Hastings Local Plan 2019-20 – 2039-40 A revised and updated submission from The Friends of Country Park Nature Reserve October 2020 Contents

A. Submission

1. Respecting Nature Reserve as a protected environment

2. Community involvement

3. Two additional priority themes

4. Addressing the priority themes 4.1 Climate change and the low carbon agenda 4.2 Supporting a diverse thriving economy 4.3 Creating healthy places with opportunities for more active lifestyles 4.4 Protecting and enhancing biodiversity 4.5 Equality of opportunity to access public assets

5. The need for different planning policies for Hastings Country Park

B. Supporting Information and Research Material

1. Description of The Hastings Country Park Nature Reserve

2. Who are The Friends of Hastings Country Park Nature Reserve?

3. Process and timetable for Public Participation

4. Content of the Plan

5. Priority themes 5.1 Addressing climate change and the low carbon agenda 5.1.1 Sustainable Energy Generation 5.1.2 Friends comments on development issues 5.2 Supporting a diverse thriving economy 5.3 Creating healthy places with opportunities for more active lifestyles

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5.4 Achieving growth while mitigating any impacts on and enhancing valued natural environment assets 5.5 Enhancing Biodiversity 5.6 Equality of Opportunity to access public assets

6. The current Development Management Plan as context

7. Nature Recovery

8. Further evidence and references 8.1 Friends of The Country Park Nature Reserve - Solar arrays in the nature reserve 8.2 High AONB Management Plan 2019-2024 8.3 East County Council - Landscape Character Assessment for the High Weald Coast 8.4 Sussex Wildlife Trust - Wild Coast Sussex 8.5 Natural England - Hastings Cliffs to Beach SSSI citation 8.6 Exeter University - eco-tourism 8.7 DEFRA - Research on the physical and mental health benefits of engagement with the natural world – in Hastings 8.8 Public Health England: Improving access to green spaces 8.9 NHS Clinical Commissioning Group 8.10 Groundwork South – Heritage Lottery application 8.11 Hastings Borough Council - Country Park Nature Reserve Management Plan 2010-2015 8.12 Combe Valley Countryside Park

9. Development Management Plan Focus Area 13: Hastings Country Park

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A. Submission

1. Respecting Hasting Country Park Nature Reserve as a protected environment (See section B1)

Hastings Council describes the reserve in the following terms: “Hastings Country Park Nature Reserve is the most prestigious area of biodiversity management in the Borough.” “Some of the most stunning views of the south east coast can be experienced from the cliff tops. It is difficult to overestimate the importance of the site to wildlife conservation on a national, international and local context.”

The Friends of Hastings Country Park Nature Reserve (FoHCPNR) is a community organisation of more than 180 mainly local people which aims to “protect, promote and enhance the natural environment of the Reserve”. We make this submission as a contribution to the production of the new local plan which is a foundation for a sustainable biodiverse future for Hastings.

Request 1 We call for the new local plan to identify, describe and celebrate the numerous qualities and diversity of the Country Park and the benefits of the designation of the country park as an Area of Outstanding Natural Beauty, SSSI, SAC, Local Nature Reserve and the East Hill being a Scheduled Monument.

2. Community involvement (Sections B2 and B3)

Meaningful, transparent and timely community engagement as set out in the Council’s Statement of Community Involvement (SCI) should be part of the process for developing the plan for it to have credibility and be supported by the community.

This submission refers to Appendix A of the report presented to Hastings Cabinet on 2 March 2020 which identifies several priority themes. We are concerned however that the themes have not come out of the process described in the Statement of Community Involvement to “help us (HBC) to understand community aspirations and concerns”.

Despite intentions described in the HBC SCI the Friends are yet to have substantive engagement with HBC. A preliminary submission from FoHCPNR to Hastings Council was made in April 2020. This revised and updated submission is our attempt to ensure that our views are properly and meaningfully considered.

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Request 2 We ask Hastings planning policy staff to keep FoHCPNR informed and involved in the planning policy development process in line with the Council’s statement of Community Involvement. (See Section B2 for FoHCPNR contact details)

3. Two additional priority themes

Three of the priority themes identified in the new plan have a particular significance for The Hastings Country Park Nature Reserve and these are considered in sections 4.1, 4.2 and 4.3 of this submission.

These themes are: • Climate change and the low carbon agenda • Supporting a diverse thriving economy • Creating healthy places with opportunities for more active lifestyles

In addition, the currently identified theme “achieving growth while mitigating any impacts on and enhancing valued natural environment assets” places “enhancing valued natural environment assets” as a secondary issue to achieving growth. We disagree with this emphasis.

Request 3

We recommend that a new separate theme of ‘protecting and enhancing biodiversity’ be added (to replace ‘enhancing natural environmental assets’ that are currently only associated with the ‘growth’ theme).

Request 4

We recommend inclusion of a further theme which seeks to provide equality of opportunity for residents and visitors to access public assets such as public open space.

4. Addressing the priority themes (See Section B5)

4.1 Climate change and the low carbon agenda

This submission is written in the context of the recently proposed (January 2019) and then withdrawn proposals from HBC for solar arrays in the Country Park,

Advice on this industrial solar array proposal was received by HBC from Natural England and led to the cancellation of the proposal in May 2020. https://www.hastings.gov.uk/content/regeneration/pdfs/HBC_Solar_Arrays_DAS_Re port_Redacted.pdf

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This advice from Natural England is very significant in terms of the future planning policies for Hastings Country Park.

