Major Development – Proposed Minerals Sites West Sussex Joint Minerals Local Plan Soft Sand Review

Major Development – proposed minerals sites West Sussex Joint Minerals Local Plan Soft Sand Review

November 2019

1. INTRODUCTION

1.1 The purpose of this paper is to provide evidence that the national and local policies on major development in a national park have been fully considered throughout the production of the Soft Sand Review (SSR) of the West Sussex Joint Minerals Local Plan (July 2018). This is necessary in the context of the NPPF, which states in paragraph 172: Great weight should be given to conserving and enhancing landscape and scenic beauty in National Parks, the Broads and Areas of Outstanding Natural Beauty, 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 and the Broads54. The scale and extent of development within these designated areas should be limited. Planning permission should be refused for major development55 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.

54English National Parks and the Broads: UK Government Vision and Circular 2010 provides further guidance and information about their statutory purposes, management and other matters.

55For the purposes of paragraphs 172 and 173, whether a proposal is ‘major development’ is a matter for the decision maker, taking into account its nature, scale and setting, and whether it could have a significant adverse impact on the purposes for which the area has been designated or defined. 1.2 Additional advice is given in Planning Practice Guidance, paragraph 005 Reference ID: 8-005- 20140306. This states: “Planning permission should be refused for major development in a National Park, the Broads or an Area of Outstanding Natural Beauty except in exceptional circumstances and where it can be demonstrated to be in the public interest. Whether a proposed development in these designated areas should be treated as a major development, to which the policy in paragraph 172 of the Framework applies, will be a matter for the relevant decision taker, taking into account the proposal in question and the local context. The Framework is clear that great weight should be given to conserving landscape and scenic beauty in these designated areas irrespective of whether the policy in paragraph 172 is applicable.”

1.3 The South Downs Local Plan (adopted July 2019) (SDLP) is also considered material. The SDLP explains that the NPPF does not define major development. The National Park Authority has

sought legal opinions1 on what constitutes major development. These opinions are that the definition of “major development” is based on whether, prima facie, the development might potentially have adverse impacts on a national park, rather than whether, after a careful and close assessment, it will have such adverse impacts.

1.4 As such, it is necessary at the plan-making stage to consider whether sites shortlisted for possible selection have the potential for adverse impacts on the South Downs National Park due to their scale, character or nature and are therefore considered to be major development in the National Park for the purposes of plan-making. The consequence of failing to do so would be to risk allocating land for major development that was undeliverable in a National Park because it was contrary to both paragraph 172 of the NPPF2 and Policy SD2 of the South Downs Local Plan. The major development test will also apply at the planning application stage, as set out in paragraph 172 of the NPPF and in Planning Practice Guidance, as set out in paragraphs 1.1 and 1.2 above.

Inspector’s Report for the West Sussex Joint Minerals Local Plan 1.5 The West Sussex Joint Minerals Local Plan was examined by an independent Planning Inspector in 2017-18. Of particular relevance to the issue of major development were the Inspector’s conclusions on Policy M2, to commit the Authorities to starting an early focused review of the soft sand strategy. This is because he found the proposed strategy of not considering the allocation of soft sand sites in the National Park as unsound.

1.6 The Inspector’s reasoning is set out in paragraphs 22 to 39 of the Inspector’s Report. He concluded that reasonable alternatives to the strategy of ‘managed retreat’ from the National Park had not been considered as part of the sustainability appraisal process, and that it was premature to rule out sites in the National Park on the basis of there being no exceptional circumstances to justify major development.

1.7 The Inspector’s conclusions on the issue of major development and exceptional development in a national park underline the need to consider these issues at the plan-making stage. It is the reason why one of the strategy options published during the Issues and Options consultation in January 2019, Option B, is to ‘supply from sites within West Sussex, including within the National Park.’

1 Legal Opinion In the Matter of the South Downs National Park Authority and in the Matter of Paragraph 22 of PPS7 (James Maurici, 2011); Legal Opinion In the Matter of the National Planning Policy Framework and In the Matter of the South Downs National Park Authority (James Maurici, 2014); Further Opinion in the Matter of the National Planning Policy Framework and in the Matter of the South Downs National Park Authority (James Maurici, 2014) 2 See ‘Major Development Advice’ – Legal Opinion in the matter of the South Downs National Park and in the Matter of Paragraph 116 of the NPPF (Toby Fisher, Landmark Chambers, Oct 2017) published as Core 11 in the SDLP core document library

2. APPROACH TO MAJOR DEVELOPMENT IN THE SOUTH DOWNS NATIONAL PARK

The National Park purposes 2.1 The purposes of National parks are set out in the National Parks and Access to Countryside Act 1949, as amended by the Environment Act 1995 as follows:  Purpose 1: To conserve and enhance the natural beauty, wildlife and cultural heritage of the area;  Purpose 2: To promote opportunities for the understanding and enjoyment of the special qualities of the National Park by the public

The National Park Authority also has a duty when carrying out the purposes:  To seek to foster the economic and social well-being of the local communities within the National Park. 2.2 In addition, Section 62 of the Environment Act 1995 also requires all relevant authorities, including statutory undertakers and other public bodies, to have regard to these purposes. Where there is an irreconcilable conflict between the statutory purposes, statute requires the Sandford Principle to be applied and the first purpose of the National Park will be given priority.

