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Society pledges public support for the National Park Authority

National Park Friends Group pledges support for Park Authority in controversial move.

At its meeting on 3 July the South Downs National Park Authority was promised the full and continuing support of its “Friends” organisation, the South Downs Society.

Addressing the meeting, the Society’s policy officer Steve Ankers, said “The Authority has taken a controversial step in seeking judicial review of the process by which Highways England identified its preferred option for the A27 Arundel bypass. This may not have gone down well with everyone but this Society unhesitatingly supports the Authority. Along with many other organisations, we campaigned for many years for a powerful, well-resourced body dedicated to conserving and enhancing the very special qualities of the South Downs and we are delighted to see it make this stand.” READ MORE…

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Shaping the future of England’s strategic roads

The government’s agency for planning and maintaining the trunk road network, Highways England, has been consulting on its plans for future investment. The Campaign for National Parks (CNP), which works closely with all the national park “Friends” groups, has submitted the following response to the consultation, which is fully endorsed by the Society. 

February 2018

1. The Campaign for National Parks is the independent national voice for the 13
National Parks in England and Wales. Our mission is to inspire everyone to enjoy
and look after National Parks – the nation’s green treasures. We have been
campaigning for over 80 years to ensure that our National Parks are beautiful,
inspirational places that are relevant, valued and protected for all.

2. National Parks are our finest landscapes with the highest level of protection. They
contribute significantly to the well-being of the nation, by providing safe, attractive,
healthy places for recreation. They also deliver key environmental resources and
services, like water provision and carbon storage in peat soils and forests, which can
mitigate the effects of climate change. As well as being inspiring places for people to
enjoy and improve their health and well-being, National Parks make a significant
contribution to the economy through tourism, farming, and other related businesses.
The English National Parks currently attract 94 million visitors a year, who spend
more than £5 billion and support 75,000 full time equivalent tourism related jobs.

3. All of the English National Parks are affected to some extent by the strategic road
network (SRN) and several have significant lengths of this network within or close to
their boundaries. It is therefore essential that the plans for RIS2 take full account of
the additional planning protection that applies in National Parks. We are very
concerned at the potential for RIS2 to include road schemes which could be
extremely damaging for National Parks, undermining their special qualities and
putting at risk the significant economic benefits that these areas provide. There is
evidence that road schemes justified on the basis of reduced journey times fail to
deliver the promised economic benefits2 and such schemes would be particularly
damaging in areas such as National Parks where the economy is heavily dependent
on a high quality environment.

4. We are particularly concerned at the threat posed to the Peak District National Park
by the revised Trans-Pennine Tunnel study and proposals for major upgrades to the
A628. The decision to shorten the length of the proposed tunnel means that most of
the upgraded route would be above ground through the National Park, or adjacent to
its boundary and within the setting of the Park. While we do not yet know exactly
what is planned for the A628, it appears from the information about expressways in
the SRN Initial Report that the plan is to upgrade the road to motorway standard.
Such extensive road-building is completely inappropriate in a National Park.

5. There is a long-established presumption against significant road widening or the
building of new roads in National Parks. This is clearly set out in paragraph 5.152 of
the National Policy Statement for National Networks3 published in 2014, which 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, the
Broads and Areas of Outstanding Natural Beauty, 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 Broads and Areas of
Outstanding Natural Beauty.”

6. In addition, paragraphs 5.150 and 5.151 of the National Policy Statement for National
Networks reiterate the more general presumption against major development in
National Parks, which is also set out in paragraphs 115 and 116 of the National
Planning Policy Framework. The Government emphasised the additional planning
protection for National Parks in the recent 25 Year Environment Plan (p57)
alongside strong support for greater enhancement of our landscapes.

7. Furthermore, Highways England also has a duty to take account of the potential
effect of its decisions and activities on National Park purposes, including activities
undertaken outside National Park boundaries which may affect land within them.

National Parks’ statutory purposes as set out in the Environment Act 1995 are:
 to conserve and enhance natural beauty, wildlife and cultural heritage; and
 to promote opportunities for public enjoyment and understanding of their special
qualities.

