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National Park Society’s mixed reaction to A27 schemes

Highways England is currently consulting on options to improve capacity at junctions on the A27 at Worthing, Lancing and Sompting. The Society has responded as follows:

 

A27 Worthing and Lancing improvements scheme

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, many of whom live or work close to the A27 and use it on a regular basis. The Society’s focus is on conserving and enhancing the special qualities of the national park and their quiet enjoyment.

The Society recognises the issues raised in the consultation, in respect of protracted and unreliable journey times, accident rates and severance, and regrets the difficulties experienced by those seeking access to the national park as well as local residents, visitors and through traffic.

We welcome the clear recognition that “the issue” here is not merely that of enabling through traffic to pass more quickly through the area but also the need to facilitate local movement by those on foot, bike and public transport as well as by car. We also welcome the recognition of the key environmental constraint of the national park and the decision not to include options in the consultation that would involve major engineering within or adjacent to the park. The Society would object most strongly to any move to reintroduce such options, which would in any event be very costly in financial terms and do little to ameliorate the traffic issues identified.

We welcome the recognition of Highways England’s statutory duty to have regard to the purposes of national park designation, including in respect of works planned outside the park, and the undertaking to consult with the South Downs National Park Authority with regard to potential impacts of the scheme options on landscape, tranquillity, dark night skies, biodiversity, recreation and heritage. We believe that options involving online underpasses and flyovers may have a negative visual impact on key viewpoints in the national park and their exclusion from the consultation is welcome.

It is asserted that, owing to the current levels of congestion on A27, some longer distance traffic now diverts onto inappropriate routes, some of which pass through the national park. If the overall effect of the proposed schemes were to reduce total traffic levels within the park, that is broadly to be welcomed. We assume that origin and destination surveys, census and mobile phone data are available to substantiate this potential outcome? While indicating the existence of this displaced traffic, we note that the summary consultation material stops short of claiming that the proposed works will actually reduce it.

To the extent that the options outlined are aimed at increasing capacity at existing junctions, reducing journey times, trip unreliability and accident rates, and improving air quality, the Society is broadly supportive, though we would be keen to see detailed design and landscaping that respected views towards and from national park viewpoints.

The Society fully supports measures aimed at reducing manmade climate change and will object to schemes that are likely to exacerbate it. We note that the measures proposed are expected to increase traffic levels along the A27 while generally reducing levels on roads such as A259 which run parallel to it. But we see little recognition of the overall increase in traffic along the corridor which will be encouraged by the implementation of the proposals and the accompanying modal shift from rail to road which seems an inevitable consequence.

The consultation material claims there is “no evidence to suggest that there will be any significant switch from road to rail along the A27 corridor between Chichester and Brighton.”  The likelihood is surely the opposite if the proposed works take place. There seems little doubt that a speedier passage for through traffic will persuade many current rail passengers to drive – at least until the congestion builds again to its current levels. Moreover, any increase in traffic on the A27, which Highways England forecasts as a consequence of these proposals, will add to traffic levels at other pinch points on the road, particularly at Arundel and Chichester, increasing the pressure for further investment aimed at “solving” the freshly exacerbated problems.

Meanwhile, as the consultation material indicates, there are no current plans to improve rail capacity or performance along the corridor. The lack of integrated transport planning is to be deplored. Rail investment is of course not within the remit of Highways England, rendering this exercise partial at best and, in its cycle of further road investment generating increases in traffic and pressure for further road investment, a poor use of finite resources.

To the extent that the schemes currently envisaged are modest in ambition – though costly in cash terms — the Society accepts that they are likely to achieve some limited improvement for road users in the Worthing/Lancing area in the short term, while serving to exacerbate problems along the corridor. The aspects of the proposals aimed specifically at vulnerable road users, such as toucan crossings and new traffic signals at roundabouts, should benefit local residents and those seeking access to the national park and are to be welcomed.

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“A place to fly in peace”?

Concerned walkers have approached the Society on finding that their quiet walks through the Balsdean valley near Woodingdean have been disturbed by drones flying. The Society took up their complaints with the national park authority which has taken enforcement action. Despite this the activity has continued. The Society has written to the Sussex Express as follows:

It is for good reason that the Balsdean valley between Kingston, Woodingdean and Saltdean has been referred to as the “hidden” or “secret” valley. Those who follow the public footpaths to this special place discover a surprisingly tranquil haven, a rarity so close to centres of population in this precious part of the national park.