Determining major development 2.3 The SDLP includes Core Policy SD3: Major Development which sets out the approach taken to determining what constitutes major development in the National Park. In short, this relates to whether development, by reason of its scale, character or nature, has the potential to have a significant adverse impact on the natural beauty, wildlife or cultural heritage of, or recreational opportunities provided by, the National Park. The SDLP also sets out a set of principles to consider when applying Policy SD3 at the planning application stage to determine whether development constitutes major development:

 A judgement will be made in light of all of the circumstances of the application and the context of the application site;

 The phrase ‘major development’ will be given its common usage, and will not be restricted to the definition of major development in the Town and County Planning (Development Management Procedure) (England) Order 2015, or to proposals that raise issues of national significance;

 The determination as to whether the development is major development will consider whether it has the potential to have a serious adverse impact. It will not include an in- depth consideration of whether the development will in fact have such an impact;

 The application of other criteria may be relevant to the considerations, but will not determine the matter or raise a presumption either way. 2.4 These principles will be applied in the consideration of shortlisted sites in the section below.

Exceptional circumstances evidence

2.5 The NPPF sets out, in paragraph 172, examples of what may constitute exceptional circumstances to justify development in a national park. These are set out in full in paragraph 1.1 above. In short, they relate to the need for the development; the cost of (and scope for) meeting the need elsewhere or in another way; and the impact on landscape/recreation and how this might be mitigated. Furthermore, major development must be shown to be in the public interest. SDLP Policy SD3: Major Development also sets out the same exceptional circumstances as paragraph 172 of the NPPF.

2.6 A brief analysis of what, if any, exceptional circumstances might be considered at the appropriate time, are set out in the section below.

3. ASSESSING POTENTIAL MINERALS SITES

3.1 The following section provides a proforma-based analysis of the sites which have been considered for allocation in the SSR. This draws information from the Soft Sand Site Selection Report (4SR) (WSCC/SDNPA, 2019) which was prepared for the Issues and Options consultation stage for the SSR. It is noted that the Inspector for the Joint Minerals Local Plan concluded that, in respect of the earlier Minerals Site Selection Report (WSCC/SDNPA, 2019), “the site selection methodology and its application, including the traffic light system, is robust and sound” (paragraph 64). The Authorities have therefore applied the same site assessment methodology for the 4SR, having first reviewed it with technical specialists to ensure it is up-to-date.

3.2 The sites as set out in Figure 1 were shortlisted for consideration in the Issues & Options document.

FIGURE 1: SHORTLISTED SITES Extension to Site Name Parish Site (Ha) Yield (tonnes) In SDNP? existing site? Buncton Manor Farm Washington 23 1,000,000 No No (new site) Chantry Lane Storrington and 2.5 1,000,000 Yes Yes (Extension) Sullington Coopers Moor Duncton 6 500,000 Yes Yes (Extension) Duncton Common Duncton and 28 1,800,000 Yes Yes (Extension) Petworth East of West Heath Harting and 16 1,000,000 Yes Yes Common (Extension) Rogate Steyning and Ham Farm (new site) 8.2 725,000 No No Wiston Minsted West Stedham with 10 2,000,000 Yes Yes (Extension) Iping Severals East (new Woolbeding with 20 1,000,000 Yes No site) Redford Severals West (new Woolbeding with 50 1-3 million Yes No site) Redford

3.3 Only the seven sites located inside the South Downs National Park have been assessed with regards major development. The full commentary is set out in Appendix A. The summary outcome of these assessments is set out in Figure 2.

FIGURE 2: SUMMARY OF MAJOR DEVELOPMENT ASSESSMENT Potential Potential impact on impact on Potential Potential landscape conservation impact on impact on Likely to be major Site Name and and recreational cultural development? natural enhancement opportunities heritage beauty of wildlife Depends on Chantry Lane Depends on Yes scheme Unlikely Yes (Extension) scheme details details Depends on Coopers Moor Yes scheme Yes Yes Yes (Extension) details Duncton Common Yes Yes Yes Yes Yes (Extension) East of West Depends Depends on Depends on Heath Common on scheme Yes scheme Yes scheme details (Extension) details details Minsted West Depends on Yes Yes Yes Yes (Extension) scheme details Severals East Depends on Yes Yes Yes Yes (new site) scheme details Severals West Depends on Yes Yes Yes Yes (new site) scheme details

4. EXCEPTIONAL CIRCUMSTANCES

4.1 As set out in paragraph 2.3 above, the following criteria have been cited in NPPF paragraph 172 as needing to be considered when assessing whether major development in a national park is exceptional:  Is there an overriding need for the development?  What is the cost of, and scope for, developing outside the area?  To what extent are there detrimental effects on the environment?  What are the landscape and recreational opportunities?  What is the extent of moderation (mitigation)?  Are there any other exceptional circumstances? 4.2 Figure 3 sets out examples of information that could be provided at the planning application stage in order to demonstrate that exceptional circumstances exist. 4.3 In considering whether there is an overriding need for the development, reference should be made to the Local Aggregates Assessment (LAA) for West Sussex.3 This will provide some indication of the scale of need compared with the existing supply of soft sand. The LAA is updated annually, so an assessment of whether there is overriding need can only be reasonably made at the time a site comes forward by way of planning application. This also needs to be balanced against other exceptional circumstances (or lack of) to establish whether taking forward such a site in the National Park is appropriate. 4.4 To assess the cost of, and scope for, developing outside the area, a full assessment of other sources of supply outside of the National Park will need to be undertaken. If it is determined that there are insufficient sites in the county of West Sussex, the potential for other authorities to be able to meet needs from West Sussex will require consideration, through the requirements of the Duty to Cooperate. 4.5 The other criteria cited above are site specific criteria that will need to be considered at the planning application stage. It is considered imperative in a national park context that the moderation of the impacts of such development ensure significant enhancement towards achieving the national park statutory purposes. If there is confidence this can be achieved in the long term, this will lend considerable weight to exceptional circumstances applying to justify the development.