8. This means that Highways England should be seeking to conserve and enhance
National Parks through all of its activities. High volumes of traffic already have a
negative impact on the tranquillity and natural environment in some parts of our
National Parks. It is completely inappropriate to propose projects which would
increase these negative impacts. Instead Highways England should be
demonstrating how it has fulfilled this duty by placing a much stronger emphasis in
RIS2 on measures to reduce the negative impacts of the SRN on National Parks.
This should include, for example, a commitment to prioritise these areas for
measures which reduce noise and light pollution such as low impact lighting and
noise-reducing road surfacing. Tranquillity and dark skies are two of the special
qualities for which many areas of National Parks are particularly valued.

9. Highways England should also be demonstrating that it takes its responsibilities
towards National Parks seriously by actively managing demand for road capacity on
sections of the SRN which pass through National Parks and instead encouraging the use of routes which avoid these protected areas; and placing a much stronger emphasis on investment, and promotion of, public transport as an alternative to roadbuilding.

10. Unfortunately, our recent experience with proposals for the SRN in other National
Parks provides evidence that Highways England does not always take account of the
additional protection afforded these areas. For example, the consultation on the A27
Arundel bypass last autumn only included options which involved unacceptable
damage to the South Downs National Park and failed to take account of alternative
options that would have reduced the impact on the National Park.

11. The consultation document states that one of the key aims of RIS2 is to “make a
positive contribution to the environment”. This will only happen if Highways England
takes its responsibilities towards National Parks seriously. We therefore seek a
reassurance that the strong presumption against significant road widening or the
building of new roads in National Parks will be upheld and that damaging proposals
such as the A628 upgrade will be abandoned.

 

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South Downs Society lobbies for better weekend rail services

Govia Thameslink Railway, which operates the Southern Rail franchise amongst others, is consulting on possible changes to its weekend timetable for 2018. The Society responded to GTR’s earlier consultation on weekday services and has now pressed for more frequent weekend stopping services at Amberley and Southease, two stations in the national park, close to the South Downs Way. At both stations many trains pass through without stopping: with little impact on the overall service it would seem reasonably straightforward  for all trains to stop, encouraging greater use by residents, walkers and other visitors to the national park. Our response appears below:

These are the comments of the South Downs Society, the national park society for the South Downs National Park. The Society has nearly 2,000 members and its focus is the conservation of the special qualities of the national park and its quiet enjoyment. Satisfactory rail access, during the week and at weekends, plays a vital role in enabling local people and visitors to enjoy the national park by means other than the private car. This provision is a key element in this Society’s programme of walks aimed at encouraging enjoyment of the park by more environmentally sustainable means. Other groups, and many individuals– some with, some without access to a car — also rely on rail access, and weekends are a very important part of the week in this respect.

We will focus our comments on the timetables for Southease and Amberley stations, both of which provide ready access to the South Downs Way national trail and other local recreation facilities including the Southease youth hostel and the Amberley Museum. 
Southease
 
The service on this line on both Saturday and Sunday is half hourly but only alternate trains stop at Southease, providing an hourly service.  If all trains stopped at Southease, providing a half hourly service, this would surely create no significant issues for the overall service but be a boon for walkers.
Amberley
 
The same remarks apply to the Saturday service at Amberley. If all trains on this line stopped at Amberley there would be a half hourly service, of much benefit to local residents, walkers and other visitors.
We trust you will afford suitable weight to these comments.
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National Park Society gives two and a half cheers for South Downs Local Plan

The South Downs Society has actively engaged at each stage of preparation of the new local plan for the South Downs National Park. We have met with park authority staff at each stage, submitted comments on its general principles as well as specific land use allocations and development management policies, and believe our voice has been heard.

While most local plans are dominated by the need to find locations for new housing, this plan is “landscape led”. It seeks to ensure that, while sites can be found for affordable housing to meet local needs, strong limits are placed on housing numbers.

The draft plan contains 96 policies. We have looked carefully at every one, commented on most and suggested some that aren’t there. We believe the overall approach deserves our support — there will undoubtedly be those who will lobby against it — and we have commented robustly where we feel the plan needs improvement.