Request 5

The plan must give proper consideration to the guidance contained in the National Planning Policy Framework particularly with regard to development within Areas of Outstanding Natural Beauty and the protection of SSSI’s and Nature Reserves.

4.2 Supporting a diverse thriving economy

Request 6

The plan should seek to build an eco-tourism offer for the area in collaboration with adjoining authorities, reserves, and landowners. This should include consultation with expert organisations and other interested NGO’s. The plan should provide the framework to enable and support recreation opportunities, and encourage eco-tourism while recognising that the Country Park is a Nature Reserve and any provision for and impact of human activities must not result in adverse impacts on nature.

4.3 Creating healthy places with opportunities for more active lifestyles

Hastings Country Park Nature Reserve is a key part of Hastings physical infrastructure that supports and enables achievement of local and national physical and mental wellbeing objectives.

Natural England’s People and Nature Survey has revealed that during April-June 2020, almost nine in 10 adults in England reported that protection of the environment is important to them personally. Nearly three quarters of adults were concerned about biodiversity loss in England.

Request 7

The plan should recognise the physical and mental health benefits of the Country Park Nature Reserve for local people and visitors.

Request 8

To support active lifestyle objectives the plan should provide for well- maintained paths for walkers crossing the Country Park extended out from, and towards, the soon to be approved England Coast Path into the surrounding areas making a web of paths covering a wide area.

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4.4 Protecting and enhancing biodiversity

Hastings Country Park Nature Reserve is managed in order to enhance biodiversity and it is the Friends’ position that this should be the paramount consideration for all policies relating to the country park within the plan.

“The fifth (2020) edition of the UN’s Global Biodiversity Outlook report, published by the Convention of Biological Diversity (CBD), provides an authoritative overview of the state of nature worldwide. The report notes the importance of biodiversity in addressing climate change, ………and acts as a wake-up call, and an encouragement to consider the dangers involved in mankind’s current relationship with nature: continued biodiversity loss, and the ongoing degradation of ecosystems, are having profound consequences of human wellbeing and survival”.

The keynote Making Space for Nature report in 2010 noted the importance of increasing the connectivity of England’s ecological network and that a step-change is required towards large-scale habitat restoration and recreation for the benefit of people and wildlife and that 'Private landowners, land managers and farmers have a crucial role to play in delivering a more coherent and resilient wildlife network.’ Ten years later, in September 2020, John Lawton, chair of the Making Space for Nature Panel, sent a letter to the Prime Minister calling for a £1bn Green Recovery Programme, recognising that the recommendations from the 2010 Review have not been delivered. The letter highlights 3 key areas for action: • Better protect and manage our remaining wildlife habitats • Deliver Ecological restoration at Scale • Bring Nature to People

The 2019 UK State of Nature Report noted: ‘At the UK scale, the abundance and distribution of species has, on average, declined over recent decades and many measures suggest this decline continues. There has been no let-up in the net loss of nature in the UK.’

Industrial scale energy production by solar arrays or wind turbines will have a negative effect on biodiversity.

The Evidence Base for the Local Plan presented on the Council’s website includes two Energy Studies prepared for HBC.

The first by Regen (June 2017) https://www.hastings.gov.uk/content/planning/planning_policy/aap- pdfs/Sustainable_Energy_Options_Study_by_Regen_SW_June2017.pdf

This considers locations for industrial scale solar arrays and excludes the Country Park from consideration as a “designated environmental area” (page 14 of the Study).

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The second by CLS Energy (June 2017) https://www.hastings.gov.uk/content/planning/planning_policy/aap- pdfs/Energy_Options_Study_by_CLS_Energy_June2017.pdf considers options for Wind Turbines and rules out sites in Hastings Country Park.

“attempting to install …. will be extremely contentious…. this is a very prominent location and as such, a turbine siting here will be relatively contentious. Species that have been sighted around the Hastings Country park in Ore include the dormouse, badgers and water voles. Bat species recorded within 2km of the site include Serotine, Daubenton’s bat, Natterer’s bat, Nathusius pipistrelle, Soprano Pipistrelle and Brown longeared bats… this site will be problematic in terms of a grid connection…..”

Request 9

The plan should be clear that industrial scale renewable energy installations within the Hastings Country Park Nature Reserve are inconsistent with the designations of Area of Outstanding Natural Beauty, SSSI, SAC and Local Nature Reserve and rule them out accordingly.

Request 10

The plan should strictly control any physical development in or close to the Hastings Country Park. Pressure for holiday accommodation within, or adjacent to the Country Park should be resisted as such development detracts from the reasons people want to visit.

Request 11 The Plan should seek to mitigate past impacts of incompatible development in particular there should be included in the plan proposals for landscape restoration and improvement, in particular, the visual screening of sites that have an adverse impact on the amenity of open spaces, footpaths and viewpoints etc such as caravans and lodges. (see ESCC Landscape Assessment- see B8.3)

Request 12 The plan should allow for the possibility of other environmentally friendly uses of existing agricultural land.

