Response to the SDNPA Comments

Brett Aggregates Ltd. B&A Response to the South Downs National Park Authority (SDNPA) Neighbouring Authority Consultation Comments, Ref SDNP/17/05659/ADJAUT (Dated 5 December 2017)

1.1. INTRODUCTION 1.1.1. The following document provides a response to the South Downs National Park Authority (SDNPA) Neighbouring Authority Consultation Comments, Ref SDNP/17/05659/ADJAUT (Dated 5 December 2017). 1.1.2. Landscape and visual matters have been addressed and the comments are reproduced from page 3 and 4 of the SDNPA response. The comments have been reviewed in light of the amendment to the planning application and the removal of Stage 4. 1.1.3. The Landscape and Visual Impact Assessment undertaken by B&A is referred to as the 2017 LVIA. Reference is also made to the Addendum Report produced by B&A in February 2018.

1.2. TIDEMILLS AREA, LANDSCAPE CHARACTER OF THE AREA AND THE SETTING TO THE NATIONAL PARK 1.2.1. SDNPA Comment: ‘The significant visual effects of the proposal are clearly demonstrated in the photomontages and are most striking when viewed from the Tide Mills area of the National Park. This is likely the most significant view as the change here will be front and centre in views. The significance of these effects and the role that the site currently plays in the landscape character of the area and the setting to the National Park has failed to be drawn out in the LVIA’. 1.2.2. B&A Response: The Site represents a relatively small area and consists of industrial buildings (sheds) and large areas of concrete hardstanding. It is located in the port area of Newhaven which includes commercial and industrial land use. It is important to recognise that the current baseline situation encompasses planning consents in the vicinity including the Rampion building which is now completed to the west of the Site, the Newhaven East Quay and Port Expansion Area (consent reference LW/15/0034) to the south of the Site and the Newhaven Port Access Road (NPAR) which is broadly to the east and incorporates a bridge across Mill Creek and the southern extension. The changes to this situation as a result of the Proposed Development is very small. Viewpoint location 1: From Footpath No. N40b 1.2.3. In the 2017 LVIA, photomontages were prepared for five viewpoint locations, No’s 1 to 3, 8 and 11 and have been updated due to the removal of the Stage 4 development. 1.2.4. The above illustrate the baseline situation including the Newhaven East Quay and Port Expansion Area etc. and Stage 1 to 3 development.

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Brett Aggregates Ltd. B&A Response to the South Downs National Park Authority (SDNPA) Neighbouring Authority Consultation Comments, Ref SDNP/17/05659/ADJAUT (Dated 5 December 2017) 1.2.5. Viewpoint location 1: From Footpath No. N40b is to the east of the Site and is located in the Tide Mills area on the edge of the South Downs National Park (SDNP). Receptor sensitivity is Medium to High (Footpath users) given the location is close to the existing industrial areas. Visual Pack Supporting Information (Fieldsheets) were provided in Appendix 4 of the 2017 LVIA and record features such as components and characteristics etc. at each Viewpoint Location. The industrial nature of the view including lighting towers and disturbed landscape experience in terms of tranquillity and management was noted by the assessor. 1.2.6. The Addendum Report concurs with the conclusions of the 2017 LVIA. The Proposed Development would be visible but viewed against existing development and rising ground on the western side of the River Ouse. In Stage 1, the aggregate processing plant and storage areas and in Stage 3, the concrete batching and cement silos would be seen, although this would constitute only a minor component of the wider view and would not affect the overall quality of the scene. In Stage 2, there would be glimpsed views of the conveyor and the storage areas. Consequently, in Stage 1 and 3 there will be a Small magnitude of impact and a resultant Minor- Moderate (neutral) significance of effect. For Stage 2 there will be a Very Small magnitude of impact and a Minor (neutral) significance of effect. Close Range Views 1.2.7. The beach area of Tide Mills is also examined through a narrative of close range views. Promoted recreational routes such as the Poppy Trail and the Bishopstone Walk together with the nature reserve which forms part of planning consent LW/15/0034 (Newhaven East Quay and Port Expansion Area) is also nearby and acknowledged in the 2017 LVIA. They may provide an additional attraction for visitors and will bring the public in close proximity to the Site (Section 7.5: Visual Impact Assessment (Close Range Views)). The port area and industrial uses form part of the current scene. 1.2.8. The 2017 LVIA described aspects of the Newhaven East Quay and Port Expansion Area which includes a fenced boundary and results in a baseline of visual amenity including industrial buildings, related noise and activity and other built form. The 2017 LVIA noted that the Proposed Development would add to the amenity rather than causing new adverse effects and this assessment also applies to the Addendum Report. 1.2.9. For such close range views, when looking in a westerly direction, the Proposed Development is viewed against rising ground on the western side of the River Ouse, with residential development at a higher elevation and existing commercial and industrial activities evident in the port area. Given that the proposed built form is generally similar to that currently in situ and can be successfully integrated, the scale of the change from the baseline situation is minor. Stages 1 to 3 are located within a cluster of existing development. A Small level of change was noted for the 2017 LVIA and the Addendum Report concurs with the findings of the 2017 LVIA.