To read our full response CLICK HERE.

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The Road to Rural Oblivion: A27 Arundel Bypass

Guardian columnist Patrick Barkham recently visited the Arundel area to explore the environmental issues associated with options for a new Arundel bypass. His piece, The Road to Rural Oblivion, appeared in the paper on Tuesday 14 November. Our Policy Officer Steve Ankers took the opportunity to write in response. We’ll let you know if it gets published, text below:

 

Three cheers for Patrick Barkham’s analysis (Notebook, Guardian 14 November) of Highways England’s discredited approach to the trunk road network.

Its public consultation on Arundel bypass ignored the role of public transport and other “greener” transport in providing access to jobs, education, services and the South Downs National Park. Arundel hardly features in the exercise. We were asked to choose which of three bypass options would best take traffic off the existing bypass — with each option ploughing through ancient woodland, wildlife habitats, splendid views, historic settlements, close-knit communities and our newest national park.

The National Park Authority rejected all three options and listed the environmental evidence for their objections. Highways England was honest enough to identify as “adverse/major adverse” the impact of each option on cultural heritage, landscape, nature conservation, geology, soils, road drainage, water resources, people, communities, farming and recreational businesses — and that’s from the organisation charged with building the bypass.

Extensive research into the impact of major new highways is consistent — they lead to increased traffic, contribute nothing to the local economy and do lasting, significant environmental damage.

Arundel residents and national and local organisations like ours have offered real solutions —  junction improvements and a modest, single carriageway road which would reduce congestion, facilitate greener transport and minimise the damage. We cannot afford the waste of cash and the environmental destruction that are integral elements of major highway schemes. Arundel, the South Downs National Park and the country deserve better.

 

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National Park Authority objects to Arundel bypass schemes: press release

At its meeting on 19 October the South Downs National Park Authority resolved to object to Highways England’s three options for a new Arundel bypass because of their significant adverse impact on the national park. The following press release has subsequently been issued jointly by Arundel SCATE (South Coast Alliance on Transport and the Environment) and ABNC (Arundel Bypass Neighbourhood Committee). It quotes the South Downs Society and other organisations.

 

National Park objects to A27 Bypass – Campaigners slam Highways ‘narrow focus’ 

The South Downs National Park Authority has voted to object to all three options for the Arundel A27 Improvements Scheme. All options go through the National Park.  The Authority wants Highways England to do more work on assessing, mitigating and compensating the impacts, as well as alternatives, before it will even rank the options.

Local community and environmental organisation representatives spoke at the full Authority meeting.  Nick Herbert MP claimed that an offline bypass at Arundel should be seen as a “National Park Relief Road”, but other speakers disagreed. “Any traffic diverted from other parts of the Park would still be travelling through the National Park, but faster, more noisily and on a high embankment”, countered Mike Tristram, a member of the Park Partnership and Binsted campaigner.

“This is not a plan for reduced congestion,” added Tony Whitbread of the Sussex Wildlife Trust. “It is a plan for increased traffic, which will spread throughout the National Park. Imagine Midhurst, Petworth, Pulborough and Storrington all with 20 per cent more traffic.”

Steve Ankers spoke for the South Downs Society, the Campaign for National Parks and CPRE Sussex. “Highways England’s recent consultation was fundamentally flawed by its narrow focus on a bypass to take traffic off the existing bypass.  Our focus is on the impact on the National Park, its statutory Purposes and Special Qualities.  We also don’t believe that the options presented will solve Arundel’s traffic and access issues.  We strongly object to all three options on the table.  Our heaviest criticisms are of options 3 and 5A, and we have asked for the ‘New Purple’ variations on option 1 to be taken seriously.”

Mike Tristram agreed.  “Highways England has failed to properly analyse impacts on the Park’s Special Qualities.  Having ‘regard to the Park’s Purposes’ is a legal requirement, but they won’t have this unless they assess the impacts of all options thoroughly before choosing a preferred route. The next stage is too late.”