Request 13 The plan should actively pursue collaboration with other landowners and Council to identify and protect wildlife corridors and territories, potentially evolving into a partnership to deliver a Local Nature Recovery Strategy as envisaged Government policy for 30% of land to be for nature. https://www.gov.uk/government/news/pm-commits-to-protect-30-of-uk-land-in-boost-for- biodiversity

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4.5 Equality of opportunity to access public assets

Improving accessibility to the Nature Reserve is an important component in engaging people with nature. However, accessibility has to be carefully managed to ensure that in a Nature Reserve nature comes first. A Management Plan for the Country Park is currently awaited and needs to identify how sustainable transport to and within the nature reserve can best be encouraged and how this can be achieved in conjunction with East Sussex County Council and Rother District Council.

Request 14 The Plan should recognise any shortcomings and contain policies to improve or enable access, especially for the less able and those using active and sustainable forms of transport.

5. The need for different planning policies for Hastings Country Park

The Country Park is a significant physical area and its importance for nature conservation, health and wellbeing and strategic biodiversity enhancement mean that planning policies will need to be different to the rest of the Hastings area.

Request 15 The current Plan includes Hastings Country Park Nature Reserve as its’ own focus area and we recommend that the new local plan also includes the Country Park as a Focus Area or equivalent.

In addition to references included in the body of the submission we have included in Section B “ Supporting Information and Research Material”. This includes many additional items of supporting evidence from local, national and international organisations for HBC to evaluate when considering this submission and developing the Plan.

Note: In this submission “Hastings Country Park Nature Reserve” is also referred to for simplicity as “The Country Park” and “The Nature Reserve” or just “The Reserve”.

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B. Supporting Information and Research Material

1. Description of The Hastings Country Park Nature Reserve The Reserve is owned by Hastings Borough Council and the majority lies within Hastings Borough boundaries but the furthest Eastern part is within Rother District. Hastings Borough Council itself designated the Country Park as a Nature Reserve within the terms of National Legislation.

On its website the Council describes the Reserve - https://www.hastings.gov.uk/countryside-nature/naturereserves/naturereserves- hastings/hcp/ “Hastings Country Park Nature Reserve is the most prestigious area of biodiversity management in the Borough. It is the largest area of public open space in the borough.

The reserve consists of Hastings Cliffs Special Area of Conservation, Hastings Cliffs to Pett Beach Site of Special Scientific Interest and Hastings Country Park, as well as heritage designations such as scheduled ancient monument. The site is renowned as an area of archaeological importance.

The reserve is a beautiful area of ancient gill woodland, maritime cliff and slope, cliff top grassland and mixed heather, lowland meadow and sustainably managed farmland, all sitting with the High Weald Area of Outstanding Natural Beauty. The nature reserve covers 345 hectares (853 acres) of coastal gill woodlands, open pasture and cliff top grassland, together with five kilometres of dramatic soft rock cliffs and coastline.

Some of the most stunning views of the south east coast can be experienced from the cliff tops. It is difficult to overestimate the importance of the site to wildlife conservation on a national, international and local context.”

The current Development Management Plan describes the Country Park (Focus Area 13) as follows: http://www.planvu.co.uk/hbc2015/written/cptdm6.htm#fa13

“Hastings Country Park is Hastings' area of true countryside – and it is a very special area of countryside. Gradually acquired by the Borough Council over a century, it is made up of farmland, wooded glens and crumbling cliff tops that, together, make up an area of astonishing natural beauty; a wild, sea-edged landscape where rare plants and uncommon wildlife are present, in an environment little touched by development.” (The full text is presented in Section B9 to this submission)

The current plan, the Strategic Policy for the Eastern Area, includes this commitment: item g:

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“protect, manage and enhance the green network of nature areas and open spaces that include Hastings Country Park Nature Reserve and associated national and international designated wildlife areas such as Hastings Cliffs Special Area of Conservation and Hastings Cliffs to Pett Beach Site of Special Scientific Interest”

2. Who are The Friends of Hastings Country Park Nature Reserve?

The Friends of Hastings Country Park Nature Reserve is a community organisation of more than 180 mainly local people which works to “protect, promote and enhance the natural environment of the Reserve”. We organise events, publish a newsletter and have worked with the Council over many years. In 2020-21 we are pleased to be celebrating with the Council and Groundwork Trust the opening of a new visitor centre and working with them to enhance education, interpretation and volunteering.

We try to be vigilant when physical development proposals are presented that affect the Country Park and that will urbanise or industrialise this stunning, biodiverse natural space. Hastings Council’s development control policies have often successfully restricted development in the Nature Reserve though there are two notable exceptions: the holiday accommodation at Rocklands Holiday Park overlooking the East Hill and Ecclesbourne Glen; and the increasing development and visibility of caravan, cabin and mobile home parks.

Most recently, in 2019/20, Hastings Council’s own proposals for 10 acres of ground mounted solar arrays was a major concern for the Friends and many other local residents but was withdrawn after considerable local opposition and adverse advice from Natural England.