FIGURE 3: EXAMPLES OF INFORMATION AVAILABLE TO ASSESS NPFF PARAGRAPH 172 NPPF Paragraph 172 Examples of information that may be used in assessment of proposals Is there an overriding need for the development The LAA will be the primary tool for assessing need

What is the cost of, and scope for, developing This will be guided by site allocations and the outside the area LAA for other Mineral Planning Authorities, any

3 The latest Local Aggregates Assessment is at https://www.westsussex.gov.uk/about-the-council/policies-and- reports/environment-planning-and-waste-policy-and-reports/minerals-and-waste-policy/local-aggregate- assessment/

relevant national policy and guidance, and information from the minerals industry To what extent are there detrimental effects on This will be informed by the assessments the environment prepared to support the SSR and wider JMLP, those prepared in support of other development plans and relevant project level Appropriate Assessments and Environmental Impact Assessments What are the landscape and recreational The updated landscape assessment for the SSR opportunities provides some context for the landscape and recreational opportunities that may be available. Proposals should also consider the most up to date SIDILCA4. Any proposals should fit with wider strategies for recreational opportunities within the SDNP. What is the extent of moderation (mitigation) Proposals requiring moderation and mitigation (beyond normal operating procedures).

Are there any other exceptional circumstances? Other exceptional circumstances may arise over the plan period and those will be reviewed as

and when development proposals come forward or when the JMLP is reviewed.

5. CONCLUSIONS AND NEXT STEPS

5.1 This paper has set out how sites shortlisted for soft sand extraction should be considered in the context of major development in the South Downs National Park. The assessment indicates that all 7 sites shortlisted within the National Park are likely to be considered major development, as they have the potential to adversely impact on the landscape and natural beauty, conservation and wildlife enhancement, recreational opportunities and cultural heritage. 5.2 It is important to note that these assessments are provisional. At the plan-making stage, there is insufficient detailed information on schemes likely to come forward on sites to conclusively say that a site is major development. Nevertheless, it is important to understand the likelihood of this being the case, as this in turn highlights whether there is a need to consider whether or not an exception case will need to be made at application stage to take the site forward. 5.3 The next steps will be for West Sussex County Council and the South Downs National Park Authority to decide which, if any, of the shortlisted sites to take forward as allocations. This decision will fundamentally be based on whether sites are the most appropriate overall. Part of

4 South Downs Integrated Landscape Character Assessment

this will be the consideration of whether major development in the South Downs National Park can be justified, in light of potential exceptional circumstances.

APPENDIX A: ASSESSMENT PROFORMAS

Chantry Lane Extension (SDNPA)

Site description District/Parish Horsham/Storrington and Sullington Area (ha) 2.5 Mineral type Soft sand Potential yield 1 million tonnes Current use Extension to existing workings. Adjoining land uses: Chantry Quarry and pasture. Owner Dudman Group Ltd

Potential operator Dudman Group Ltd Restoration options LVIA (2019) Restoring all or parts of the site to support a mix of nationally important heathland habitats including open heather heath, acid grassland, bracken, gorse, woody scrub, and oak-birch woodland, alongside the implementation of an appropriate management plan, to be agreed prior to consent; • Returning the site to its existing profile and then restoring to agricultural use following extraction. Long term restoration should aim to maximise the habitat value of the farmland, minimising soil erosion and pollution (of soil and ground water), and to improve the historic and landscape character by restoring and enhancing hedgerows and woodland structure. • Opportunities should be taken to improve habitat connectivity. • • Restoration proposals should be considered in combination with the restoration of the existing Chantry Lane site to the west Site specific information A draft redevelopment plan has been drawn up for Chantry Lane (operational Industrial Estate and the Sand Quarry. This includes housing and considerations) employment or an educational campus.

Assessment of potential to be major development Potential impact on Analysis landscape and scenic The 4SR gives the site a Red/Amber RAG score in respect of landscape beauty and visual designations. It states that the site itself has a medium landscape sensitivity, though the access has a medium-high landscape sensitivity. The site has a moderate capacity for mineral extraction. The existing access to the site is not supported by Highways and therefore a new access would be required. The site is shown with a proposed northern access onto the A283 (approximately 70m west of Sullington Lane). This aspect of the proposed site has potential to cause significant urbanising impacts on the existing character and views of the chalk ridge to the south. Overall character of the A283 could also be affected to a significant degree by necessary highway improvement works. Levels, boundaries, signage and detailed design will require careful consideration and may not be acceptable in Landscape terms.

Assessment The creation of a new access and associated changes to Sullington Lane is likely to result in significant impacts on landscape character within the National Park. Subject to details of any planning application, it therefore has the potential to have a significant adverse impact on the scenic beauty of the South Downs National Park. For this reason, the proposal is considered to be major development.