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Brett Aggregates Ltd. B&A Response to the South Downs National Park Authority (SDNPA) Neighbouring Authority Consultation Comments, Ref SDNP/17/05659/ADJAUT (Dated 5 December 2017) Other Viewpoint Locations within the SDNP 1.2.10. In terms of other photomontages, Viewpoint location 8: From Footpath No. Sh18b is located within the SDNP and is a long range view to the north- east of the Site. 1.2.11. For the 2017 LVIA and Addendum Report, views of the Stage 1 aggregate processing plant and storage areas and Stage 3, concrete batching plant and cement silos may be available albeit, this would constitute only a minor component of the wider view. In Stage 1 and 3 there will be a Small magnitude of impact and a Minor-Moderate (neutral) significance of effect. During Stage 2, there will be a Very Small magnitude of impact and a Minor (neutral) significance of effect. 1.2.12. Viewpoint Locations 5, 6, 13 and 14 are also within or on the edge of the SDNP. Viewpoint Location 5: From the A259 (Seaford Road) assesses views for road users (Low sensitivity) and footpath users/other public accessed areas (Medium sensitivity). For the 2017 LVIA and Addendum Report, magnitude of impact is recorded as Small or Very Small for the individual Stages (1 to 3). At Viewpoint Location 6: From Footpath No. S3, footpath users would have a Medium sensitivity. Results for the individual Stages 1 to 3 would be slightly lower overall with a Very Small or Negligible magnitude of impact. 1.2.13. Viewpoint Locations 13 and 14 are distant views north of the Site from within the SDNP. Receptor sensitivity is Medium for bridleway users and restricted byway users respectively. The Addendum Report concurs with the conclusions of the 2017 LVIA. Viewpoint Location 13: From Bridleway No. N32e records either a Very Small or Negligible magnitude of impact. The higher elevations of the aggregate processing plant may be visible, albeit the change will not be prominent given the existing view and current baseline situation of the Newhaven East Quay and Port Expansion Area and Newhaven Eastside, the latter being closer to the viewer. At Viewpoint Location 14: From a Track Near South Heighton (Restricted Byway No. Sh4b), the Proposed Development is mainly hidden due to intervening built form located near the Site and it will not materially alter the existing view. In Stages 1 to 3 there would be a Negligible magnitude of impact. 1.2.14. In the Addendum Report, the Desk Review Figures and Viewpoint Analysis Figures have been updated. See Section 7: Assessment Of Visual Effects Review which includes a description of close range views and Table 2: Addendum Report Visual Impact Assessment Summary.

1.3. CONSIDERATION OF MITIGATION MEASURES 1.3.1. SDNPA Comment: ‘As a result of the astonishingly poor quality LVIA, there is a significant lack of mitigation measures - particularly in response to the adverse visual effects on the National Park’. 1.3.2. B&A Response: For the 2017 LVIA and Addendum Report, mitigation measures for Stage 1 to 3 of the Proposed Development primarily relate to their grouping which is close to or within existing buildings. See Section 2:

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1.4. ASSESSMENT OF LANDSCAPE AND VISUAL IMPACTS 1.4.1. SDNPA Comment: ‘In addition the poor LVIA has taken such a general approach (and not adhering to the definition of landscape or landscape character) the majority of impacts remain unacknowledged at all’. For example:  Only impacts of the built form of the proposal have been assessed – there is no assessment of the landscape and visual impacts of the indirect affects e.g. new access routes, traffic increase, noise, dust, lighting etc’. 1.4.2. B&A Response: The focus of the 2017 LVIA and the Addendum Report is to assess the built form of the Proposed Development. In the 2017 LVIA, with respect to lighting, a brief description is provided in Section 4: The Baseline Situation and refers to the Site being located within an area that is well-lit, namely comprising industrial/port area land, as opposed to a more isolated area and separate to existing development. On Site, it is currently lit using modern lighting (e.g. down lighter type with shading). (paragraph 4.2.3) 1.4.3. In the Addendum Report, see Appendix 1, Table 1D: EIA Regulations (Schedule 4: Information for Inclusion in Environmental Statements) confirms that there have been no changes to lighting during the interim period.