The significant advice from Natural England: https://www.hastings.gov.uk/content/regeneration/pdfs/HBC_Solar_Arrays_DAS_Re port_Redacted.pdf

The new Local Plan should provide the framework that will prevent urbanisation and industrialisation of the Country Park and its setting and promote and enable rectification and mitigation of adverse developments that have already taken place. The Friends are keen to work with Hastings Borough Council’s Planning Policy staff in achieving a new Hastings Local Plan that achieves the Friends objectives of protecting, promoting and enhancing the natural environment of the reserve. Contacts: www.friendsofhastingscountrypark.org email: [email protected] Chair: Michael Moor [email protected] Vice-Chair: Andrew Colquhoun [email protected]

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3. Process and timetable for Public Participation

The local Development Scheme approved by Hastings Cabinet on 2 March 2020 provides for public participation in Quarter 2 2020/21 (ie July to September 2020).

The Councils Statement of Community Involvement of December 2016 says of the Development Plan: https://www.hastings.gov.uk/content/planning/planning_policy/latest_news_consultati ons/467751/Adopted_SCI_Dec_2016.pdf

“ 4.6 Community involvement will be specifically invited at various stages of preparing a DPD (Development Plan Document) – the pre-production, production and submission stages. 4.7 Pre-production stage – early engagement with the statutory environmental bodies on the Scope of the Sustainability Appraisal will make sure that we have produced a sound framework against which the social, economic and environmental effects of the plan can be assessed. 4.8 This stage will also help us to understand community aspirations and concerns relating to the issues to be addressed by the particular DPD. This will take the form of informal engagement methods, which will involve, for example, meetings, correspondence or focus groups. Types of involvement here are participation and information giving.”

The Friends of The Country Park Nature Reserve had not been approached in the pre-production stage. The preliminary submission from FoHCPNR to Hastings Council in April 2020 was our attempt to have our voice heard before the draft plan is produced in line with paragraph 4.8 above of the Statement of Community Involvement.

Hastings Council have acknowledged receipt of our April submission but, at the time of writing, have not provided feedback or comments as requested by FoHCPNR. This revised and updated submission from FoHCPNR attempts to reflect and incorporate relevant local, regional and national developments since the preliminary submission.

We acknowledge that the Coronavirus will have had an impact on the timetable. We have twice requested a revised schedule (July and September 2020) but are yet to receive one.

An ‘early engagement questionnaire’ was issued by HBC in early September 2020 asking participants to nominate priorities from a pre-determined list and FoHCPNR responded to this, noting the preliminary submission from FoHCPNR and this updated version as evidence to inform the plan process. This simplistic questionnaire is not considered to be meaningful engagement with FoHCPNR and only a few days were given for responses.

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4. Content of the Plan

This submission refers to Appendix A of the report presented to Hastings Cabinet on 2 March 2020 which is at: https://hastings.moderngov.co.uk/documents/g3747/Public%20reports%20pack%20 02nd-Mar-2020%2018.00%20Cabinet.pdf?T=10

In paragraphs 20, 21 and 22 ‘some of the priority themes and issues that it (the Local Plan) will respond to’ are identified: ❖ addressing climate change and the low carbon agenda ❖ supporting a diverse thriving economy ❖ increasing the delivery of housing and sustainably designed homes including responding to the Government’s new annual target figure of 430 net new homes per year ❖ maximising delivery of affordable housing that meets local need ❖ promoting more sustainable transport ❖ creating healthy places with opportunities for more active lifestyles ❖ achieving growth while mitigating any impacts on and enhancing valued natural environment assets

As far as we are aware these themes have not come out of the pre-production stage of developing the Development Plan Document as would have been expected from a reading of the Councils Statement of Community Involvement of December 2016. The pre-production stage is, according to the policy, there to “help us to understand community aspirations and concerns”.

The report goes on to say that “several of these issues overlap and are complementary; but in some cases balanced approaches will need to be taken where these priorities conflict. These balanced policy approaches will need to be clearly set out through the Local Plan. In addition, the Local Plan cannot undermine the viability of developments and must be deliverable – if the plan is not deliverable it will fail the independent examination. Balanced policies; developing a robust evidence base including related to viability and deliverability; considering the sustainability impacts of the plan and effective community engagement, are all critically important to the development of the new Plan.”

5. Priority themes

Four of the priority themes identified for the new plan have a particular significance for The Hastings Country Park Nature Reserve: • Addressing climate change and the low carbon agenda (5.1) • Supporting a diverse thriving economy (5.2) • Creating healthy places with opportunities for more active lifestyles (5.3)

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• Achieving growth while mitigating any impacts on and enhancing valued natural environment assets (5.4)

These themes are considered in the sections below.

We consider that there should be two additional themes:

• Enhancing biodiversity (5.5) • Equality of opportunity to access public assets (5.6)

5.1 Addressing climate change and the low carbon agenda

5.1.1 Sustainable Energy Generation

Policy context

• The Council’s Plan must give proper consideration to the guidance contained in the National Planning Policy Framework particularly with regard to visual impact within Areas of Outstanding Natural Beauty.