Potential impact on Analysis conservation and enhancement of wildlife The 4SR gives the site a Amber RAG score in respect of nature conservation and geodiversity designations. Adjacent to a SSSI (which is outside the National Park). 5km from the Arun Valley SPA/Ramsar, although unlikely to be affected by the site- provided sediment loading into nearby watercourses is adequately controlled through appropriate conditions. Within the 12km buffer for the Mens SAC, therefore considered to be in proximity to commuting and foraging habitat for barbastelle and Bechstein bats. Assessment There are some sensitivities at this site which may result in potential negative impacts. The outcome of the major development test at application stage in respect of wildlife conservation is likely to depend on more detailed site assessment at the planning application stage, and whether proposals include effective mitigation measures. Potential impact on Analysis recreational opportunities The 4SR gives the site a Green RAG score in respect of public rights of way, and a Amber RAG score in respect of amenity. Public Footpath 2664 runs in a southeasterly direction along the boundary of the existing quarry. It emerges onto Chantry Lane beside the entrance to the existing quarry. The 4SR concludes that there are no detrimental issues for PROW – on the basis that no works are undertaken within 20m of public footpath 2664. There is potential for the quarry extension to affect long views from the South Downs Way, albeit in the context of existing development in the vicinity and the existing quarry. Assessment The impact on recreational opportunities is likely to be limited. Potential impact on Analysis cultural heritage The 4SR gives the site a Green/Amber RAG score in respect of historic environmental designations. It identifies that the remains of an ancient occupation may be present below ground. It further states that the site is acceptable, provided impacts upon any buried archaeological remains can be satisfactorily mitigated. Overall, the site may have a minor negative effect on archaeological remains and the setting of various historical assets. There is some uncertainty as to the scale of the impacts and as such a detailed archaeological impact assessment would be required. Mitigation measures would need to be adopted to prevent harm to any archaeological remains. Assessment The outcome of the major development test in respect of cultural heritage is likely to depend on the effectiveness of mitigation measures proposed.

Conclusion – Chantry Lane Extension The proposed extension has the potential to have a significant adverse impact on the natural beauty of the South Downs National Park. There is also potential for an impact on conservation enhancement and wildlife. The proposal is, therefore, considered to be major development.

Coopers Moor (SDNPA)

Site description District/Parish Chichester/Duncton Area (ha) Approx. 6 Mineral type Soft sand Potential yield 500,000 tonnes Current use Woodland - birch regeneration and chestnut coppice Owner Leconfield Estate Potential operator Dudman Group Ltd.

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Restoration options LVIA (2019) The recommendation is not to develop this site to the low capacity and visual sensitivity, however should circumstances result in extraction required to take place: • Careful siting of access tracks and roads, avoiding significant mature, broadleaf and coppiced trees; • Mitigate the impact on access point onto rural roads and sensitive verges; • Create and retain appropriate buffers around the water courses internally within the site; • Retain mature trees around the perimeter and reinforce with additional planting of Beech / Oak trees to improve on existing screening seen from surrounding public rights of way and residential properties; • Link new planting with the existing structure of woodland, tree belts and hedgerows within the surrounding farmland to the south; • Ensure appropriate screening of views into the site from Duncton Common Road to the north, the A285 and the public path to the southwest is included. • Mitigation and restoration measures would have to provide a high net gain to Ecosystem Services. Site specific information The site would be worked as an extension to the existing Heath End (operational Sandpit. considerations).

Assessment of potential to be major development Potential impact on Analysis landscape and scenic The 4SR gives the site a Red RAG score in respect of landscape and beauty visual designations. Coopers Moor is considered to have high sensitivity on all/many aspects of landscape. The site contains mature broadleaf trees and water courses, is tranquil in character and overlooked by higher ground to the south, which means adequate screening of views from the ridge may not be achieved by retaining and enhancing trees and vegetation around the perimeter. These factors reduce the overall capacity of the landscape to accommodate development of this nature without adverse impacts on the habitat value and visual amenity. With the proximity of the existing extraction site to the northeast, there is potential for cumulative effects on the special qualities of the wider Wealden Farmland and Heathland Mosaic character area, within the SDNP, and the potential for this type of development to visually intrude into views from Duncton Viewpoint and the chalk ridge to the south.

Assessment The 4SR concludes that the site is not suitable due to its highly visible and sensitive location which would be severely affected by mineral extraction. It therefore has the potential to have a significant adverse

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impact on the scenic beauty of the South Downs National Park. For this reason, the proposal is considered to be major development. Potential impact on Analysis conservation and The 4SR gives the site an Amber RAG score in respect of nature enhancement of wildlife conservation and geodiversity designations. The site includes BAP habitat and woodland. Heath End Sandpit SNCI is directly adjacent to the north of the site. River Rother SNCI is 1km to the north. Duncton Common SNCI is 0.4km to northwest. SAC/SSSI (Duncton and Bignor Escarpment) is located under 2km to the south of the site.