Until recently, that is. 
Visit www.hidden-valley.org — “a place to fly in peace” (we’re talking drones here) — and you will find that not everybody has the same ideas about tranquillity. The activities taking place do not have planning permission and those involved have been instructed by the national park authority to cease. The park planners would appreciate any first hand information from walkers, horse riders. cyclists and others who may have experienced the drones in order to take matters forward.

 

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The Society’s response to the Lewes neighbourhood plan

The Society has submitted comments on the draft neighbourhood plan for the town of Lewes as follows:

Lewes Neighbourhood Plan

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

The Society regards the neighbourhood planning process as a key element in setting the statutory planning framework for future decision making. With Lewes being the largest settlement in the national park, a coherent neighbourhood plan is essential for the conservation and enhancement of the special qualities of this part of the national park.

The Society recognises the considerable work that has gone into the preparation of the draft plan, and the efforts made to engage the public in and around the town in the process. The key document produced is attractive and accessible and the Town Council and the plan steering group are to be congratulated.

Plan summary

We welcome the emphasis in this brief summary on low-cost housing, green spaces and the natural environment around the town.

Introductory remarks and vision statement

These are a welcome identification of what makes Lewes “Lewes” – its history, geography, built heritage, creativity and non-conformity. It is right that these characteristics of the town should run through what follows. We endorse the vision statement and supporting text and note in particular such phrases as:

“acknowledging the part that the historic and environmental setting of Lewes has played in shaping our town”

“brownfield sites should be developed to avoid greenfield development especially on downland.”

“wide range of housing and work space options”

“resilient to the effects of local and national climate change”

“improvement of access to the town, particularly for pedestrians in the central area, and the development of routes for walking, cycling and public transport to service outlying areas and to connect with the town centre”

 

The Society welcomes the concept of “Lewes low cost housing” (p.27) and the contribution it can make to providing new housing that is genuinely affordable for Lewes people.

Plan policies

The Society supports all of the draft policies as being appropriate for the special circumstances that obtain in the town. We will not list them here: they seem well thought through and reflect the special qualities of the town “going forward”.

We note with approval draft policy PL2 Architecture and design and the comment (p.84):

“Lewes has a unique position in the South Downs National Park because of its attractive Medieval and Georgian central area and largely unaltered Victorian and Edwardian residential streets. New designs need to take heed of the reason why Lewes was included in the South Downs National Park”

And we note with interest draft policy HC2 (p.42) and its proposal to reconsider the use of the Phoenix iron foundry within the North Street development. As this Society sought consideration of the retention of this element of the Phoenix site in its response to the planning application for North Street, we would support this policy.

We note (p.54) that “during the plan period, Lewes can meet its housing needs within the settlement boundary without recourse to greenfield sites beyond”.

Two key questions arise from this welcome statement:

  • Can sufficient sites be developed from those possibilities outlined in the draft plan to meet the target of 220 dwellings? If some prove undeliverable on practical or physical grounds or as a result of valid objections, will the above statement of intent hold good? This Society regards that intention as imperative.
  • Is the 220 target likely to be affected by current legal uncertainty over proposals elsewhere, in particular at Old Malling Farm? Again, it is imperative for the integrity of the neighbourhood planning process that all of the good work carried out to date is not rendered irrelevant by decisions made elsewhere.

 

Allocated housing sites

This exercise appears to have been carried out with skill and sensitivity. We have studied not only those sites allocated but also those considered and discounted. While other organisations and individual respondents may present valid concerns about specific sites, this Society finds little on which to express concern in terms of meeting national park purposes.

We do however raise a strong query about the Spring Barn Farm site (PL1 50) which would constitute an unwelcome development almost in open countryside and an unhappy incentive to farms and other rural businesses to erect non-residential buildings with the prospect of securing residential value at a later stage.

We also note that a number of sites allocated for housing are currently used for car parking. If these are lost as parking spaces, there will need to be a compensatory and comprehensive approach adopted across the town to rationalise provision. This appears to be recognised in draft policy AM3.

