Please note: The South Downs National Park has now issued a revised draft plan. The current consultation closes on the 21st Nov 2017. See this link for the latest draft: https://www.southdowns.gov.uk/planning/national-park-local-plan/
The South Downs National Park draft local plan sets out proposed policies for the period until 2030. The target for submitting the final plan to the Government is now March 2018.
Here is a list on the revised (Sept 2017) policies: List of polices
Apart from developing polices to control development in the park the plan has to define land allocation for housing. Here are some notes about our area:
NB: the items mentioned below have been updated in the latest plan. For new policies see the links as above.
SD22: Development strategy. Under this item some changes are defined regarding the settlement areas of some villages. Kingston & Rodmell are show on page 320 & 327 respectively and shows a reduction in the settlement boundary. SD23: Housing. The total number of additional home in the park is defined as 4,596. Allocations are made through the park and include: Kingston – 11 and Rodmell 11. NB: Section 9 of the Plan also deals with specific major site allocations for housing and this includes a major site (ref SD-SS03) at Old Malling Farm, Lewes
Proposed additions to SDNP Local Plan – by Cllr Vic Ient
Comments submitted on 19th Oct 2015 Here is a copy of my actual submission: SDNP Local Plan Suggested New Policies Appendix A – V S Ient 19-10-15
Whilst the National Park plan has many laudable policies contained within it such as dark night skies, tranquillity, ecosystems, sustainable development etc, it appears that there is no attempt to tackle some of the current ‘conflicts’ within the countryside. Please take into account these 4 points:
- Shotgun Shooting v Walkers & Cyclists + wildlife & flora & fauna
- The impact of large barns being erected in the landscape
- The impact of major changes to agricultural on prominent open down-land
- The impact of major commercial & housing developments on the edges of the SDNP
Comments as follows:
1. Shotgun Shooting v Walkers & Cyclists + wildlife & flora & fauna
Game shooting with its attendant risks of accidents from shooting near public footpaths and the potential conflict between the progress of the shooters and beaters across downland pathways and those out for a pleasant cycle ride or walk in the countryside have not been recognised in the proposed plan.
The growing commercial businesses of game shooting conflicts with those who wish to enjoy the countryside using the South Downs Way, the many footpath and bridleways that criss-cross the Downs and the ‘Open Access’ land designations [see: The Countryside and Rights of Way Act 2000 ( CROW Act)].
The game shooting business has grown significantly over the last 10 years. On the South Downs we have been moving from small parties ‘rough shooting’ to a major business operating on a significant scale. To give you an idea of the scale Shooting UK magazine admits that nearly 35 million gamebirds are released each year, (the RSPCA have published an estimate of 27.9 million pheasants and 7.5 million partridges). Both figure are dated 2015.
With the growth of these businesses across the Downs I believe the SDNP should adopt a policy which attempts to minimise the conflict. For example it could include:
Actively encourage all ‘Shoots’ to:
- Adopt The Code of Good Shooting Practice (see http://www.countryside-alliance.org/ca/file/COGSP_2012.pdf )
- Adopt the Shotgun Safety Code (see http://basc.org.uk/cop/shotgun-safety-code-of-practice/ )
- Publicise the methods by which they will operate safely when in proximity to public footpaths, bridleways and the South Downs Way.
- Minimise their activities on ‘open access’ land.
- Ensure that they do not obstruct public footpaths, bridleways and the South Downs Way at any time.
- Avoid shooting on nature reserves and other special nature areas including SSSIs.
- Undertake measures to protect other farms and small holdings which might suffer from an influx of pheasants and gamebirds during the season.
- Undertake measures to deal with the growing rat population which develops because of feeders being placed on the Downs. Villagers in nearby areas suffer with influx of rats when the shooting season finishes and the feeders are no longer topped up with feedstuffs.
Shooting, is normally organised into local shooting groups called “the XYZ or ABC shoot” etc. These are loosely tied to a farm or an area. For instance in my local area on the Downs there are 4:
- Above Piddinghoe, Hoddern Shoot, see http://www.shooting4all.com/featured-shoots/the-hoddern-shoot
- Above Iford & Rodmell Iford Down Shoot, see http://www.iforddownsshoot.co.uk/location.html
- Above Swanborough & Kingston, Swanborough Shoot
- Near Falmer, Houndean Shoot
The areas these businesses operate is approximately shown as below:
NB: The areas of Open Access land are shaded in yellow. CROW land as designated by the Countryside Act 2000. The dotted and dashed red lines are public footpaths and bridleways. The red/black line is the South Downs Way. See OS maps for more detail.
click on image to enlarge
A “shoot” consists of quite a number of people including – the shooters (normally 8 the people with the shotguns), those who reload the guns, beaters, ‘marshals’, drivers and their vehicles.
These groups criss-cross the Downs taking up positions at different points where beaters flush the birds out from the bushes and ‘cover crops’ so that the shooters can shoot them.