1.5. KEY ELEMENTS RELATING TO THE SDNP 1.5.1. SDNPA Comment: ‘There is no assessment at all of key elements of landscape character and particularly those which relate to the National Park, such as: - Tranquillity - Dark Night Skies - Landscape History - Perceptual Qualities - the experiential qualities of this landscape and the effect the proposal will have on walkers has not been given sufficient thought in the LVIA. The LVIA takes a random approach to defining the sensitivity of visual receptors with some walkers being classed as less sensitive than local residents - this is contrary to the guidance’. 1.5.2. B&A Response: The above have been addressed below. 1.5.3. With reference to the South Downs National Park Authority Tranquillity Study 2017. Having examined the tranquillity mapping and the colour coded definitions, relative tranquillity across the South Downs National Park is split into three broad categories (i.e. Areas of highest tranquillity, Areas of intermediate tranquillity and Areas of lowest tranquillity). Appendix 1: Relative Tranquillity Scores For The South Downs National Park Area, identifies the environs of Newhaven including the port area shaded yellow (Areas of intermediate tranquillity) and orange (Areas of lowest tranquillity). Areas of highest tranquillity which are shown as dark green applies to higher elevations of the SDNP. (See Section 4: Baseline Situation Review of the Addendum Report). This accords with the general findings of the LVIA.

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Brett Aggregates Ltd. B&A Response to the South Downs National Park Authority (SDNPA) Neighbouring Authority Consultation Comments, Ref SDNP/17/05659/ADJAUT (Dated 5 December 2017) 1.5.4. Dark night skies mapping provided by the Campaign to Protect Rural England (CPRE) has been examined. The South Downs National Park mapping shows the environs of Newhaven and night lights between a ‘brighter’ and ‘brightest’ levels apply to the port area of Newhaven. The ‘darkest’ skies relate to more remote areas of the South Downs National Park. See Section 4: Baseline Situation Review of the Addendum Report. 1.5.5. With respect to historic landscape character studies, the Newhaven Historic Character Assessment Report, Sussex Extensive Urban Survey (EUS) (2004) does not include the majority of the Site and concentrates on the areas close to the River Ouse in Newhaven. The Sussex Historic Landscape Characterisation (HLC) (2010) identifies Newhaven in Area 15: Brighton & Coastal settlement. The HLC Sub-types relating to the town appear to be connected to the expansion of the settlement. (See Section 4: Baseline Situation Review of the Addendum Report). 1.5.6. In the 2017 LVIA, Section 3: Methodology explains how sensitivity, magnitude of impact and nature of effect is defined. The sensitivity of the viewer (receptor) is categorised according to the type of receptor and ranges from Very High to Very Low and is summarised in Table 3: Visual (Sensitivity). High sensitivity is defined as ‘From residential properties (ground floor locations/gardens), an established viewing point, or recognised public location for which the sensitivity of visual amenity is noted as being of a higher rating and includes views from the Sussex Ouse Valley Way, east of the Site’. Whilst Medium sensitivity concerns ‘Residential locations not associated with a High sensitivity as described above, footpath, bridleway and byway users including routes on the edge of the South Downs National Park and road users on the general road network’. 1.5.7. The above applies to the Addendum Report. Viewpoint Locations 1, 5, 6, 8, 13 and 14 are on the edge of or within the SDNP and examine views for footpath and bridleways users etc. The photomontages and photographs included with both the 2017 LVIA and updated for the Addendum Report demonstrate that views of the Site and Proposed Development are restricted from such routes. 1.5.8. In the Addendum Report, see Section 3: Methodology Review. Tables 1 to 6 of the 2017 LVIA have been adopted unchanged.

1.6. LANDSCAPE CHARACTER OF THE SITE AND ENVIRONS 1.6.1. SDNPA Comment: ‘The entire landscape baseline fails to demonstrate the distinctive landscape character of the site and it's context - it simply presents an inventory of land use. The reader is left none to wiser about the local character here and the information presented does not take a qualified landscape specialist to determine it’. 1.6.2. B&A Response: In the 2017 LVIA, Section 4: The Baseline Situation describes at length the landscape setting, in terms of the Site, immediate vicinity and surrounding landscape. It is essential to understand the context of the base line.

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Brett Aggregates Ltd. B&A Response to the South Downs National Park Authority (SDNPA) Neighbouring Authority Consultation Comments, Ref SDNP/17/05659/ADJAUT (Dated 5 December 2017) 1.6.3. Published Landscape Character Assessments are referenced from a National level, through Regional/County Level Landscape Character Assessments, such as The East Sussex Landscape Character Assessment (2016) including an exploration of the Newhaven LLCA No.34 (Urban Area) and Firle Bishopstone Downs LLCA No.21 (County Landscape Character Area). 1.6.4. The South Downs Integrated Landscape Character Assessment (ILCA) (2011) is referred to in particular the Landscape Types (LT) and Landscape Character Areas (LCA) within the study area. Mention is made to visual aspects and sensitivity to change. 1.6.5. Other Landscape Related Reports include Marine Character Areas (MCA) (2014) and the Lewes District Council and South Downs National Park Authority Landscape Capacity Study (2012). 1.6.6. Further to the above, B&A evaluated local landscape character at a more detailed level to provide a better understanding of the current landscape character of the Site and environs within c.1.5km. Figure L-DR4: Local Character Areas demonstrates the Local Landscape Characters identified. The 2017 LVIA clearly states that the B&A assessment is primarily based on current landuse, field work observations relating to visual amenity and the landscape setting and takes into account planning consents such as the Newhaven East Quay and Port Expansion Area (reference LW/15/0034). 1.6.7. See Section 4: Baseline Situation Review of the Addendum Report and Figure L-DR4 (Rev A): Local Character Areas which has been updated due to the Amended Development Site.