 

Appendix 5: Key views to be protected

This is a welcome appendix to the plan and we are very pleased to see the iconic views identified.

Appendix 6: Contributing organisations

A useful list but could we please be given our correct title of South Downs Society?

 

 

 

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Seven Sisters Country Park: South Downs Society’s plea for safeguarding

East Sussex County Council has carried out extensive public consultations on the future management of its rights of way and countryside sites, including the famous Seven Sisters Country Park. Decisions on their future are scheduled to be made by the Council at a meeting of its Cabinet at the end of June.  In the light of recent moves by both Eastbourne and Brighton and Hove Councils to sell off land in their ownership, the Society has written to each member of the East Sussex Cabinet urging them to guarantee “benign” ownership, ensuring the protection and improvement of the landscape, wildlife, cultural heritage and public enjoyment.

The text of our letter is as follows:

The Society recognises the achievement of the County Council over the years in acquiring and maintaining land for the purposes of countryside recreation over and above its statutory duties with regard to rights of way. We also fully recognise the financial pressures facing the authority which render increasingly difficult the achievement of the highest standards which you would wish to meet.
In the circumstances we have responded positively to your consultation on options for future management and we await with great interest the report due to be considered at your June meeting. As set out in our written response to the consultation, the Society would urge the County Council to:
1. Ensure that the rights of way function is adequately resourced in terms of staff and finance to meet not only its statutory obligations but also the reasonable expectations of its users and other stakeholders
2. Either deploy sufficient resources on a continuing basis on the management of its countryside estate or agree to dispose of its assets to one or more benign owners committed to maintaining and enhancing their landscape, wildlife, cultural heritage and quiet enjoyment. In our response we made particular positive reference to the National Park Authority and National Trust as potential new owners.
The Society, which owes its origins to the benevolent and protective acquisition of coastal downland close to Seven Sisters Country Park, looks forward with great interest to your deliberations and offers its continuing support towards the achievement of the national park objectives of conservation, understanding and enjoyment.
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Eastbourne ends downland sell-off!

The Society has campaigned alongside local residents and other environmental groups against Eastbourne Borough Council’s plans to sell off the bulk of its landholding in the national park. While the planning powers of the National Park Authority would have remained in place, and rights of way would have been protected, there is no substitute for benign ownership if landscape, wildlife, recreation and cultural heritage are to be conserved and enhanced, so there is much to celebrate in the recent decision of the Borough Council to stop the sale. The Society has continually offered to collaborate with the council and others to realise the potential of the landholding and looks forward to engaging in that process.

The South Downs Network of environmental groups active across the national park — of which the Society is an active member and secretariat — has also offered its expertise. Below is the text of the Network’s letter to Eastbourne:

 

14th March 2017

Councillor Tutt       Leader, Eastbourne Borough Council

Dear Councillor Tutt

Following our letter to you (30th January 2017) this is a positive follow-up to thank you for the bold decision you have taken to stop the sale of the Eastbourne downland estate farms. Our network of 40 organisations with environmental interests in the South Downs National Park is relieved that you have come to this conclusion, influenced by the overwhelming feelings of your Eastbourne residents in the recent poll.

We understand the financial difficulties and pressure to deliver public services that you are under, and recognise that this has no easy solutions. However, we strongly believed that selling the downland asset was not the right answer. Now you have stopped the sales you will be looking forward to how best to manage the downland estate and we re-emphasise the offer we made in our previous letter: “we will be more than happy to work with you, in partnership, to maximise the benefits from public land ownership”.

A strong partnership with the South Downs National Park Authority, Water Company, key organisations and local interests can be galvanised here. The estate is an invaluable public asset for the people of Eastbourne, for the local area and visitors from further afield. Your tenant farmers are making a valuable contribution. Their sensitive land management in food-growing helps deliver clean drinking water, wildlife and natural capital, along with its value for cultural heritage, public access, recreation and tourism and increasing the sustainability of the local economy in the face of climate change. With ownership and management in your control, as the publicly-accountable local authority for Eastbourne, much can be achieved.