Assessment There are some sensitivities at this site which may result in potential negative impacts. The outcome of the major development test in respect of wildlife conservation is likely to depend on more detailed site assessment at the planning application stage, and whether proposals include effective mitigation measures. Potential impact on Analysis recreational opportunities The 4SR gives the site a Green RAG score in respect of public rights of way. No PROWs cross/enter the site. A network of footpaths and bridleways are located close to the site (to the north, south, east and west) including the Serpent Trail. The Duncton Viewpoint is located approximately 2.5km to the south of the site and offers views of the landscape to the north, including towards this site. The analysis of landscape impact found potential for this type of development to visually intrude into views from Duncton Viewpoint and the chalk ridge to the south. There may also be impacts on the tranquillity of the area, which in turn impacts upon recreational enjoyment.

Assessment There is potential for this type of development to have a significant adverse impact on recreational opportunities offered by the South Downs National Park in this location. For this reason, the proposal is considered to be major development. Potential impact on Analysis cultural heritage The 4SR gives the site a Red/Amber RAG score in respect of historic environment designations. There are several Listed Buildings nearby, including Redlands Farmhouse and Milestone Cottage approximately 150m to the southeast. The site lies near several known archaeological sites, including a Scheduled Ancient Monument (linear barrow cemetery - one of the most important surviving examples on the Greensand); there may be further buried archaeological remains within the site, and visible field boundary earthworks, pre-dating the present (early 19th- century?) wood. The potential impact of mineral extraction upon the setting of the nearby Scheduled Ancient Monument (SAM) should be

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considered in the light of the long-standing location of the SAM upon an unworked ridge within the existing sand pit, still in operation.

Assessment The 4SR concluded that development of the site could cause major harm to the setting of a number of listed buildings, a SAM and may harm buried archaeological remains in the absence of high levels of mitigation. Subject to details of any planning application, it therefore has the potential to have a significant adverse impact on the cultural heritage of the South Downs National Park. For this reason, the proposal is considered to be major development.

Conclusion – Coopers Moor The development of this site has the potential to have a significant adverse impact on the natural beauty of the South Downs National Park. There is also potential for an impact on cultural heritage, recreational opportunities, and on conservation enhancement and wildlife. The proposal is, therefore, considered to be major development.

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Duncton Common (SDNPA)

Site description District/Parish Chichester/Duncton and Petworth Area (ha) 28.5 Mineral type Soft sand (concrete and building sand) Potential yield 1.8mt Current use Forestry/ heathland

Original proposed scheme: Depending on water table, either a landscaped lake or reafforested. Owner Leconfield Estate Potential operator Dudman Group Ltd

Restoration options LVIA (2019) Due to capacity and landscape sensitivity in certain areas the recommendation is for the partial development of this site, based on mitigation measures that could include: • Phasing of extraction, so that a series of areas are developed in sequence, reducing the potential for the visual intrusion that development of the entire area at one time would result in; • Careful siting of access tracks and roads, avoiding pockets of mature broadleaf trees; • Mitigate the impact on access point onto rural roads and sensitive verges; • Create and retain appropriate buffers around the water courses through the site; • Create and retain appropriate buffers around areas of ancient woodland to the northwest of the site and link new planting with the existing structure of mature woodland; • Retain footpaths, bridleways and the Serpent Trail in their existing alignment, and ensure appropriate screening of views into areas of extraction activity from them. Site specific information Wet heathland site/bog with important species. (operational considerations).

Assessment The 4SR concludes that the site is not suitable due to its high landscape sensitivity which would be be severely harmed by mineral extraction from the site. It therefore has the potential to have a significant adverse impact on the scenic beauty of the South Downs National Park. For this reason, the proposal is considered to be major development.

Potential impact on The 4SR gives the site a Red/Amber RAG score in respect of nature conservation and conservation and geodiversity designations. There are a number of enhancement of wildlife environmental sensitivities:  Small wet heathland SCNI;  Priority habitat lowland heath, rare species inventory records and falls within a Biodiversity Opportunity Area;  Heath End Sandpit SNCI in proximity

 Lavington Common SSSI lies immediately to the west;  Duncton Common SNCI and the River Rother SNCI in proximity;  Approximately 2.3km from Duncton to Bignor Escarpment SSSI/SAC;  Ancient Woodland (Kilsham Copse) is located adjacent to the site;  Approximately 8km from the Mens SAC and 9km from Ebernoe Common SAC, however it lies outside of the key foraging distance of Barbastelle and Bechstein bats;  A watercourse adjacent to the site drains into River Rother and into Arun Valley SPA/Ramsar, and  An initial screening exercise identified that water quality was a pathway requiring consideration due to the potential impact of sediment within close proximity to European designated sites. It was concluded that adequate safeguards are in place to ensure that this site will not have an adverse effect on the Arun Valley SPA/Ramsar through reduced water quality. Assessment The 4SR concluded that development of the site could severely harm an important area of wet heathland habitat within a SNCI and also harm nearby BAP habitats, ancient woodland and the Arun Valley SPA/Ramsar. It therefore has the potential to have a significant adverse impact on the conservation and enhancement of wildlife. For this reason, the proposal is considered to be major development. Potential impact on Analysis recreational opportunities The 4SR gives the site an Amber RAG score in respect of public rights of way, and a Amber score in respect of amenity. Also, the landscape assessment notes that development of the site has the potential to affect the amenity and recreational value of the adjacent areas, as it forms a link between areas to the east and west of high recreational value. Public Bridleway 671 runs along the northern boundary. Public Footpath 672/2 - the Serpent Trail bisects the site from east to west. Public Footpath 3527 also crosses the site from north to south. There is a parking and picnic areas close to the western boundary. A number of non-statutory forestry paths and tracks cross the site. Open access land at Lavington Common lies immediately to the west of the site. Assessment There is potential for this type of development to have a significant adverse impact on recreational opportunities offered by the South Downs National Park in this location. For this reason, the proposal is considered to be major development. Potential impact on Analysis cultural heritage The 4SR gives the site a Red/Amber RAG score in respect of historic environment designations. The site lies adjacent to several Listed Buildings with a high concentration to the southeast (between approximately 0.5km and 1.5km). The closest is Cathanger Farmhouse which is located approximately 300m to the north. The site adjoins one