1.7. CONTRIBUTION OF THE SITE TO THE SETTING OF THE SDNP 1.7.1. SDNPA Comment: ‘The amount to which the site and its environs contribute to the landscape setting of the National Park has not been understood - therefore the impacts of the scheme on the national park have not been understood’. 1.7.2. B&A Response: The Site is located within the port area of Newhaven and includes existing commercial and industrial activities. Stage 1 to 3 of the Proposed Development is located within existing buildings or in close proximity to similar land uses. 1.7.3. Effects on landscape designations including the SDNP are explored and also through visual effects from close range views and specific viewpoint locations in both the 2017 LVIA and Addendum Report. 1.7.4. In the 2017 LVIA, in Section 4: The Baseline Situation, Sub-Section 4.4. Landscape Designations, refers to the South Downs National Park: View Characterisation and Analysis (November 2015) which examines views to, from and within the SDNP. Having reviewed the locations and landmarks selected, only one ‘Representative viewpoint’ falls within the study area applied for the 2017 LVIA, No. 51 Nore Down above Piddinghoe is

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Brett Aggregates Ltd. B&A Response to the South Downs National Park Authority (SDNPA) Neighbouring Authority Consultation Comments, Ref SDNP/17/05659/ADJAUT (Dated 5 December 2017) c.2.7km north-west from the Site and shown on Figure L-DR3 for reference purposes. 1.7.5. As noted in the 2017 LVIA, ‘Field work undertaken as part of the LVIA explored views towards the Site (and Proposed Development) from the South Downs National Park, northwest of Newhaven. Although the ZTV identifies isolated areas near Bollen’s Bush, intervening built form and vegetation together with the distance involved limits potential views. Section 7: Assessment of Visual Effects evaluates views from locations in the South Downs National Park from a broad arc (clockwise) north to east of the Site’. (paragraph 4.4.5) 1.7.6. In the Addendum Report, see Section 6: Effects On Landscape Character and Designations Review and Section 7: Assessment Of Visual Effects Review including Table 2.

1.8. CONTRIBUTION OF THE SITE TO THE SETTING OF NEWHAVEN FORT (SCHEDULED MONUMENT) 1.8.1. SDNPA Comment: ‘The amount to which the site and its environs contribute to the landscape and visual setting of the Scheduled Monument of Newhaven Fort have not been understood - therefore the impacts of the scheme on the national heritage asset have not been understood’. 1.8.2. B&A Response: In the 2017 LVIA, photomontages were included for five viewpoint locations, No’s 1 to 3, 8 and 11 and all photomontages have been updated for the Addendum Report. 1.8.3. Viewpoint Location 3: From car park near Fort Newhaven examines views for visitors and residents (High sensitivity). The 2017 LVIA refers to the vantage point at the Fort Newhaven car park which allows a much wider panorama of Newhaven Harbour as well as a more elevated and thus, broader view of the Site. Field work established that at Fort Newhaven, the aspect is primarily enclosed and offers its own history and visual context. 1.8.4. The 2017 LVIA also mentions the modern industrial uses which can be clearly seen whilst the SDNP, residential areas near Rookery Hill and the urban areas of Bishopstone and Seaford form the backdrop to the scene. It is noted that although of interest it does not offer a high level of scenic quality and the industrial character of the harbour is a key component in the view. In Stage 1, the aggregate processing plant and in Stage 2 the conveyor and storage areas would be seen albeit, they constitute only a minor component of the wider view. Whilst in Stage 3, the concrete batching and cement silos will just be discernible together with the southernmost limits of the Stage. In Stage 1 and 2 there will be a Small magnitude of impact and a Moderate (neutral) significance of effect. In Stage 3 there will be a Very Small magnitude of impact and a Minor (neutral) significance of effect. The Addendum Report concurs with the conclusions of the 2017 LVIA. 1.8.5. In the Addendum Report, see Section 7: Assessment Of Visual Effects Review including Table 2.

