Report to the Secretary of State for Environment, Food and Rural Affairs
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The Planning Report to the Secretary of State Inspectorate Temple Quay House 2 The Square for Environment, Food and Temple Quay Bristol BS1 6PN Rural Affairs GTN 1371 8000 by Robert Neil Parry BA DIPTP MRTPI An Inspector appointed by the Secretary of State for Environment, Date: Food and Rural Affairs 31 March 2006 THE SOUTH DOWNS NATIONAL PARK INSPECTOR’S REPORT Volume 1 Inquiry held between 10 November 2003 and 18 March 2005 Inquiry held at The Chatsworth Hotel, Steyne, Worthing, BN11 3DU SOUTH DOWNS NATIONAL PARK VOLUME 1 1. Covering letter to Secretary of State 2. Part 1: In-Principle Report 3. Part 2: Boundary Report 4. Annex A: Landscape Assessor’s main report 5. Annex B: Landscape Assessor’s supplementary report on A3 corridor/Rother Valley 6. Annex C: Governance VOLUME 2 Appendix 1: List of persons appearing at the Inquiry Appendix 2: List of Core Documents/Inquiry Documents Appendix 3: List of Countryside Agency Responses (CARS) Appendix 4: List of Proofs/further statements Appendix 5: List of written representations Appendix 6: List of representations in numeric order. VOLUME 3 1. Maps 1A and 1B showing generalised boundary for a more focussed National Park. 2. Key to A4 Boundary Maps. 3. Bundle of designation order boundary maps including recommended changes. Temple Quay House 2 The Square Temple Quay Bristol BS2 9DJ To the Right Honourable Margaret Becket MP Secretary of State for the Environment, Food and Rural Affairs Madam South Downs National Park (Designation) Order 2002 East Hampshire Area of Outstanding Natural Beauty (Revocation) Order 2002 Sussex Downs Area of Outstanding Natural Beauty (Revocation) Order 2002 South Downs National Park (Variation) Order 2004 The attached reports - Part 1 “In-principle Report” and Part 2 “Boundary Report” - relate to the inquiry into the above orders that I conducted at the Chatsworth Hotel, Worthing. I was assisted at the inquiry by Nigel Buchan MA MLI who acted as Landscape Assessor. The inquiry sat for over 90 days between 10 November 2003 and 14 December 2004 and eventually closed on 18 March 2005. In addition to the inquiry sessions, the Assessor and myself spent well over 50 days during and after the inquiry visiting locations within and beyond the boundary of the proposed South Downs National Park (PSDNP). These visits were normally unaccompanied but when requested they were undertaken in the company of inquiry participants and other interested parties. The attached reports take account of the volume of evidence put forward at the inquiry together with all of the written representations; those supporting the creation of a new National Park as well as those opposed “in-principle” or opposed to the boundary shown in the designation order/variation order. In total almost 6000 objections were lodged when the designation order and related orders were placed on deposit. Even this high figure understates the volume of representations insofar as many of the boundary objections refer to more than one area or parcel of land, and in some instances to a large number of parcels. The attached reports address all of the areas of land identified by objectors. In the interests of brevity I normally set out the relevant material as follows. Firstly, I set out the gist of the case made by objectors, then the Agency’s response and, where necessary, any supporting representations. I follow this with my conclusions and recommendations. I do not normally identify objectors or supporters by name. Attached to the reports are 3 annexes; annex A is the Landscape Assessor’s main report, annex B is a supplementary report that looks in detail at the Rother Valley and the A3 corridor. Annex C is my report on the governance of any new National Park. In addition I attach a number of appendices listing inquiry appearances and relevant inquiry documents. The terms of reference for the inquiry were: (i) Does the area as a whole enclosed within the proposed boundary meet the criteria and purposes of designation as a National Park set out in the National Parks and Access to the Countryside Act 1949? (ii) Should the boundary be altered to include or exclude any areas specifically referred to by objectors to the Order (and the Arundel Variation Order), bearing in mind the criteria and purposes of designation? (iii) Is it justified to revoke all of the land in the East Hampshire AONB and the Sussex Downs AONB. (iv) Is a National Park Authority (NPA) appropriate to the South Downs and, if so, how might it best be established and operate? The Part 1 report considers whether there is an extensive tract of land in the South Downs that meets the criteria and purposes of designation as a National Park – essentially issue (i). The Inspector’s report following the earlier New Forest National Park dealt with this issue in one short paragraph - para.1.221 - in the virtual