for the visitor centre, and difficult and dangerous conditions for the huge numbers of visitors crossing the road.

In conclusion, the Friends of the South Downs consider that any intention to increase capacity on the A259 is entirely inappropriate and the study should instead focus on remedying current problems and providing improvements for cyclists, pedestrians and public transport users.

Upgrading the A259 has the potential to damage the inherent value of the South Downs.

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Pondtail Wood Albourne–SAVED!

Triumph after tragedy! You may remember about 5 years ago a new owner of Pondtail Wood in Albourne created a local controversy. Without appropriate permission, he created a new access track from the highway and clear felled a large area of this ancient woodland, dumping a large amount of building material in the cleared area. What an eyesore it was! Residents of Hurstpierpoint, Sayers Common, Poynings and Albourne, amongst others, were all closely involved in creating the action group that saved Pondtail Wood.

The Save Pondtail Wood Facebook page gives further details of both the destruction and campaign which also involved the Sussex Wildlife Trust

It proved very difficult for various technical reasons to put a stop to the illegal activity, but eventually the South Downs National Park Authority were successful through their enforcement team. The wood is in a “bubble” pushing out from the National Park and is some way from the Downs. Together with the Shaves Wood to the north, it hosts some rare butterfly species.

The wood was put up for sale by auction but needed urgent and very expensive remedial work. After 700 tons of illegally dumped waste were cleared, recovery commenced, which included planting 2000 new trees. Pondtail Wood is now in the safe hands of a local family who regard themselves as custodians of this wonderful part of the South Downs National Park. They have overseen the replanting and regrowth of the five acres, lost to illegal felling and the woodland has begun to recover beautifully.

Despite the terrible damage caused by the trucks and excavators, bluebells have started  once again to carpet the woodland and vast quantities of life have returned to the ponds and streams that had once been filled with tree stumps and rubble.

As well as visiting Canada Geese, a family of ducks now occupy the pond island and traditional native bred pigs nuzzle through the woodland floor. It has been a wonderful example of how with a little help, Mother Nature can fix even the worst damage caused by humans.

Works continue at the site and there are plans to install a borehole to help water the trees through the summer months (not needed this year!)

It is hoped in future to open the woods in future to anyone wanting to learn more about woodland craft and forest management. The wood is on the B2117 Muddles Wood road in Albourne more or less opposite Singing Hills Golf Club, before you reach Poynings Crossways coming from the east.

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National Parks and the Climate Emergency

The Campaign for National Parks, of which we are a member, produced a report in June entitled National Parks and the Climate Emergency. It starts with the premise that the climate crisis is the biggest global threat we’ve ever faced and sets out to examine what the National Park Authorities (NPAs) are currently doing and to identify further actions that they, Government and other stakeholders need to take.

Eastbourne Downs from Windover – photo by Richard Reed

There are 10 national parks in England, covering almost 10% of the country and three in Wales accounting for 20% of the country. In the Foreword, the CNP Chair, Janette Ward, declares: “With this report we want decision makers to understand the importance of ensuring our National Parks are fully equipped to combat climate change and contribute to achieving national and global targets for carbon reduction.”

The Report observes that “Many NPAs have now developed specific Climate Change Adaptation and Mitigation Strategies and are undertaking detailed studies to better understand the impacts on their Park”. The SDNPA have done just that. In March 2020, they adopted a Climate Change Strategy and Action Plan confirming a “commitment to address the climate and nature emergency” by:

  • Committing to the SDNPA becoming a ‘Net-Zero’ Organisation by 2030
  • Agreeing an action plan which includes a commitment to working with our constituent Local Authorities and other partners, in particular communities and landowners, to deliver actions that respond effectively to the climate and nature emergency
  • Committing to working towards the SDNP becoming ‘Net-Zero with Nature’ by 2040

As part of that exercise, the SDNPA produced three principal documents: a Strategy, an Action Plan and a 5-Year Programme.  Climate Change Adaptation Plan and Strategy – South Downs  National Park Authority . They make interesting reading, in particular, the 5-Year Programme. It marks an attempt to actually translate good intentions into positive action and sets targets by which the success or otherwise of the actions can be judged.

In early December 2020, National Parks England published four Delivery Plans defining key targets for the NPAs’ work. One of these was on Climate Leadership. They made a number of specific commitments, one of which was “leading by example, through achieving net zero NPAs by 2030, wherever possible”.  They identified actions to achieve this, including:

  • Securing additional funding to establish a consistent carbon budget baseline for all 10 National Parks
  • Employing a climate change officer in each NPA to coordinate data and lead delivery of the net zero plan
  • Promoting sustainable tourism and demonstrating the benefit of low carbon holiday destinations
  • Better communicating how changes in land use as a result of climate change might affect the landscape character of the National Parks
  • Advocating for changes to national policy that will “provide NPAs with the tools locally to deliver net zero”                          

Interestingly, the SDNPA is not proposing to employ a specific climate change officer as they take the view that it is an expertise that should extend across all their work streams. Having said that, their Landscape and Biodiversity Strategy Lead, Chris Fairbrother, is the convenor for the UK National Parks Climate Change group and helped produce their Delivery Plan on Climate Leadership.

This particular Delivery Plan does come in for some criticism from the CNP Report. The charge is that it is “largely aspirational and does not contain any specific milestones other than the net zero dates”. There is a suggestion that although it declares itself to be “rightly ambitious”, it could be more ambitious. There are more ambitious commitments from elsewhere in the public sector. For example, the York and North Yorkshire Local Industrial Strategy sets out an ambition for the area (which contains two national parks) to be carbon neutral by 2034 and then to become England’s first carbon negative economy by 2040. It will be hard for NPAs to argue that they are at the forefront of tackling the climate emergency unless they can demonstrate that they are at least matching such ambitions.

There is a suggestion too that if they want to demonstrate real leadership, the NPAs need to ask for more powers, responsibilities and resources and for wider changes to national policy in order to support such ambitions. For example, encouraging car-free visitors would be far easier if a national road pricing scheme was introduced and/or local bus services were organised in a way which ensured greater support for rural services.

It is clear that, by themselves, the NPAs can only achieve a limited amount. They own a very small proportion of the land in their respective Parks and they are not the transport authority. That significantly reduces their influence. The Glover Report did propose a pilot scheme for the Lake District NPA to be the strategic transport authority for its area and it is understood that two other NPAs are interested in being included in any such pilot. Thus far, the Government has been very slow to respond to Glover.

The CNP Report does identify good progress made by the NPAs but suggests room for improvement. It also emphasizes that more needs to be done by way of education and that there has to be an appreciation on the part of everyone, but particularly Government, that radical action is required urgently before we can start to tackle the crisis effectively. Please do read it if you have the time.

David Green, Trustee