The range of ecosystem services that the Eastbourne downland generates offers great opportunity, particularly if the UK’s post-Brexit farming policy results in more financial support for the maintenance of such services. Furthermore, your Downland Management Plan provides a useful base to affirm a renewed vision to develop a more comprehensive action plan for the Downs in harmony with local people while also recognising the national significance of this iconic landscape.

Yours sincerely

Dr Tony Whitbread, Chairman, South Downs Network

Cc Mr R Cottrill, Chief Executive, Eastbourne Borough Council

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Stanmer Park

On 8 December the Planning Committee for the national park approved a scheme submitted by the owners of Stanmer, Brighton and Hove City Council, for restoring elements of the park landscape and rearranging the car parking. The Society had welcomed the thrust of the proposals but objected to the large increase in car parking associated with the project.

The Society frequently takes the opportunity to address the committee on proposals on which it has particular concerns or which it wishes to support. In this case we were unsuccessful.

Here is the text of our oral comments to the meeting, from the Society’s Policy Officer:

SDNPA Planning Committee 8 December: Stanmer Park

I’m speaking this morning on behalf of both the South Downs Society and CPRE Sussex.

We believe there is much to welcome in the proposals. Stanmer is a major source of enjoyment and access to the national park. Indeed, living only a few minutes away, I have been a regular visitor to the park, the house and tearoom for many years and know the site well. The city council is to be commended on its efforts to reinvigorate the estate and secure external funding to that end.

We welcome the removal of parking from the access roads and its relocation to the perimeter of the park, provided this can be adequately screened. We agree that the provision of access to the area round the walled garden, the house and the church from any direction other than the entrance gates would be unacceptable.

We acknowledge the need for existing residents and businesses to have vehicle access to their properties, both for themselves and for their customers, and that there will therefore be some continuing traffic through the park. But, and it is a big but, we very much oppose the plan to increase significantly (a net gain of more than 200 spaces) the parking in the very heart of the estate in order to encourage substantial business growth in this inappropriate location – for a third refreshment outlet and for a commercial garden centre. Business growth like this should not be at the expense of conservation and quiet enjoyment.

References in the application to differential pricing between the car parks is misleading: if it were genuinely anticipated that motorists would be discouraged from parking in the centre of the park, there would be no need for such a large increase in numbers of parking spaces and the inevitably associated increase in traffic through the park, in fundamental contradiction to the stated aims of the scheme. It follows that we do not support the new access road between the church and the house or the tree felling programme required for the parking provision.

We would urge you to reject this element of the proposals and seek a more sensitive solution to the issues of traffic and access at Stanmer. The Park has good public transport links and the city council should do more to promote these.

Thank you.

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A better rail service for Cooksbridge?

Govia Thameslink Railway, which includes Southern Rail, is currently carrying out a public consultation on possible timetable revisions (this is for beyond the current strikes!)   The Society has responded to the consultation as follows:

 

During the previous round of consultation this Society, the national park society for the South Downs National Park, requested that the timetable revisions under consideration should recognise the designation of the national park and the statutory duty on public agencies and utilities to have regard to that designation. In particular we pressed for an improved service to Cooksbridge station, providing enhanced access to the downs.

 On page 25 of the current consultation this need is acknowledged and the Society welcomes that recognition.
 
Qu. 35 poses a question in relation to the frequency of services at Plumpton and Cooksbridge. This Society, though regretting any proposed reduction in service at Plumpton would welcome the introduction of a two hourly service throughout the week at Cooksbridge.
 
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The Shale Wealth Fund: compensating local communities

Government is consulting on the creation of a fund to ensure that local communities where shale gas is being extracted (“fracking”) benefit from that activity. The Society has responded to the consultation as follows:

 

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 campaigning for the conservation and enhancement of the special qualities of the national park and their quiet enjoyment. Our comments will reflect this focus.

We note an emphasis in the consultation on the role of shale gas in regional development and the wish (para 1.19) to “rebalance growth across the regions”. The need for such a rebalancing is clearly less in evidence in the south east, unless it is intended to suggest that this region be accordingly afforded lower priority in pressures for exploitation.