absence of any claims that the statutory criteria were not satisfied. In the South Downs there is no such consensus. Many objectors argue that the proposed National Park does not satisfy the statutory criteria and purposes of designation and that it would be significantly different from the existing members of the National Park family. Key differences identified by objectors include the large resident population, the inclusion of several sizeable settlements, the relatively high proportion of arable farmland and a reliance on the rights of way network rather than “open access” land to provide superior recreational experiences. I conclude, nevertheless, that the proposed new National Park contains extensive tracts of land that merit National Park status and deserve the additional status, resources and integrated management that a National Park Authority (NPA) can provide. The attached Part 2 report then considers the possible extent of any new South Downs National Park – essentially issues (ii) and (iii). Before considering the detailed boundary objections, the report addresses a number of more general matters. One matter is of especial importance. Many objectors argue that if there is to be a new South Downs National Park it should not include non-chalk landscapes such as the Weald. In his report the Landscape Assessor considers this argument and concludes that such areas should be omitted from any new South Downs National Park. His conclusions on this point are reinforced by doubts concerning the intrinsic landscape quality of some of the land in question. I concur with his recommendation that if there is to be a new National Park in this part of the country, it should be more closely focussed on the chalk hills that extend from Winchester as far east as Eastbourne. It is widely accepted that these hills contain the chalk landscapes that form the core or essence of the proposed new National Park. If that recommendation is accepted, a significant amount of the designation order land would be excluded from the PSDNP. Unfortunately none of those who argue generally for the exclusion of non-chalk landscapes identify an alternative boundary that would meet this point. Additional work therefore needs to be undertaken to identify an alternative more focussed boundary. In effect, a new boundary needs to be identified to replace the designation order boundary from section E through to section H. To assist any such exercise I have prepared a plan (Volume 3, plan1) to illustrate the general extent of a new National Park more closely focussed on the core chalk landscapes. I am conscious, however, that my recommendation on this matter may not be accepted. Accordingly, I have separately addressed all of the objections that relate to the designation order boundary between sections E and H. In these and other sections, I occasionally recommend an amendment to the boundary. This is often a consequence of my appraisal of detailed material submitted in writing or at the inquiry, material that was not always to-hand when the Agency made its boundary decisions. Confirmation of the East Hampshire AONB (Revocation) Order and the Sussex Downs AONB (Revocation) Order is clearly inappropriate if my recommendation regarding the exclusion of non-chalk landscapes is accepted. To do otherwise would leave large areas of attractive Wealden countryside without a protective landscape designation. On the other hand, if my recommendation is not accepted, it would seem appropriate to confirm the Revocation Orders as and when the (amended) Designation Order is confirmed. I say that even though there are widespread concerns regarding the long term future of the many small parcels of land that currently enjoy AONB status but would not be part of any new National Park. My recommendations regarding non-chalk landscapes (and the inclusion of several large settlements) have significant implications for the governance of any new National Park – essentially issue (iv). In particular, if my recommendations on these matters are accepted I am not convinced that an in-coming National Park Authority needs to agree a development control delegation agreement with the constituent local authorities. If my recommendations on these matters are not accepted, however, some form of delegation agreement seems inevitable given the likely scale of the development control caseload. CD22 is a written description of the National Park boundary as proposed by the Countryside Agency. At the inquiry I was informed that the written description is itself based on the designation order plans (CD12), the latter taking precedence in the event of any inconsistency or dispute. Because of the uncertainty regarding the general extent of any South Downs National Park and its detailed definition, I do not provide a written description of the boundary. As and when a boundary is defined, the preparation of a new written description should be a relatively straightforward exercise.