Scheduled Ancient Monument and lies near another (a single barrow and a linear barrow grouping). Archaeological finds are recorded from just within this site, and medieval/ early post-medieval earthworks are known at the eastern edge of Lavington Common, and may extend into this site.

Assessment The 4SR concludes development of the site may cause major harm to the setting of listed buildings, Scheduled Ancient Monuments and it may harm archaeological items within the site. It therefore has the potential to have a significant adverse impact on the cultural heritage of the area. For this reason, the proposal is considered to be major development.

Conclusion – Duncton Common

The development of this site has the potential to have a significant adverse impact on the scenic beauty of the South Downs National Park, the conservation and enhancement of wildlife, recreational opportunities and cultural heritage. The proposal is, therefore, considered to be major development.

East of West Heath Common (SDNPA)

Site description District/Parish Chichester/Harting and Rogate Area (ha) 14 Mineral type Sand – Folkestone Beds Potential yield 950,000 tonnes Current use Agricultural site located to the north east and south east of scheduled monuments. Farm buildings are located to the west of the site and the village of Nyewood is located to the east of the site. Owner Cemex

Potential operator Cemex Restoration options LVIA (2019) • Restoring parts of the site (along the northern edge) to support a mix of nationally important heathland habitats including open heather heath, acid grassland, bracken, gorse, woody scrub, and oak-birch woodland. Appropriate options include expansion of riparian/ heathland woodland scrub linked to watercourses/ land drainage system to manage water table and option for developing areas of open water alongside the implementation of an appropriate management plan, to be agreed prior to consent; • Returning the site to its existing profile and then restoring to a mix of heathland and open water linked to riparian woodand, scrub and wet meadow following extraction. Long term restoration should aim to maximise the habitat value of the site with a mosaic of habitats linked into the surrounding farmland and seek to improve the historic and landscape character by restoring and enhancing hedgerows and woodland structure. • Opportunities should be taken to improve links with the surrounding woodland and copses, including Downpark Common and Chase Copse Site specific information The water table may be an issue. (operational considerations).

Assessment of potential to be major development Potential impact on Analysis landscape and scenic The 4SR gives the site an Amber RAG score in respect of landscape and beauty visual designations. The site is considered to have a Medium sensitivity to extraction. Although low lying and generally flat, with views into the area restricted by existing vegetation, the site has a secluded quality and an intricacy of landscape pattern and elements. There also sensitive features such as a Moat to the south, and habitats in the immediate vicinity.

Assessment Whilst there are opportunities to mitigate impacts on the landscape due to the screened nature of the site, there is still potential for harm due to the site’s secluded and tranquil character, and contribution of landscape elements. The outcome of the major development test in respect of landscape and scenic beauty is likely to depend on more detailed site assessment at the planning application stage, and whether proposals include effective mitigation measures.

Potential impact on Analysis conservation and enhancement of wildlife The 4SR gives the site an Amber RAG score in respect of conservation and enhancement of wildlife. This site lies approximately 6km from Wealden Heaths Phase II SPA and East Hampshire Hangers SAC. There is

potential for an impact pathway via traffic emissions to the Wealden Heaths Phase II Special Protection Area (SPA). West Heath Common SNCI (SNCI C64) lies to the west of the site and consists of the existing quarry and permitted extension area. The area within this SNCI is notable for supporting four species of reptile and important wet heath habitat. Records show it supports breeding nightjar and has supported woodlark. The River Rother SNCI is in proximity. Millhanger Copse, Harting Pond and Stream SNCI is located approximately 0.2km to the southwest of the site. Also in proximity are Fyning Moor SSSI, and a number of Ancient Woodland sites. Assessment The site is located close to a number of national and local designations which may be moderately harmed by developing the site for minerals extraction – especially if sediment enters the adjacent watercourse, although this could be controlled through conditions. It therefore has the potential to have a significant adverse impact on conservation and the enhancement of wildlife. For this reason, the proposal is considered to be major development. Potential impact on Analysis recreational opportunities The 4SR gives the site an Amber RAG score in respect of public rights of way, and an Amber RAG score in respect of amenity. Public Footpath 861 is located 500m to the west of the proposed site and runs northwards along the eastern boundary of the existing quarry. This footpath forms part of the Serpent Trail, and may be affected by a mechanical conveyor which may be needed to link the existing site and the proposed site together. Assessment There is potential for the development to adversely affect a public right of way that forms a national trail. The outcome of the major development test in respect of recreation is likely to depend on mitigation proposed at the planning application stage with respect to the experience of users of the Serpent Trail. Potential impact on Analysis cultural heritage The 4SR gives the site an Amber RAG score in respect of historic environment designations. The site is approximately 350m from a Scheduled Monument comprising two, probably prehistoric barrow mounds. Further archaeological artefacts have been discovered and recorded. North-west of the site there may be present early prehistoric rive terrace sands/ gravels, which may contain Early Palaeolithic flint tools, and microfossils relevant to the understanding of the ancient environment. Parlour Copse directly to the south of the site boundary could also be compromised. Assessment There is potential for the development to adversely affect cultural heritage assets in the area. The outcome of the major development test

in respect of cultural heritage is likely to depend on mitigation proposed at the planning application stage.