Kay Wagland, an elected Arundel Town Councillor but speaking as chair of local group Arundel Scate, agreed. “We wholly oppose the offline options 3 and 5A.  Both are highly destructive of communities, irreplaceable species, habitats and features.  They are a huge waste of money, and unlikely to ease congestion in the long run.   We object to Option 1’s dualling, but support its alignment, which matches our preferred single carriageway ‘New Purple’ route.

“We are also concerned about Highways England’s narrow focus and poor quality data, including unreliable traffic figures  and large gaps in environmental data.  The public has not been sufficiently informed. The Department for Transport should allow work on more integrated transport solutions. The A27 needs to be better not bigger.”

Dr Mike Davis from Walberton, a regular walker in Binsted and Tortington, said,  “I cannot accept that option 5A on a high embankment, visible night and day, in such a beautiful setting, pays any regard at all to the Special Qualities of the South Downs National Park. The few minutes saved by option 5A cost over twice as much as those saved by option 1 and cause far worse damage. This degrading of the National Park is not justified.”

Highways England will now be looking at the consultation responses. They have to decide in the light of what they have been told, whether or not they can now recommend a preferred option through the National Park.

 

www.a27arundel.org

www.facebook.com/ArundelSCATE

www.arundelbypass.co.uk

www.facebook.com/arundelbypass

www.twitter.com/arundelbypass

www.arundela27forum.org.uk

For more online information about affected areas see:

www.binsted.org                     www.maves.org.uk              www.facebook.com/mavesarundel

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Arundel bypass: the South Downs National Park Authority response

The SDNPA today, 19 October, considered its response to the Highways England consultation on three options for a new bypass at Arundel.

The Society’s Policy Officer took the opportunity, alongside MP Nick Herbert, Sussex Wildlife Trust and local residents and campaigners, to address the meeting. The text of the Policy Officer’s “speech” is reproduced below. In line with his plea the SDNPA agreed the recommendations of their officers and resolved to object to all three bypass options on the basis of their significant adverse impacts on the national park.

A27 Arundel bypass

I am speaking for the South Downs Society but also on this occasion for CPRE Sussex branch and for the Campaign for National Parks.

I have addressed this Authority and its Planning Committee on many occasions but seldom on an issue of greater importance.

The idea that a bigger, better road will lead to less congestion, more jobs, environmental benefits is out of date and discredited. I speak as someone who headed East Sussex County Council’s environment division for 15 years but also, for a decade, its transport planning, road safety and economic development functions.

Any road scheme which achieves short term reduction in congestion will attract traffic from other routes and from public transport alternatives but will also “induce” additional traffic – in this case adding to congestion at Chichester, Worthing and Lancing along the A27 and adding to pressures for more road building in or close to the national park. If not already familiar with CPRE’s recent extensive study into the effects of major highway schemes I would highly recommend it.

Highways England’s recent consultation was fundamentally flawed by its inevitable restriction to what benefits an improved trunk road might bring. No real consideration of public transport or the traffic and access issues of Arundel or the national park. Just “what kind of bypass to take traffic off the existing bypass?”

Any benefits to through traffic will be limited and short term. The disbenefits to the environment will be long-lasting and will range, in the words of Highways England, from predominantly “moderate adverse” for option 1 to “major adverse” with options 3 and 5A. What a choice you have before you!

The focus of the bodies for whom I speak today is the same as yours, the impact on the national park, its statutory purposes and special qualities. The South Downs Society and CPRE Sussex strongly object to all three options on the table. We are aware that a letter, which I believe you have seen, has been sent by nine national transport and environmental organisations to the Secretary of State for Transport making the same points. We saved our heaviest criticisms for options 3 and 5A and we asked for variations on option 1 – referred to as the “new purple” route and devised by local residents – to be taken seriously.

Your excellent officer’s report recommends you to object to all three options on the basis of significant adverse impacts on the national park. I strongly urge you to take his advice.

 

 

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A27 Arundel bypass

The Society has submitted its formal comments in response to a consultation by Highways England on options for a new bypass on the A27 at Arundel, full text below:

 

These are the comments of the South Downs Society, the national park society for the South Downs National Park.