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Brett Aggregates Ltd. B&A Response to the South Downs National Park Authority (SDNPA) Neighbouring Authority Consultation Comments, Ref SDNP/17/05659/ADJAUT (Dated 5 December 2017) 1.9. SENSITIVITY OF THE SDNP 1.9.1. SDNPA Comment: ‘The landscape of the National Park is only considered to be of medium to high sensitivity. The SDNPA has significant concerns about this and would suggest this approach is fundamentally flawed. The National Park is a nationally important landscape and its sensitivities are most keenly felt around the edges of the designation’. 1.9.2. B&A Response: In the 2017 LVIA, Section 6: Effects on Landscape Character and Designations explored effects on landscape designations. It was acknowledged that the SDNP has a Very High sensitivity given its designation and the core central areas such as open downland etc. are found at some distance from the Site. A Medium to High landscape sensitivity was applied to the edge of the SDNP. 1.9.3. B&A applied the above landscape sensitivity based on background research and field work. As noted previously, B&A also carried out a local landscape character assessment to provide a greater understanding of the Site and environs (within c.1.5km). 1.9.4. The following summarises the guidance provided in the Guidelines for Landscape and Visual Impact Assessment (GLVIA Third Edition) (2013) and Landscape Character Assessments which support the approach adopted by B&A. GLVIA Third Edition 1.9.5. In the GLVIA Third Edition, Chapter 5 Assessment of landscape effects, under ‘Establishing the value of the landscape’, states that National Parks in England, Wales and Scotland are nationally valued landscapes. (paragraph 5.22) 1.9.6. The GLVIA Third Edition then notes the following which clearly allows for a difference in landscape value at a more local level, which can be established during the desk study element of the LVIA process and through field work, albeit, recognising the contribution of specific areas:  ‘… An LVIA should consider the implications of the full range of statutory and non-statutory designations and recognitions and consider what they may imply about landscape value’. (paragraph 5.22);  ‘The criteria and terms used in making statutory designations vary and may not always be explicitly stated. If a project subject to LVIA is in or near to one of them, it is important that the baseline study should seek to understand the basis for the designation and why the landscape is considered to be of value. Great care should be taken to understand what landscape designations mean in today's context. This means determining to what degree the criteria and factors used to support the case for designation are

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Brett Aggregates Ltd. B&A Response to the South Downs National Park Authority (SDNPA) Neighbouring Authority Consultation Comments, Ref SDNP/17/05659/ADJAUT (Dated 5 December 2017) represented in the specific study area’; and (paragraph 5.23)  ‘Desk study of relevant documents will often, although not always, provide information concerning the basis for designation. But sometimes, at the more local scale of an LVIA study area, it is possible that the landscape value of that specific area may be different from that suggested by the formal designation. Fieldwork should help to establish how the criteria for designation are expressed, or not, in the particular area in question. At the same time it should be recognised that every part of a designated area contributes to the whole in some way and care must be taken if considering areas in isolation’. (paragraph 5.24) Landscape Character Assessments The East Sussex Landscape Character Assessment (2016) 1.9.7. The study area adopted for the 2017 LVIA and Addendum Report features both ‘County Landscape Character Areas’ and ‘Urban Areas’. The former includes the Falmer Telscombe Downs LLCA No.18, Lower Ouse LLCA No.19 and Firle Bishopstone Downs LLCA No.21. Urban Areas comprise Peacehaven LLCA No.28, Seaford LLCA No.32 and the Newhaven LLCA No.34. The latter broadly occupies the central part of the study area and is adjacent to the aforementioned County Landscape Character Areas which fall within the SDNP. 1.9.8. For the 2017 LVIA, B&A examined the mapping for the Newhaven LLCA No.34 and Firle Bishopstone Downs LLCA No.21 and concluded that the Site should be located within the former. The text below reflects this assumption. Distance and direction is from the Site. 1.9.9. The individual ‘Characteristics’ of the LLCAs, ‘Problems, pressures, detracting features’ and mapping have been reviewed. It is important to note that the LLCAs extend beyond the study area adopted for the 2017 LVIA (i.e. c.3km from the Site). 1.9.10. Newhaven LLCA No.34 (including the Site): ‘Characteristics’ include ‘The scale of the heavy industry on the riverbanks, towering cranes, huge timbered wharfs and the size of the ferry, when it is in port, contrasts with the rows of small terraced cottages clustered up the hillsides’. Special features comprise Newhaven Fort, huge grey timbered quays, the Ouse Estuary wetlands and historic ruins at Tidemills. Whilst ‘Problems, pressures, detracting features’ are noted in terms of ‘Harsh, open built up edges to countryside and South Downs National Park’. 1.9.11. Falmer Telscombe Downs LLCA No.18 (c.920m south-west with a broad band expanding c.1.8km west): ‘Characteristics’ include a ‘High, bare scarp with coombes looking northwards and eastwards’ with ‘Remote areas away from the built up edges and C7 road’. In terms of ‘Problems,