• The Development Plan applicable to Hastings Country Park Nature Reserve will have to fit with other policies that will be in the Plan. For example, current policy HN8 (Biodiversity and Green Space) which states that:

“Development should result in no net loss of biodiversity or designated green space as defined on the Policies Map. The weight given to the protection of sites will be proportionate to their position in the hierarchy of internationally, nationally and locally designated sites. Development that would affect a designated site will only be permitted where there is an adverse impact on ecological, geological or biodiversity interests of the site if it can be demonstrated that the need for the development would outweigh the nature conservation interests”

The plan should have regard to the HBC reports that concluded that the Country Park was not suitable for ground mounted solar arrays or wind turbines.

Nevertheless proposals for solar arrays within the Hastings Country Park were prepared in 2019 and early 2020. Advice on the proposal was received by HBC in May 2020 from Natural England.

https://www.hastings.gov.uk/content/regeneration/pdfs/HBC_Solar_Arrays_DAS_Re port_Redacted.pdf

As a result of the advice from Natural England the project was cancelled. This advice from Natural England is very significant in terms of the future planning policies for Hastings Country Park.

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5.1.2 Friends comments on development issues

• Because of the undulating nature of the land any development within the Country Park is highly likely to be visible from key locations such as the England Coast Path and Fairlight Head. The Development Plan should protect key views.

• The Country Park is protected as part of the High Weald AONB, as a Nature Reserves, and as an SSSI's (either directly or indirectly by the Impact risk zone around the SSSI). The Development Plan is the first and vital line of defence for the environment. Full environmental impact assessments should be required for any substantial development.

• Land that is outside the SSSI but within the SSSI Impact Risk Zone in the Country Park is generally under agricultural cultivation. This is not Brownfield Land.

• The new Development Plan should define sites for commercial energy generation as industrial.

5.2 Supporting a diverse thriving economy

An eco-tourism vision for Hastings and Rother

Tourism is a major component of the Hastings economy. In 2017 the Hastings Observer reported “Cllr Kim Forward, then lead member for marketing at Hastings Borough Council, explained: “Tourism is vital for Hastings. It supports over 5,000 jobs in the town and generates over £266m for the local economy.”

The new Development Plan should identify and encourage polices that would encourage eco-tourism. This would help to diversify the current tourism base in Hastings which is focussed on traditional seaside activities, the arts and festivals. It would also help to grow visitor numbers to the area outside the summer peak season for popular activities such as walking and bird-watching which are more attractive in cooler weather. The plan must however recognise that the Country Park is a Nature Reserve and any provision for and impact of human activities must not result in adverse impacts on nature. In terms of actions, first, there are the physical linkages that the Council could make. Hastings Country Park Nature Reserve is at the Eastern edge of Hastings; indeed, part of the Country Park is in Rother District. An objective of the physical plan should be, in the long term, to link up the areas to the east of Hastings which are being maintained as nature reserves. This includes Nature Reserve and the privately owned land to the North of the Fairlight Road, in Rother District, that is being maintained as Stonelynk Valley nature reserve. https://stonelynkvalley.wordpress.com/contact/

Projects that are mutually beneficial for biodiversity and the public such as improved footpath signage and wildlife corridors could be instituted.

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In addition, network linkages and signing related to the England Coastal Path route through the Country Park, that is currently in development, will be required (see links in Access and Mobility section below).

The plan should encourage joint working with other organisations. We have in mind ways of encouraging co-operation between East Sussex County Council, Rother District Council, Groundwork, The Sussex Wildlife Trust and The National Trust. Visitor Centres should be opening in 2020 at both Hastings Country Park and Rye Harbour Nature Reserve and the Plan should build an eco-tourism offer for the area.

In a very local example of an eco-tourism focussed initiative Borough Council has a Downland Whole Estate Plan – a document laying out how the iconic area will be managed and maintained by the council over the next 25 years.

https://www.lewes-eastbourne.gov.uk/eastbourne-borough-council-news/council-sets-out- comprehensive-plan-for-eastbourne-downland/

An example of connected visitor attractions in neighbouring authorities, including Hastings, the ‘Coastal Culture Trail’ promotes arts venues and activities in Hastings, Bexhill and Eastbourne. http://coastalculturetrail.com/ A similar collaboration could be developed for the nature reserves along the coastal area.

An example of a joined up eco-tourism offer across a wide region is demonstrated by this Nature and Wildlife website for North Norfolk which is a single point of information on Nature Reserves, walking routes, bird watching and dark skies: https://www.visitnorthnorfolk.com/see-and-do/nature_and_wildlife.aspx

5.3 Creating healthy places with opportunities for more active lifestyles

The Country Park, the largest open space in Hastings is: “Somewhere to explore, to walk, to think and to link with nature”; “it’s refreshing, inspiring, healthy, peaceful and an escape from the everyday” (quotes from our members).

Hastings Country Park Nature Reserve is a key part of Hastings physical infrastructure that enables achievement of local and national objectives for quiet personal physical activity. It’s also a place for exercise and for group activities including formal and informal education.

In September 2020 the Chief Executive of the Environment Agency said Investing in nature is an investment in the NHS: https://www.gov.uk/government/news/investing-in-nature-is-an-investment-in-the- nhs-says-environment-agency-chief-executive

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5.4 Achieving growth while mitigating any impacts on and enhancing valued natural environment assets

The bottom line is that industrial scale renewable energy developments within the Hastings Country Park Nature Reserve are inconsistent with the purposes of the designations of Area of Outstanding Natural Beauty, SSSI, SAC and Local Nature Reserve. It’s also unlikely to be sustainable given the costs that will have to be met to balance the environmental and amenity damage that development will cause.