Conclusion – East of West Heath Common

The development of this site has the potential to have a significant adverse impact on conservation and the enhancement of wildlife. There is also potential for an impact on landscape and scenic beauty, recreational opportunities and cultural heritage. The proposal is, therefore, considered to be major development.

Minsted West (SDNPA)

Site description District/Parish Chichester/Stedham with Iping Area (ha) 11 Mineral type Soft sand, Folkestone Beds Potential yield 2mt Current use Agricultural field Owner All Souls College Potential operator Dudman Group Ltd

Restoration options LVIA (2019) Restoring all or parts of the site to support a mix of nationally important heathland habitats including

open heather heath, acid grassland, bracken, gorse, woody scrub, and oak-birch woodland, alongside the implementation of an appropriate management plan, to be agreed prior to consent; • Returning the site to its existing profile and then restoring to agricultural use following extraction. Long term restoration should aim to maximise the habitat value of the farmland, minimising soil erosion and pollution (of soil and ground water), and to improve the historic and landscape character by restoring and enhancing hedgerows and woodland structure. • Opportunities should be taken to improve habitat connectivity with the Steadham Common LNR and surrounding fragmented areas of heathland • Restoration proposals should be considered in combination with the restoration of the existing site to the north Site specific information Operator indicated that the site would be worked as an extension to an (operational existing quarry and an open water would be connected to an existing considerations). water body.

Assessment of potential to be major development Potential impact on Analysis landscape and scenic The 4SR gives the site a Red/Amber RAG score in respect of landscape beauty and visual designations. The site is considered to have a Medium-High sensitivity. The potential effects of development on the tranquillity of the area and inter-visibility with the upper slopes of the chalk escarpment increase the sensitivity of the site. Although broadly enclosed, with views into the area restricted by existing vegetation, the site has a secluded and tranquil quality. A number of paths and bridleways, and which contributes to the recreational value of the wider area.

Assessment The supplement to the WSCC Sensitivity Study 2011 (SDNPA 2015) identified that restoration proposals would be key to this site and should be contiguous with that of the existing site which are proving to be difficult to resolve. It therefore has the potential to have a significant adverse impact on the scenic beauty of the South Downs National Park. For this reason, the proposal is considered to be major development.

Potential impact on Analysis conservation and enhancement of wildlife The 4SR gives the site a Red/Amber RAG score in respect of conservation and enhancement of wildlife. Henfield Wood SNCI (SNCI C123) lies approximately 200m to the west of this site, Stedham

Common SNCI within 0.5km to northeast, and Severals Bog approximately 0.6km to the east. Ipping Common (SSSI and LNR) is 0.5km to the north of the site. An initial screening exercise identified that water quality was a pathway requiring consideration due to the potential impact of sediment within close proximity to European designated sites. It was concluded that adequate safeguards are in place to ensure that this site will not have an adverse effect on the Arun Valley SPA/Ramsar through reduced water quality.

Assessment The site near to national designations which could experience negative impacts from the development of the site. The hydrological impact of the existing quarry on national designations is currently unknown. Minerals extraction therefore has the potential to have a significant adverse impact on conservation and the enhancement of wildlife. For this reason, the proposal is considered to be major development. Potential impact on Analysis recreational opportunities The 4SR gives the site an Amber RAG score in respect of public rights of way, and an Amber RAG score in respect of amenity. Bridleway 907 runs along the northern boundary of the proposed site (to the south of the existing quarry) joining Public Bridleway 909/4 to the northeast of the site. Footpath 910 is located 150m to the east of the site, bridleway 3358 and footpath 903are located 0.4km to the southeast. Whilst surrounding woodland and forestry limit visibility with the wider area to an extent, the site lies in close proximity to a local nature reserve to which it is linked by these paths and bridleways, and which contributes to the recreational value of the wider area. Re-routing of the footpath which crosses to the south of the existing site would be necessary. Assessment There is potential for the development to adversely affect a number of public rights of way. Bridleway 907 could require a long diversion- should the existing site and the extension area be joined together. It therefore has the potential to have a significant adverse impact on recreational opportunity of the South Downs National Park. For this reason, the proposal is considered to be major development. Potential impact on Analysis cultural heritage The 4SR gives the site an Amber RAG score in respect of historic environmental designations. There is evidence of former settlements on the site, and a number of Scheduled Monuments to the northwest of the site; Bowl Barrow on Fitzhall Rough is the closest at 200m away. Three listed buildings located to the southeast of the site (all within 0.5km). Two listed buildings to the northeast of the site, one within

0.5km and one just over 0.5km from the site. Also listed building to the west of the site, under 0.5km. There are three Conservation Areas close to the site, Stedham (1.2km northeast), Iping (1.7km north) and Trotton (1.8km northwest). Woolbeding Estate and Gardens is located north east of the site, managed by the National Trust. Assessment The site is located within 200m from a Scheduled Monument which may experience harm, in the absence of appropriate mitigation. Listed buildings, registered parks and potentially archaeological remains are located in close proximity to the site. There is potential for the development to adversely affect cultural heritage assets in the area. The outcome of the major development test in respect of cultural heritage is likely to depend on mitigation proposed at the planning application stage.