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Brett Aggregates Ltd. B&A Response to the South Downs National Park Authority (SDNPA) Neighbouring Authority Consultation Comments, Ref SDNP/17/05659/ADJAUT (Dated 5 December 2017) pressures, detracting features’ direct reference is not made to Newhaven rather it is the ‘Continued urban expansion north of Peacehaven’. The study area adopted for the 2017 LVIA is on the southern periphery of the LLCA. 1.9.12. Lower Ouse Valley LLCA No.19 (c.1.5km north-west): ‘Characteristics’ include ‘Strategic Countryside Gap Between Newhaven And Lewes’ and ‘Transport Corridors In The Valley Floor Including Roads, Rail And River’. ‘Problems, pressures, detracting features’ feature the ‘Commercial and industrial development at southern end’ (i.e. of the LLCA). 1.9.13. Firle Bishopstone Downs LLCA No.21 (adjacent to the Newhaven LLCA No.34 having been reviewed by B&A): ‘Characteristics’ concentrate on landform features such as scarps, dipslopes, winding dry valleys and open downland and notes the ‘Remote Character Of Central Areas’. Having reviewed the mapping available, the study area adopted for the 2017 LVIA occupies the south-western edge of the Firle Bishopstone Downs LLCA No.21, as opposed to the higher elevations of scarp and the more remote central areas. The LLCA does not make reference to aspects of Newhaven under ‘Characteristics’ rather ‘Special Features’ include Tide mill and ‘Problems, pressures, detracting features’ comprise ‘Open built-up edges to south – Denton, Newhaven and Seaford’. 1.9.14. After considering the above, it is notable that the Newhaven LLCA No.34 and most of the LLCAs include commercial and urban ‘Characteristics’ with ‘remote areas’ at some distance from coastal towns such as Newhaven and Peacehaven. South Downs Integrated Landscape Character Assessment (ILCA) (2011) 1.9.15. The South Downs Integrated Landscape Character Assessment (ILCA) (2011) identifies 18 generic Landscape Types (LT) which are then sub- divided into component Landscape Character Areas (LCA). The information provided in the Study including the Technical Report has been reviewed. The following is taken from page ix to xi of the Technical Report. 1.9.16. The South Downs Landscape Character Summary identifies a number of ‘key integrating themes’ including ‘Variety and Contrast’ which describes the SDNP as ‘An extremely diverse and complex landscape’ and highlights local variations due to a combination of physical influences and historic and economic processes. A ‘landscape of contrast and juxtaposition’ offers the ‘perception of remoteness in close proximity to urban areas…’ (Bullet 1) 1.9.17. ‘Summary of Forces for Change’ makes reference to ‘the South Downs is a relatively narrow protected landscape, particularly to the east, with the expanding coastal plain development to the south and more developed landscapes of the Low Weald to the north. Only a very narrow area of high quality landscape remains – just a perception of remoteness and tranquillity, but this perception is an important element to conserve. Changes beyond the final boundary, such as night time glow of urban

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Brett Aggregates Ltd. B&A Response to the South Downs National Park Authority (SDNPA) Neighbouring Authority Consultation Comments, Ref SDNP/17/05659/ADJAUT (Dated 5 December 2017) development … all contribute to change within the South Downs…’ (Development Squeeze) 1.9.18. Forces for change, including landscape change outwith the SDNP boundary is mentioned in relation to ‘Development’ including visual aspects etc. Whilst ‘Erosion Of Isolated, Island Quality’, describes the ‘strong ‘island’ quality and sense of separateness/difference from the surrounding landscape’ which is partially due to ‘the very real contrasts between the South Downs and adjacent areas. Such contrasts include the often sharp transition from the adjoining urban landscape on the coastal plain or settled landscapes of the Weald’. Mention is also made to expanding urban areas and the light pollution of dark skies. 1.9.19. With regards to the above, there is an acknowledgement of the urban areas comprising part of the setting of the SDNP which creates a sense of contrast and juxtaposition. As noted, the Proposed Development will be located within an existing port area as opposed to a separate more open area outwith the environs of Newhaven. The sensitivity of the adjacent character areas to the Site and within the SDNP are clearly different compared to those in more remote central areas, and to apply a blanket category is too simple an approach. 1.9.20. Reference to Figure L-DR2: Landscape Character Classification in the 2017 LVIA which has been updated for the Addendum Report shows that the LCAs (and LTs) overlap specific LLCAs in the East Sussex Landscape Character Assessment (2016):  In the eastern part of the study area, the Ouse Floodplain LCA F2 (Major River Floodplains LT F) and Ouse to Eastbourne Open Downs LCA A1 (Open Downland LT A) overlap the Firle Bishopstone Downs LLCA No.21;  In the north-western part of the study area, the Ouse Floodplain LCA F2 (Major River Floodplains LT F) and a small part of the Ouse Valley Sides LCA G2 (Major Valley Sides LT G) overlap the Lower Ouse LLCA No.19; and  In the western part of the study area, the Adur To Ouse Open Downs LCA A2 (Open Downland LT A) and Ouse Valley Sides LCA G2 (Major Valley Sides LT G) overlap the Falmer Telscombe Downs LLCA No.18. 1.9.21. After examining their respective ‘Integrated Key Characteristics’, there are differences in relation to landform, sense of tranquillity and the influence of coastal towns such as Newhaven and Peacehaven. This is noted at both LCA and LT level. 1.9.22. For example, the Ouse Floodplain LCA F2 which is notable to the east of the Site, features a flat valley floor with ‘wet fences’ dividing pastures. Tranquillity is noted as being ‘affected by proximity of built development, trains on the mainline railway and traffic on the A27 (T) that crosses the