5.5 Enhancing Biodiversity

The new Development Plan should make it clear that the Council’s objective is to enhance biodiversity and not simply maintain what is already there. The farm fields at Hastings Country Park are an integral part of the Nature Reserve with, for example, planting that provides feed for birds and agricultural processes which limit the use of chemicals and meet the requirements of the Higher Stewardship Scheme.

The Development Plan should provide more opportunities for a more biodiverse approach to farming practice during the plan period by encouraging appropriate planting and habitat improvement.

Three reports set the picture:

(a) The United Nations Convention on Biological Diversity 15 September 2020 https://news.un.org/en/story/2020/09/1072292

“The fifth edition of the UN’s Global Biodiversity Outlook report, published by the Convention of Biological Diversity (CBD), provides an authoritative overview of the state of nature worldwide.

The report notes the importance of biodiversity in addressing climate change, and long-term food security, and concludes that action to protect biodiversity is essential to prevent future pandemics. The study acts as a wake-up call, and an encouragement to consider the dangers involved in mankind’s current relationship with nature: continued biodiversity loss, and the ongoing degradation of ecosystems, are having profound consequences of human wellbeing and survival.

(b) Making Space for Nature Defra

This is a keynote report to Defra in September 2010 by a panel chaired by Professor Sir John Lawton https://webarchive.nationalarchives.gov.uk/20130402170324/http://archive.defr a.gov.uk/environment/biodiversity/documents/201009space-for-nature.pdf

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Extracts from Foreword: ‘……as we argue in this report, increasing the connectivity of England’s ecological network is only one of the things we need to do if we are to stop the seemingly inexorable decline in the numbers of many species, and the continuing loss of valuable wildlife habitats. The report argues that we need a step-change in our approach to wildlife conservation, from trying to hang on to what we have, to one of large-scale habitat restoration and recreation, under-pinned by the re-establishment of ecological processes and ecosystem services, for the benefits of both people and wildlife. Private landowners, land managers and farmers have a crucial role to play in delivering a more coherent and resilient wildlife network.’ Ten years after the review, in September 2020, John Lawton, chair of the Making Space for Nature Panel, sent a letter to the Prime Minister calling for a £1bn Green Recovery Programme, recognising that the recommendations from the 2010 Review have not been delivered.

The letter is here: https://nbn.org.uk/wp- content/uploads/2020/09/MakingSpaceforNature_10years_final.pdf

It highlights 3 key areas for action: • Better protect and manage our remaining wildlife habitats • Deliver Ecological restoration at Scale • Bring Nature to People

(c) UK State of Nature Report

This is a data driven report from a partnership of conservation and research groups.

The 2019 summary report for England https://nbn.org.uk/wp-content/uploads/2019/09/State-of-Nature-2019-England- summary.pdf

‘At the UK scale, the abundance and distribution of species has, on average, declined over recent decades and many measures suggest this decline continues. There has been no let-up in the net loss of nature in the UK.’

5.6 Equality of Opportunity to access public assets

To satisfy equality, transport and health objectives the Country Park should be accessible to everyone as far as reasonably practicable provided there are no adverse effects on nature. The Plan should recognise any shortcomings and contain policies to improve access, especially for the less able and those travelling actively and sustainably.

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The following considerations are too specific for The Development Plan but they give a flavour of the policies that The Plan should encourage.

- Extending the hours of operation of the East Hill lift which is a key point of entry to the park for those unable to negotiate the slopes and steps from and to Hastings Old Town - Improving and marketing bus services that provide access to the Country Park via the bus stops along Fairlight Road - Supporting and promoting bus services that link the Country Park with other Nature Reserves such as Rye harbour and Combe Valley Countryside Park - Assessing the safety and condition of the walking route into the Country Park via Barley Lane from the official Country Park car-park located off Fairlight Road - Reducing adverse impacts of motor traffic on wildlife and visitors, especially on Fairlight Road, by considering speed reduction measures. (eg 40mph throughout ) - Development of the England Coastal Path through the Country Park See proposal for Tackleway (Hastings) to Cliff End (Pett)

https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attach ment_data/file/867079/eastbourne-camber-report-5.PDF

As a strategic document the plan could support commissioning a Travel Plan for the Country Park to promote sustainable access while managing any adverse impacts on the core biodiversity objectives of the Country Park.

6. The current Development Management Plan as context

The current Development Management Plan includes Hastings Country Park Nature Reserve as Focus Area Number 13. This is included as Section B9 of this document.

It’s appropriate that The Country Park is a Focus Area because it’s a significant physical area and planning policies will be different to that appropriate to the Hastings urban area.

Following the withdrawal of proposals for solar panel arrays in the Country Park, changes to the Focus Area 13 statement might include in the Section headed : “Our Vision for Hastings Country Park” confirmation that Hastings Country Park Nature Reserve is not suitable for industrial scale development including wind and solar energy generation.