We would stress at the outset that the current consultation is fundamentally flawed – as with recent consultations at other sections of the A27 – by being restricted to the remit of Highways England to the trunk road network. While some effort has been deployed on linking the proposed works to the wider networks of highways, rights of way and pedestrian and cycling desire lines, the overall transport and traffic issues facing Arundel, its surrounds and the rest of the south coast corridor are not addressed and will inevitably be impacted adversely. The proposals are aimed at bypassing an existing congested bypass to the intended advantage of through traffic, not at contributing to improving access to and from Arundel or the national park.

The consultation material acknowledges but does not adequately address the inevitable element of induced traffic. Whatever option is favoured as an outcome of the current work and consultation, there will be an increase in traffic encouraged to use the A27, adding to the existing problems, including poor air quality, at places like Chichester and Worthing/Lancing (where “solutions” are not imminent) and modal shift from rail to road (contrary to government transport policy). The increased threat to the national park from the growth of traffic along the A27, raising expectations of further road building in or adjacent to the park, and the additional contributions to “greenhouse gases” and climate change, are of great concern.

That said, the Society recognises the congestion issues at Crossbush, particularly for westbound traffic and is not opposed in principle to alleviating those problems provided any measures are compatible with the statutory purposes of national park designation and the duty on Highways England under Section 62 of the Environment Act 1995 to have regard to them.

The Society’s appraisal of the route options will be based chiefly on the potential impact, for good or ill, in both short and long term, on the national park. In particular, the special qualities of the park, identified following extensive public consultation and participation, are at the heart of the planning consideration of any development proposals.

In summary these are:

* Diverse, inspirational landscapes and breathtaking views

* Rich variety of wildlife and habitats

* Tranquil and unspoilt places

* An environment shaped by farming

* Great opportunities for recreation and learning

* Well conserved historical features and rich cultural heritage

* Distinctive towns and villages, with community pride

The South Downs National Park Authority has carried out various assessments of the impact of the scheme options on these special qualities of the national park. In general these provide detailed confirmation of Highways England’s own assessment – that the environmental impact of all three options is substantially adverse. The Society fully endorses these findings.

Option 5A

The Society understands that, following our representations, a revised press release was issued by HE correcting its assertion that option 5A “passes between the national park and ancient woodland”. The route does of course take a route through both the national park and ancient woodland, as well as the village of Binsted.

Unfortunately some respondents to the consultation may be unaware of this glaring inaccuracy and their comments on the environmental impacts may be inadvertently softened accordingly.

Nevertheless, local groups and residents have submitted and published a good deal of information on the wildlife, landscape, community and cultural impacts of this option, sufficient to avoid any belief that this option can be anything other than hugely detrimental to the special qualities of the national park, a national designation and planning imperative that would require a major justification – including lack of more acceptable alternatives – if it were to be pursued. This Society fully endorses these detailed findings.

Indeed, Highways England’s consultation material identifies as “major adverse” in its own Environmental Appraisal the impact of option 5A on cultural heritage, landscape, nature conservation, geology and soils, “materials” and road drainage and the water environment. The EA also identifies a “permanent adverse effect on people, communities, farming and recreational businesses located south of Arundel”. The EA identifies as the only “moderate to slight benefit” the prospect of improvement to air quality due to reduction of congestion at Crossbush and other points along the A27, but qualifies this by acknowledging that there will be a worsening of air quality at other locations. The EA fails to acknowledge the additional contribution to greenhouse gases from the overall increase in traffic along the A27 promoted by the various bypass options, including the additional traffic which will be experienced at the notorious areas of congestion on the Chichester bypass and at Worthing/Lancing as a direct result of improving traffic flow at Arundel.

As an organisation whose focus is the conservation and enhancement of the special qualities of the national park and their quiet enjoyment, the South Downs Society strongly objects to option 5A.

 

Option 3

Option 3 suffers from a similar Environmental Appraisal to option 5A. The EA identifies as “major adverse” the impact of option 3 on cultural heritage, landscape, nature conservation, geology and soils, materials, road drainage and water environment. It identifies as “slight-moderate adverse” the “effect on people, communities, farming and recreational businesses located south of Arundel”. Identified as the only “moderate to slight benefit” is the prospect of improvement to air quality due to reduction of congestion at Crossbush and other points along the A27, but qualifies this by acknowledging that there will be a worsening of air quality at other locations.