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Brett Aggregates Ltd. B&A Response to the South Downs National Park Authority (SDNPA) Neighbouring Authority Consultation Comments, Ref SDNP/17/05659/ADJAUT (Dated 5 December 2017) floodplain’. The Major River Floodplains LT F, states that ‘Key landscape sensitivities’ include ‘The flat, open and undeveloped character of the valley floors, which are particularly vulnerable to introduction of built elements, particularly large scale linear/vertical developments such as transmission lines or changes/extensions to development on the valley sides’. (paragraph F.19) ‘Development Considerations’ note ‘…Consider views to and from the adjacent valley sides and higher downland downs in relation to any change’. 1.9.23. For the Ouse to Eastbourne Open Downs LCA A1 which is further east of the Site, ‘Integrated Key Characteristics’ reference the open rolling uplands and dry valleys. Sensitivities specific to this particular LCA include traffic and development influence on tranquillity and remoteness. This is noted in terms of the edge of Seaford and Eastbourne as opposed to Newhaven, albeit the text mentions that ‘… the landscape is visually sensitive to change within the adjacent urban areas’ which can be applied more generally. (paragraph A1.8) In terms of the Open Downland LT A, ‘Development Considerations’ include ‘Consider effects of any development beyond the designated area on the South Downs landscape. In addition to being visible in views from the South Downs, secondary effects such as light spill, noise and increased traffic will all have an impact on the special qualities of remoteness and tranquillity associated with the Open Downs’. 1.9.24. To the north-west of Newhaven, the Ouse Valley Sides LCA G2 includes ‘Integrated Key Characteristics’ such as an extensive road network. No mention is made to views beyond the LCA or influences outwith the LCA or LT. 1.9.25. In the western part of the study area, in terms of the Adur to Ouse Open Downs LCA A2, ‘Integrated Key Characteristics’ include ‘... A strong sense of remoteness and tranquillity in close proximity to the south coast urban area…’ Sensitivities Specific to the Adur to Ouse Open Downs LCA A2 comprise ‘… the level of perceived tranquillity and remoteness which is being eroded by traffic pressures and urban development on the adjacent coastal plain - light pollution already impacts on dark skies. Given the proximity to and views over development on the coastal plain, this area is also especially sensitive to changes in the urban area beyond the study area’. 1.9.26. Having examined the above LCAs and LTs, there are relevant differences in terms of ‘Integrated Key Characteristics’ and Development Considerations’ etc. urban development influences are noted in regard to the environs of Newhaven, other settlements areas and due to the existing road network which form part of the setting of the SDNP. As mentioned the Proposed Development will be located within an existing port area as opposed to a separate more open area outwith the environs of Newhaven. Other Landscape Related Reports 1.9.27. In the 2017 LVIA, reference was made to the Marine Character Areas (MCA) (2014) and Lewes District Council and South Downs National Park Authority Landscape Capacity Study (2012).