The current local plan includes the following statements and we would expect these, or similar wording, to be incorporated in the new plan:

Landscape 6.44 Of particular significance to Hastings is the nationally designated High Weald Area of Outstanding Natural Beauty (AONB), which covers 18% of the

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Borough. The AONB closely follows the Borough’s administrative boundary to the north but to the east takes in the whole of Hastings Country Park and the Hastings Cliff Special Area of Conservation. Hastings Country Park represents the best coastal section of the AONB. The Council recognises the importance of protecting this nationally important landscape, and major development should not take place in the AONB save in exceptional circumstances as outlined at paragraph 116 of the NPPF5.

In the Strategic Policy for the Eastern Area: Item g: “protect, manage and enhance the green network of nature areas and open spaces that include Hastings Country Park Nature Reserve and associated national and international designated wildlife areas such as Hastings Cliffs Special Area of Conservation and Hastings Cliffs to Pett Beach Site of Special Scientific Interest”

7. Nature Recovery

There is a great and urgent need for the creation of connected spaces for wildlife by joining up existing landholdings. We believe that there are opportunities and growing support for collaborative working between local authorities, conservation groups, landowners and managers to create enhanced spaces for wildlife. The Local Plan should include policies that enable and support such initiatives in and around Hastings and into Rother District.

In August 2020 DEFRA announced that Five local authorities had been selected to trailblaze England’s nature recovery pilots. https://www.gov.uk/government/news/five-local-authorities-announced-to-trailblaze- englands-nature-recovery-pilots ‘The pilots will enable local authorities to set out their local priorities for restoring and linking up habitats so species can thrive, and agree the best places to help nature recover, plant trees, restore peatland, mitigate flood and fire risk, and create green spaces for local people to enjoy’

“The forthcoming Environment Bill https://www.gov.uk/government/publications/environment-bill-2020 will go even further – requiring all areas in England to establish Local Nature Reserves. This will help bring a broad range of groups together – from farmers to businesses to local communities – to deliver priorities for nature recovery at a local and national level. The pilots will also help kick-start the creation of over a million acres of habitats for wildlife”

Larger areas of enhanced habitats in Southern England

Examples that are already delivering substantively larger and enhanced habitat for wildlife and biodiversity recovery are at Wickham Fen in East Anglia and Purbeck Heath in Dorset. These reserves are being created by connecting land through

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Wickham Fen https://www.edp24.co.uk/business/farming/wild-east-rewilding-project-launched-in- east-anglia-1-6698319 https://www.theguardian.com/environment/2020/jul/14/farmers-wildeast-hatch-plan- return-area-size-dorset-wild-nature-east-anglia

Purbeck Heath https://www.dorsetaonb.org.uk/purbeck-heaths-national-nature-reserve/ https://www.nationaltrust.org.uk/features/uks-first-super-nature-reserve-created-at- purbeck-heaths

8. Further evidence and references

In addition to the references included in the body of this submission, there is a large body of additional evidence from local, national and international organisations to be examined in support of this submission from FoHCPNR.

These are presented in this section, generally as external links with some supporting narrative.

8.1 Friends of The Country Park Nature Reserve - Solar arrays in the nature reserve Although a decision has been made by HBC not to proceed with the solar array development in the Country Park, for completeness, we include this briefing note on the proposal posted by FoHCPNR in January 2020: https://www.friendsofhastingscountrypark.org/news/solar-arrays-in-hastings-country- park-nature-reserve-a-briefing-note

8.2 High Weald AONB Management Plan 2019-2024 http://www.highweald.org/high-weald-aonb-management-plan.html

8.3 East Sussex County Council - Landscape Character Assessment for the High Weald Coast https://www.eastsussex.gov.uk/media/6739/area-12-high-wealden-coast.pdf

8.4 Sussex Wildlife Trust In July 2020, Sussex Wildlife Trust launched ‘Wild Coast Sussex - an exciting new project to connect coastal communities with their beautiful Sussex seas’ Wild Coast Sussex will target communities all along the Sussex coast with extra focus on Hastings, Bexhill, Eastbourne, , and Selsey.

20 https://sussexwildlifetrust.org.uk/news/wild-coast- sussex?utm_source=Sussex+Wildlife+Trust+Newsletter&utm_campaign=2332f36b0f -23_July2020&utm_medium=email&utm_term=0_9f7e3b5ad3-2332f36b0f- 292606925&mc_cid=2332f36b0f&mc_eid=c4a16757ec&fbclid=IwAR1hG20kJ0zfAB FpIvj0RhZfhIC-yo7Ye4yFNiLjb5r0buE0iMQpYmwO4UU

8.5 Natural England - Hastings Cliffs to Pett Beach SSSI citation https://designatedsites.naturalengland.org.uk/PDFsForWeb/Citation/1002885.pdf

8.6 Exeter University - eco-tourism Research at The University of Exeter on the value and management of sustainable eco-tourism. For example: http://socialsciences.exeter.ac.uk/politics/newsandevents/news/articles/researchpart nersjoinforce.html

8.7 DEFRA - Research on the physical and mental health benefits of engagement with the natural world – in Hastings The social research organisation Renaisi, https://renaisi.com/ have been engaged by DEFRA to “conduct a research project to deliver greater understanding and insight into how people most at risk of poor mental health and wellbeing in England can be best supported to increase their use and access to the natural environment for improved mental health and wellbeing”. The lead researcher is Dr Louisa Thomson Hastings is one of the four deprived locations with poor health that they have chosen to study. The results of their research are awaited.