We query what is intended by the expression (para 3.3) “shale sites themselves are small, with a lesser visual impact than many other forms of development.”  It is our understanding that the visual impact – as well as aural, disturbance, aerial and subterranean impacts – will be considerable, and significantly greater than for conventional fossil fuel exploitation, owing in part to an increased number and frequency of wellheads.

We address below the consultation questions on which we wish to express a view.

Consultation Question 1: Do you think that providing opportunities for both local and regional investments are the right priorities for the Shale Wealth Fund?

Yes. While residents and others may be affected locally by visual and other impacts and traffic, there may be regional impacts such as effects on aquifers (notwithstanding government assurances) and the tourist economy.

Consultation Question 2: Do you agree that a more local level should receive revenues before a more regional level (establishing the ‘trickle up’ principle)?

No. This may provide an undesirable incentive to some local communities to seek to outweigh any genuine planning and environmental concerns with money or investment. Planning decisions should not be made on those lines. This seems less likely to happen at regional level.

Consultation Question 4: Should the government retain flexibility regarding the proportion of funding between delivering benefits at local and regional levels, to enable learning from the industry pilot schemes and once the magnitude of shale revenues becomes clearer?

Yes.

Consultation Question 5: Do you have views on how the “local community” to a shale site should be defined for the purposes of the Shale Wealth Fund?

The community should be defined to include those likely to be affected by activities associated with extraction, such as lorry movements, as well as those directly affected by a drilling site by living close by.

Consultation Question 6: Do you agree that the “local community” should be defined on a case-by case basis?

Yes.

Consultation Question 7: Do you think a set of principles should be developed to ensure consistency of approach for different shale developments?

Yes.

Consultation Question 9: Do you agree that at a local level, it should be for local people to determine how the Shale Wealth Fund is spent?

While local people should be involved in the decision making, there should be objectives or criteria set for the funding to ensure it is used to compensate for the full range of impacts from fracking, including allocating to projects which improve the natural environment under threat.

Consultation Question 11: At the local level, should expenditure from the Shale Wealth Fund be subject to any ring-fences for a specific purpose? If so, should these be locally or centrally determined, and do you have views on what they should be?

A significant part of any extraction could take place beneath the South Downs National Park despite robust arguments having been made against that. If so, given the national park statutory purposes of conservation, understanding and enjoyment, it would be appropriate not only to compensate local communities but also recreational users of those parts of the park affected by fracking related activities, either beneath, within or close to the park. This would indicate a need for part of the fund within a national park to be ring-fenced to provide environmental enhancements and improved access, preferably to be allocated by the national park authority.

Consultation Question 12: At the local level, would an appropriate use of the Shale Wealth Fund be to make direct payments to households?

No. Other than, say, compensation for subsidence, other physical damage or blight – which should presumably be handled separately – it would be inappropriate for individual householders to be incentivised to overcome any legitimate concerns they may have about the proposed activity in order to unbalance the consideration of proper planning issues.

Consultation Question 14: How can the government ensure that decisions are as directly influenced by local residents as possible?

By affording more scope for local planning authorities (the traditional and democratically accountable mechanism) to consider the full range of potential effects of any proposal including aerial and subterranean impacts; and by discouraging ministers and planning inspectors from overruling the planning decisions made.

Consultation Question 16: What kind of investments do you think should be made from a regional level of the Shale Wealth Fund?

It would be appropriate to include investment in the natural environment and reductions in carbon emissions to compensate for the negative impacts of fracking including climate change.

Consultation Question 17: Do you think a regional level of the Shale Wealth Fund should be administered by direct grants to specific organisations, or through an open bidding process? How can the views of residents across the regions be best taken into account?

We would support an open bidding process, enabling environmental organisations like ourselves, as well as community groups, to apply for funding. If it were decided to allocate funds direct to specific organisations, that should include the national park authorities where they have planning responsibilities for any areas affected by fracking and associated activity.

Consultation Question 18: Do you have views on how a regional level of the Shale Wealth Fund should be governed? Are there existing regional organisations, or local or national governance structures that would be particularly suited to oversight of such a fund?

National park authorities should be responsible for, or at least involved in, the governance of any fund disbursed in a national park.