Conclusion – Minstead West

The development of this site has the potential to have a significant adverse impact on landscape and scenic beauty, the conservation and the enhancement of wildlife, and recreational opportunities. There is also some potential for an impact on cultural heritage. The proposal is, therefore, considered to be major development.

Severals East and West Note: Following the Regulation 18 consultation, and meetings with Raymond Brown Quarry Products Ltd., the site is being assessed as a single site.

Site description District/Parish Chichester/ Woolbeding with Redford Area (ha) Severals East = 20ha, Severals West = 55ha Mineral type Soft sand Potential yield 1.7mt approx. Current use Commercial forestry Owner Cowdray Estate

Potential operator Raymond Brown Quarry Products Ltd Restoration options Restoring the site to support a mosaic of nationally important heathland habitats including open heather heath, acid grassland, bracken, gorse, woody scrub, and oak-birch woodland, alongside the implementation of an appropriate management plan, to be agreed prior to consent; • Returning the site to its existing profile and then restoring to woodland following extraction. Long term restoration should aim to maximise the habitat value by taking opportunities to improve habitat connectivity with the Steadham Common LNR, surrounding fragmented areas of heathland and Minstead Common to the west. • Restoration proposals should be considered in combination with the restoration of other sites in the vicinity.

The site promoter has commented that the restoration could include a mixture of deciduous broad leaf tree species incoroprating the diversity of woodland/heathland habitat that links Midhurst Common to Stedham Common. Site specific information Western part of the site could be used for processing with a conveyor (operational from the east which could go underground considerations).

Assessment of potential to be major development Potential impact on Analysis landscape and scenic The 4SR gives the sites an Amber RAG score in respect of landscape and beauty visual designations. The site is considered to have a Medium-High landscape sensitivity. The potential effects of the development on the areas of ancient woodland, the tranquillity and sense of remoteness of the area and the recreational value of the area increase the sensitivity of the site. Although predominantly comprising plantation forest, restricting views into the area and enabling the visual containment of extraction activities within existing tree cover, areas of broadleaf trees reduce the overall capacity of the landscape. The existing use of the land for forestry plantation reduces its overall sensitivity on landscape grounds and to some extent how tranquillity is measured as the woodland is not perceived to be ‘natural’.

Assessment The site has medium-high landscape sensitivity owing in part to its tranquil and secluded nature, contributing to the setting of and experience provided by of Midhurst Common to the east and Stedham Common to the west. Minerals extraction therefore has the potential to have a significant adverse impact on the scenic beauty of the South Downs National Park. For this reason, the proposal is considered to be major development.

Potential impact on Analysis conservation and The 4SR gives the site a Red/Amber RAG score in respect of nature enhancement of wildlife conservation and geodiversity designations. The site is adjacent to Midhurst Common SNCI, and Stedham Common SNCI lies 0.7km to the west. The River Rother SNCI lies 0.3km to the north. Iping Common SSSI and LNR is located 1km to the west of the site. An Area of Ancient Woodland (replanted) is partially located within the north of the site. The site contains priority habitat of lowland heath and ancient woodland, contains rare species inventory records and is within a Biodiversity Opportunity Area. An initial screening exercise identified that water quality was a pathway requiring consideration due to the potential impact of sediment within close proximity to European designated sites. It was concluded that adequate safeguards are in place to ensure that this site will not have an adverse effect on the Arun Valley SPA/Ramsar through reduced water quality. Assessment It is considered that as the site contains priority habitat of lowland heath and ancient woodland, minerals extraction has the potential to have a significant adverse impact on conservation and the enhancement of wildlife. For this reason, the proposal is considered to be major development.

Potential impact on Analysis recreational opportunities The 4SR gives the site an Amber RAG score in respect of public rights of way, and a Red/Amber score in respect of amenity. The latter score in this case relates more to residential properties in the area rather than recreational amenity. Public Footpaths 3617 and 3618 run through the northern section of the site. Footpath 921 follows the eastern boundary of the site. Both footpaths 3617 and 921 form part of the Serpent Trail. Assessment Extraction across the whole site would require diversion of a national trail, or alternatively the site would pose a potential hazard for users of footpaths bisecting the site. There is potential for this type of development to have a significant adverse impact on recreational opportunities offered by the South Downs National Park in this location. For this reason, the proposal is considered to be major development. Potential impact on Analysis cultural heritage The 4SR gives the site a Green/Amber RAG score in respect of historic environment designations.

Heathbarn farmhouse (grade II listed) is to the north east of the indicated site boundary. The Grade II listed Toll House is located 0.4km away to the north east. There are four Conservation Areas within 2km of the site, Midhurst, Iping, Stedham and Woolbeding. Woolbeding Estate and Gardens north east of the site, managed by the National Trust. Assessment The site may cause minor harm to the setting of listed buildings, Conservation Areas and archaeological remains. The outcome of the major development test in respect of cultural heritage is likely to depend on the effectiveness of mitigation measures proposed.

Conclusions – Severals East and West