As an organisation whose focus is the conservation and enhancement of the special qualities of the national park and their quiet enjoyment, the South Downs Society strongly objects to option 3.

 

Option 1

Option 1 clearly performs much the best in Highways England’s Environmental Appraisal of the route options. The impact on cultural heritage and nature conservation is described as “major adverse” while the impact in the areas of landscape, geology and soils, materials, noise and vibration, people and communities, road drainage and water environment are identified as “slight-moderate adverse”.

Much of the negative environmental impact arising from option 1 stems from the continuation of “improvement” works west from the Ford Road junction and into the national park.

Variations on option 1 have been put forward, in part following the alignment of route 1 but with wide single carriageway rather than double, a modest speed limit of, say, 40 mph and with different junction arrangements at Ford Road, facilitating journeys on foot or bicycle to and from the town centre and the national park. Such measures would appear to be consistent with those recently announced by HE on the A27 between Lewes and Polegate. There was strong public support in advance of the consultation for the inclusion of such variations – generally known as the “new purple route” — amongst the options to be appraised and their omission reduces the value and validity of the current exercise.

Such an option would appear to offer a significant reduction in the current congestion at Crossbush and other points along the road but without the major environmental damage identified for the three options selected. In addition, such an option seems less likely to induce the extra traffic levels that are inevitable from the proposed “expressway” options with all the associated increased congestion at Chichester, Worthing/Lancing and elsewhere, the highly undesirable modal shift from rail to road, and the increase in greenhouse gases and contribution to climate change.

 

Conclusions

The South Downs Society agrees with Highways England’s Environmental Appraisal, that all of the options put forward would be very damaging environmentally, and especially to the South Downs National Park.

The consultation underplays the implications of the induced traffic arising inevitably from the proposals, the inevitably short term nature of any traffic benefits at Arundel as new traffic is encouraged to use this road, and the additional congestion which will be caused at points east and west on the A27.

The Society believes that, on the basis of the evidence so far provided, a Planning Inspector could not reach a conclusion that the tests in Paragraph 116 of the NPPF had been satisfied with regard to any of the options under consideration.

While the Society objects to all three options because of their acknowledged major adverse environmental impact, options 5A and 3 score considerably worse than option 1.

In addition to performing less poorly in environmental terms, we note from the documentation that option 1 provides easily the best benefit to cost ratio.

The Society would urge fuller consideration of what is referred to in the consultation documents as the wide single carriageway “new purple route”. No adequate reasons are provided for rejecting it.

 

 

 

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Major development between Lancing College and Shoreham airport

The Friends of the South Downs not only responds to planning applications within the National Park, we also look out for development proposals on or beyond the park boundary which might have a significant effect on the park’s special qualities. Below is our response to a current application alongside the A27 near Shoreham airport:

Pl app AWDM/0961/17: Demolition of existing buildings, erection of 600 new dwellings, non-food retail store, creation of country park, relocation of travellers’ site, new access to A27, community hub, primary school, landscaping: land west of New Monks Farm, Mash Barn Lane, Lancing

These are the comments of the South Downs Society, the national park society for the South Downs National Park:

READ MORE…

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Save Binsted, Save the National Park

Highways England, responsible for building and maintaining the trunk road network, are consulting on options for a new Arundel bypass. All three of the options now being considered will impact on the national park.  Media coverage has been distorted by errors in Highways England’s press release which referred to one option (“Opion 5A”) passing “between the national park and ancient woodland” when in fact it passes through both the national park and ancient woodland as well as the village of Binsted. HE agreed to change their press release after the Society pointed out the error. The Society and other environmental organisations have supported local residents in their struggle to protect this beautiful part of the national park and its special qualities.

Join us this Sunday 8 October to walk the route of the infamous Option 5A, show your support for the villagers of Binsted and the strength of your feelings for the national park.

The walk begins at 1 pm on Sunday at the Flint Barn, Binsted BN18 0LL

For more information see: http://www.arundelbypass.co.uk