 

Click on this link for the consultation paper and full list of questions:

https://www.gov.uk/government/uploads/system/uploads/attachment_data/file/544241/shale_wealth_fund_final_pdf-a.pdf

 

 

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A27 Chichester Bypass

Highways England is undertaking a public consultation on options for improving the A27 Chichester Bypass. The Society has submitted the following comments:

These are the views of the South Downs Society in response to the current open consultation on the above. The Society, the national park society for the South Downs National Park, has nearly 2,000 members and its focus is the conservation and enhancement of the special qualities for which the park was designated. Our comments will reflect this focus.

The Society fully recognises the need to address the issues of congestion, unpredictable journey times and accidents on this stretch of the A27 and regards it as essential that any options progressed must have full regard to any implications for current and future traffic levels elsewhere along the road, including Worthing/Lancing and east of Lewes. We very much regret that the current exercise is road-based only and has been divorced from any real consideration of rail and bus transport: we regard this shift from integrated thinking on transport policy to be an unacceptable weakness in the approach.

That said, the Society welcomes the fact that no bypass options passing north of the city and close to the national park have been included in the consultation. If such options were to be resurrected the Society would strongly object.

We believe that any preferred option should be able to demonstrate that it can reduce congestion and unpredictable journey times on the Chichester bypass and bring about a commensurate reduction in traffic displaced by that congestion onto roads within the national park. It is essential that origin and destination survey data, mobile phone data and the results of any traffic modelling are shared with the public in a timely and user-friendly fashion in order to facilitate informed discussion about the potential implications of any changes to the bypass.

It is not this Society’s belief that the aim should be to create a 70 mph expressway. It would be our strong expectation that such a road would induce yet more traffic, increasing its contribution to climate change, potentially encouraging traffic to cross the national park to access it, diverting custom and thus the prospect of investment from the parallel, competing railway, and adding to the obvious traffic problems on the A27 further east.

The Society has attended the exhibitions of the options and taken the opportunity to discuss them with the staff present.

There are clearly local environmental implications attached to each of the options: these will rightly be raised by those directly concerned. As this Society’s remit is the impact on the national park, and much of the impact will be felt on the opposite, southern side of the city, we will restrict ourselves to one or two comments:

  • We note that a positive value, an “economic benefit”, is attached in the scheme evaluation to any reduction in journey time. From discussion with the staff at the exhibition it appears that no consideration has been given to whether a reduced journey time is an unmixed blessing, an absolute benefit: if, for example, car commuting from the south into the city centre may be achieved more quickly, will this not encourage more car traffic and is the city centre geared to accommodating it?
  • Views into the national park are as important as those within, or outwards from, the park. We would oppose the eastern end of the proposed link road forming part of option 2 where it passes beyond the B2201 towards Hunston. It would damage the iconic view of the cathedral and South Downs from the Chichester Canal at Poyntz Bridge, a view made famous in a painting by Turner, as well as destroying the tranquillity of the canal.

 

The consultation runs until 22 September. Here is a link to the Highways England consultation website:

http://www.highways.gov.uk/roads/road-projects/a27-chichester-improvement/

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Major new housing development on the edge of Chichester

The Society has written today, 6 July, to local press in the Chichester area expressing our concerns over a planning application for 750 dwellings on the west side of the city. The text of the letter is as follows:

 

Joined up Planning

It may seem unusual for an environmental organisation like ours, the South Downs Society – the “Friends” group for the South Downs National Park – to focus attention on the need for a new road link but that’s our strong plea in connection with the current planning application for up to 750 houses on the west side of Chichester, described as “West Of Centurion Way And West Of Old Broyle Road”.

We campaigned against the loss of this site for new housing but we lost – it’s now allocated for development. But, if and when Chichester District Council agree a scheme for the site, it shouldn’t be allowed to proceed without a satisfactory highway access, and that’s what is in real danger of happening. The current application seeks permission to access the site from a new roundabout junction with the B2178 Old Broyle Road, with the general intention that at some unspecified time it will be possible to link the development to the A27 to the south. Meanwhile, the traffic generated by the new development will head in a variety of unsatisfactory directions, including through the national park.

The South Downs Society has submitted its objection to the planning application on this basis and we would invite others to join us. The District Council has a duty in law to demonstrate that it is taking the national park into consideration whenever it makes decisions – it must show that awareness now.