In order for this business to operate birds (often pheasants) have to be released in their thousands into the countryside from September each year to provide something for the people to shoot at.
Across the Downs ‘release pens’ are situated where the young birds (which have been reared in cages over seven weeks) are placed where they finish growing and gain flight and move out of the pen. In addition to the pens other items are necessary to be placed on the Downs for shooting to be carried out. These include release pens and feeder trays:
Example of a release pen:
Above – example of a feeder
These release pens and feeder trays have to be positioned on the Downs in the area where the shooting is to be carried out. Both of these constructions have to be supplied with feed and water through the course of the shooting season from September to 1 February each year. Vehicles and trailers are used to transport the feed to the sites which only adds to the amount of traffic and movement criss-crossing the Downs in addition to the agricultural activities which one would normally expect to find.
2. The impact of large barns being erected in the landscape
Over the years farming has changed and it’s now quite common for farms to concentrate the husbandry of animals and the storing of grain and equipment in central locations rather than dispersed throughout the farm. This has led to the construction of ever larger barns in the countryside. Barns over a certain size require planning permission.
It appears that the current draft plan policies does not include any measures to try and ameliorate the visual impact of such barns on the countryside.
The SDNP should:
- Adopt a policy which positively encourages materials and roof treatment to minimise the impact on the visual landscape.
- Give particular consideration to the impact on traffic that large barn developments may have on the connecting rural road network. Access via villages should be discouraged.
Here is a photograph of a set of barns which were given permission by the SDNPA in 2012 at Iford:
View from the South Downs Way – taken in Feb 2014 (click for larger image)
3. The impact of major changes to agricultural on prominent open down-land
Since the formation of the South Downs National Park there have been some major changes to the landscape under the umbrella term of ‘agriculture.’ One such example is the development of a pig farm above Steyning and the Adur valley on the route of the South Downs Way(see photos & map at the end of this section.
The SDNP should:
- Adopt a policy which positively discourages the building of farm structures on the Downs.
- Where structures exist a policy should be adopted to strongly encourage landscaping of the roofs to lessen their visual impact.
Prior to 2012 this landscape was downland grazing and pasture. Now looks like this:
This map below shows the relationship with the surrounding area (click for larger image):
As you will see the South Downs Way is surrounded by the piggery.
Yellow areas are Open Access land. Purple area are defined as: ‘Priority Habitat Inventory – Good quality semi-improved grassland.’ Please note: the piggery boundary changes from time to time.
4. The impact of major commercial & housing developments on the edges of the SDNP
There is considerable pressure on local authorities to allocate land for housing. No doubt the government has the increasing population figures in mind when setting targets for local authorities. Luckily within the National Park the housing targets are much lower. That said there are still problems for the National Park to consider in some areas where development occurs just outside Park. One example is in the east at Newhaven. This town and much of the coastal area towards Brighton is not within the National Park. It is clear that the Newhaven area is already a target for significant increases in housing development. In addition there are commercial pressures to allow development to help the UK economy. Newhaven has examples of new commercial development including the University Technical College and significant expansion of the Newhaven Port areas (planning permission given in the summer 2015).
The housing development stems from the needs already identified by the government. The commercial developments stem from the need to support our economy. All very positive you might say but these developments partly face towards the National Park as one can see from the map below:
New housing development in Newhaven and Peacehaven will inevitably bring more traffic onto the roadway system. The A259 towards Brighton is already congested. The A259 travelling east takes less traffic but does lead to congestion points within the National Park at Alfriston (with its narrow historical street) and at Cuckmere where the 8259 crosses the river. Travelling north Newhaven benefits from the A26 trunk road. There is also the C7 winding country lane leading north. Luckily Newhaven has a railway line connecting to London and the international airport Gatwick.
The National Park should work with other authorities to minimise the traffic impact through the National Park on the minor C7 road leading North and through the Park to the east leading to Alfriston and Cuckmere. Also it should develop ways of restricting traffic which attempts to travel north east through the village of Telscombe. Linked with this it should work with these authorities to encourage the use of the railway connection for both passenger and commercial traffic. Accordingly the National Park should adopt policies along these lines:
The SDNP should:
- Adopt a policy which positively discourages all forms of traffic to use the C7 and the route via Alfriston as through routes.
- Adopt a policy which seeks to gain funding and improvements to encourage traffic to travel through the National Park via their main A26 trunk road. The National Park should work with Highways England and the ESCC to improve signage and junctions to help traffic exit Newhaven via the A26
- Adopt a policy which strongly encourages the use of the railway network for passenger and commercial traffic. Newhaven benefits from rail network which runs adjacent to the port. There are opportunities here to encourage freight to be transferred directly to rail for transporting around the UK and for freight from anywhere in the UK to be transferred to the ferry terminal for transport to the continent and the EU market.
- Adopt a policy which seeks to encourage public transport using the rail and bus network for passengers. There should be positive action to encourage students and employees using the new University Technical College to travel to and from Newhaven via the railway and bus network.