8.8 Public Health England: Improving access to green spaces Public Health England (PHE) have published Improving Access to Greenspace – A new review for 2020 which builds on PHE's 2014 briefing on this topic, highlighting new evidence and actions to help local areas consider how good-quality greenspace can support the delivery of health, social, environmental and economic priorities, at a relatively low cost.

8.9 East Sussex NHS Clinical Commissioning Group The Healthy Hastings and Rother Project – see http://www.hastingsandrotherccg.nhs.uk/your- health/healthyhastingsandrother/#:~:text=In%20the%20summer%20of%202014,live %20healthy%20and%20happy%20lives.

8.10 Groundwork South A considerable body of evidence was collected by Groundwork South Trust in order to make their successful application to the Heritage Lottery Fund for £277,000 to support volunteering, education and interpretation in the Country Park. https://hiddenhastings.org.uk/

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8.11 Hastings Borough Council - Country Park Nature Reserve Management Plan 2010-2015 This, the latest Management Plan for the Country Park Nature Reserve explains the way that the area was is managed as a whole https://wildhastings.files.wordpress.com/2010/09/hcpnr-man-plan-2010-2015.pdf The plan explains (page 4) that “the Hastings Country Park Restoration Project was established to bring all the council’s land under one sustainable management for the benefit of people and wildlife.” An updated plan is awaited.

8.12 Combe Valley Countryside Park http://combevalleycountrysidepark.com/park-history/finding-the-park

9. Hastings Development Management Plan adopted September 2015 Focus Area 13: Hastings Country Park

© Crown Copyright and database rights [2015]. OS [100021328]. Use of this data is subject to terms and conditions.

Introduction to the Hastings Country Park Planning Focus Area 6.292 Hastings Country Park is Hastings' area of true countryside – and it is a very special area of countryside. Gradually acquired by the Borough Council over a century, it is made up of farmland, wooded glens and crumbling cliff tops that, together, make up an area of astonishing natural beauty; a wild, sea-edged landscape where rare plants and uncommon wildlife are present, in an environment little touched by development. This special character is recognised through the area's legal status too. Declared a nature reserve in 2006, it is a Site of Special Scientific Interest (SSSI), and also a Special Area of Conservation (SAC), a designation which gives it special protection under European law. But it is not a wilderness; people have lived and worked here for thousands of years, and the area has a wealth of archaeology to prove this. 6.293 The Country Park also includes within its boundaries the Shearbarn holiday village, one of the primary tourist accommodation sites in the Borough, with camping grounds, caravans and log cabins high on the clifftops looking out over the sea, as well as the smaller Rocklands caravan park.

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6.294 The Hastings Country Park Focus Area takes in slightly more than the Country Park nature reserve, including the curiously named 'Bachelor's Bump' area at the north-east corner of the Borough. This is where most of the people in this area live, although there are a few small pockets of housing in the Country Park itself, mostly old agricultural housing, coastguard cottages, and the impressive Fairlight Place. Most of this housing is now in private ownership, although almost all of the Country Park is owned and managed by the Council. Even so, while this is the largest of our local Focus Areas by area, it is the smallest by population: only around 1,800 people live here, with over a quarter of them above retirement age (according to 2001 Census data). 6.295 The people who live in this Focus Area generally need to travel to access shops and services, as there are few within it. Road connections to Hastings Town Centre are good, and there are bus routes that pass through, and the presence of these is important to avoid problems of isolation. 6.296 This is an area where the natural environment is of paramount importance. That means maintaining the unspoilt character of the place for those who visit and live there, but more importantly, preserving the rare and sensitive habitats for the park's astonishingly varied flora and fauna.

Our Vision for Hastings Country Park 6.297 Any development anywhere in the Country Park Focus Area would be tightly managed by existing planning restrictions that apply in SSSIs and the High Weald Area of Outstanding Natural Beauty (AONB), so we are not intending to identify much additional housing in this area to help us meet our overall housing target. Minor development outside of the Country Park itself could be considered, if it were unobtrusive and wholly in keeping with the character of the AONB and would not have an adverse effect on the integrity of the SAC. Within the park, any development would be limited to facilities that enhance the park environment and the 'visitor experience' – for example, a new visitor centre and café that fits with the Country Park's aesthetic, or buildings needed for low level sustainable agriculture. Any development would need to be sensitively built and in keeping with the natural environment. We would envisage that any structures in the park would be environmentally sensitive in their methods of construction, use of renewable energy and water conservation. Environmentally sensitive projects for sustainable energy generation could also be considered. We would want to retain tourist accommodation at Shearbarn and Rocklands too, although any development there would also need to be environmentally sensitive and limited entirely to tourist accommodation. 6.298 The potential of the Country Park to help local people, especially young people, gain experience in the crafts and skills that are used to maintain an area like this should not be overlooked. So while there would be little additional housing development, there is the potential for employment uses, largely of existing buildings, which fosters this kind of activity.

Michael Moor Chair The Friends of Hastings Country Park Nature Reserve October 2020

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