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Brett Aggregates Ltd. B&A Response to the South Downs National Park Authority (SDNPA) Neighbouring Authority Consultation Comments, Ref SDNP/17/05659/ADJAUT (Dated 5 December 2017) Marine Character Areas (MCA) (2014) 1.9.28. The area south of Newhaven is categorised within the Selsey Bill to Seaford Head MCA 7. ‘Aesthetic and perceptual qualities’ include open downland and it is acknowledged that the coastline is largely developed and includes coastal towns. Lewes District Council and South Downs National Park Authority Landscape Capacity Study (2012) 1.9.29. The Lewes District Council and South Downs National Park Authority Landscape Capacity Study (2012) is listed as a background document for the Lewes District Local Plan Part 1, Joint Core Strategy 2010-2030 (Adopted May 2016 by Lewes District Council and June 2016 by the South Downs National Park Authority). 1.9.30. The Study examines ‘… areas surrounding the towns and villages across the District where it is considered that there is likely to be future development pressures’ (paragraph 1.2). It should be noted that this does not include the urban area of Newhaven which features the Site. Of particular note is the reference to Landscape Quality (Exceptional to Poor) and Landscape Value (Very High to Low) of the Landscape Character Areas. 1.9.31. Having examined the Landscape Character Areas within the study area which fall within the SDNP, the following is of note. 1.9.32. The D02 Ouse Estuary Nature Reserve applies to the edge of the SDNP to the east of the Site. It is categorised as a Good Landscape Quality which applies to ‘• Attractive semi-natural or farmed landscape with some distinctive features … • Some detracting features; • No ‘most tranquil areas’; and • Possible areas of remoteness, rarely exceptional remoteness’. It has a Medium/High Landscape Value. 1.9.33. According to the Study, a Medium Landscape Value applies to a ‘Typical and commonplace or in part unusual Good / Ordinary landscape quality’. Typical Scale would be ‘Regional, District or Local’ and Typical Examples/Features comprise ‘Generally undesignated but value expressed through local cultural associations or through demonstrable use. Possibly some remote countryside. Accessible wildlife areas of local value’. 1.9.34. A High Landscape Value would apply to a ‘Very attractive or attractive scenic quality and in part rare High/good landscape quality’. Typical Scale would be ‘National, Regional, District or Local’ and Typical Examples/Features are identified as ‘National Park, Areas of Great Landscape Value (or similar designation) or key elements within them’. 1.9.35. B01 Bishopstone/Norton Valley is at a further distance to the east and is beyond c.1.5km from the Site. It is categorised as an Exceptional Landscape Quality (i.e. ‘Rich, distinctive, unique or outstanding natural landscape character...’) and Very High Landscape Value (i.e. ‘Very attractive and rare exceptional landscape quality’).

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Brett Aggregates Ltd. B&A Response to the South Downs National Park Authority (SDNPA) Neighbouring Authority Consultation Comments, Ref SDNP/17/05659/ADJAUT (Dated 5 December 2017) 1.9.36. With respect to the other Landscape Character Areas within the study area, in terms of the SDNP, a Good Landscape Quality and Medium/High Landscape Value is most often recorded. 1.9.37. Based on the guidance provided by the GLVIA Third Edition and information available through Landscape Character Assessments etc., B&A maintains that the SDNP has a Very High sensitivity given its designation and the core central areas such as open downland etc. which are found at some distance from the Site. Whilst a Medium to High landscape sensitivity should be applied to the edge of the SDNP. 1.9.38. This is also supported by the tranquillity and dark skies mapping currently available and reviewed as part of the Addendum Report. 1.9.39. The Addendum Report concurs with the conclusions of the 2017 LVIA. Given the type and scale of each Stage involved and in light of the current baseline situation of built form comprising industrial land uses and permitted development including the Newhaven East Quay and Port Expansion Area (reference LW/15/0034). For Stage 1 to 3, there would be a Negligible magnitude of impact and significance of effect within a medium range (i.e. 500m) and at further distance. Potential visual effects from the SDNP were also examined through visual effects (as noted previously). See Section 6: Effects On Landscape Character and Designations Review of the Addendum Report.

1.10. LANDSCAPE CAPACITY 1.10.1. SDNPA Comment: ‘The section headed Landscape Capacity is meaningless and includes no evidence about the local landscape - the assessments of capacity are simply judgements - there is no transparency about how these were made and are clearly not based on any landscape evidence nor does it follow recommended guidance’. 1.10.2. B&A Response: In the 2017 LVIA, Sub-Section 6.5: Landscape Capacity explained how/why the conclusions relating to landscape capacity were reached. It considers landscape character sensitivity and potential effects upon the visual amenity. 1.10.3. Further to the Landscape Character Assessments referenced in the 2017 LVIA, B&A evaluated local landscape character at a more detailed level to provide a better understanding of the current landscape character of the Site and environs within c.1.5km. Figure L-DR4: Local Character Areas demonstrates the Local Landscape Characters identified (and has been updated for the Addendum Report). The 2017 LVIA clearly states that the B&A assessment is primarily based on current landuse, field work observations relating to visual amenity and the landscape setting and takes into account planning consents such as the Newhaven East Quay and Port Expansion Area (reference LW/15/0034). 1.10.4. The Proposed Development will be sited in the port area which currently includes commercial and industrial uses. For Stage 1 to 3, changes will occur in terms of the Site in terms of the proposed aggregate processing plant, conveyors, concrete batching and cement silos etc. They will be in

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Brett Aggregates Ltd. B&A Response to the South Downs National Park Authority (SDNPA) Neighbouring Authority Consultation Comments, Ref SDNP/17/05659/ADJAUT (Dated 5 December 2017) keeping with existing industrial uses and are of a suitable type and scale which will adhere to existing land uses. The 2017 LVIA concluded that effects would not be overbearing upon the current features of landscape value or in visual terms and there is sufficient ‘capacity’ to enable the Proposed Development without significant adverse effects to both the character and value of the adjoining landscape. See Section 6: Effects On Landscape Character and Designations Review of the Addendum Report.

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